OVERVIEW

All personal data collected from this site complies with the principles of the EU GDPR Data Protection Act. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation). By accessing this site you agree to the terms of this privacy policy and consent to the collection, processing, use or transfer of data as set out in this policy.

For the purpose of the processing personal data, we may engage data processors and/or, at its sole discretion, hire other persons to perform certain functions on behalf of Rowan Rewards. In such cases, we shall take necessary measures to ensure that such data is processed by the personal data processors in accordance with instructions of and applicable European Union legislation. Shall also require the personal data processors to implement appropriate measures for the security of personal data. In such cases, we shall ensure that such persons will be subject to the non-disclosure obligation and will not be able to use this information for any other purpose, except to the extent necessary to perform the functions assigned to them.

ACCEPTANCE AND USE

This privacy policy covers Rowan Rewards and its subsidiaries including (collectively, "Rowan Rewards," "we" "us" or "our"). We are based in London, England. By using our services, you accept this privacy policy, which is part of our terms of service. We may modify this privacy policy from time to time. We will post any modified version of our privacy policy on our website. If we change the privacy policy in a way that materially lessens our commitments to you, we will provide notice to registered users by email or other methods.

DATA PROTECTION PRINCIPLES

“Personal data” means any information that enables us to identify you or the beneficiary of your transaction with us, directly or indirectly, such as name, email, address, telephone number, any form of identification number or one or more factors specific to your or your beneficiary’s identity.

We are committed to complying with applicable data protection laws and will ensure that personal data is:

• Used lawfully, fairly and in a transparent way;
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
• Relevant to the purposes we have told you about and limited only to those purposes;
• Accurate and kept up to date;
• Kept only as long as necessary for the purposes we have told you about;
• Kept

DATA WE COLLECT ABOUT YOU

Rowan Rewards may collect two (2) types of information about you: personal and non-personal.

PERSONAL INFORMATION WE COLLECT ABOUT YOU (PIPEDA)

According to the federal personal information protection and electronic documents act, 2000 (PIPEDA), “personal information” means information about an identifiable individual. The information you provide to Rowan Rewards is considered personal information. Failure to provide all information required by Rowan Rewards may prevent access to any or all Rowan Rewards materials, and failure to maintain accurate information may also result in suspension or termination of access to any or all Rowan Rewards materials.

TYPES OF DATA WE COLLECT FROM YOU

Personally Identifiable Information (PII). We acquire PII that may include, in certain contexts, your name, postal address, post code, email address, and telephone number. We also acquire your IP address, User ID, and/or Device ID, which certain jurisdictions consider to be PII because it could be used to identify an individual or device if it were combined with other identifying information.

Registration. Prior to using one or more of the Rowan Rewards materials, Rowan Rewards may require certain personal information and non-personal information to create an individual account (“account”) or to enable features or functionality of the Rowan Rewards materials. Failure to provide all required information required by Rowan Rewards may prevent access to any or all Rowan Rewards materials, and failure to maintain accurate information may result in suspension or termination of access to any or all Rowan Rewards materials.

Sensitive PII. In certain circumstances, such as when purchasing a service, you may provide a credit, debit, or payment account number, or other payment information to our payment gateway provider such as PayPal which we recognise as more sensitive than other PII. We generally do not request on or through the service other data that is often considered “highly sensitive,” such

as other financial account information (e.g., credit report information, bank account numbers), or government issued identification numbers (e.g., drivers’ license number, or passport number), although we reserve the right to do so when such data is necessary to offer you certain services.

Anonymous Data. Some of the data that we acquire cannot identify, distinguish or trace you or your Device, even if combined with other identifying information, and some data that could be considered PII when combined with other identifying information is not used in a way that identifies, distinguishes or traces you or your device, but is instead used in an anonymous way, often aggregated with other anonymous data about other users.

Cookies and other tracking technologies: Rowan Rewards and our third-party partners, such as our advertising, data collection and analytics partners, use cookies and other tracking technologies (e.g., web beacons, device identifiers and pixels) to provide functionality and to recognise you across different services and devices. For more information, please see our cookies and tracking notice, which includes information on how to control or opt out of these cookies and tracking technologies.

NON-PERSONAL INFORMATION

Non-personal information refers to information that, by itself, does not identify you as a specific individual (e.g. demographic information or web site visitations). Rowan Rewards may collect non-personal information through any of the methods discussed above as well as automatically through use of industry standard technologies described further below.

INFORMATION COLLECTED THROUGH TECHNOLOGY

While you are able to visit the Rowan Rewards site and remain anonymous, Rowan Rewards or its third party service providers may still collect non-personal information about your use of the Rowan Rewards materials (e.g. your internet browser, operating system, IP address, connection speed, and the domain name of your internet service provider). Such information may be gathered by the following methods:

• Cookies, including local shared objects, are small pieces of information that are stored by your browser on your computer’s hard drive which work by assigning to your computer a unique number that has no meaning outside of the Rowan Rewards site. Cookies do not generally contain any personal information. Most web browsers automatically accept cookies, but you can usually configure your browser to prevent this. Not accepting cookies may make certain features of the Rowan Rewards materials unavailable to you.
• IP address. You may visit many areas of the Rowan Rewards site anonymously without the need to become a registered Even in such cases, Rowan Rewards may collect IP

addresses automatically. An IP address is a number that is automatically assigned to your computer whenever you begin services with an internet services provider. Each time you access the Rowan Rewards site and each time you request one of Rowan Rewards’ pages, the server logs your IP address.

• Beacons. Beacons are small pieces of data that are embedded in web pages and e-mails. Rowan Rewards may use these technical methods in html e-mails that Rowan Rewards sends to users to determine whether they have opened those e-mails and/or clicked on links in those e-mails. The information from use of these technical methods may be collected in a form that constitutes personal
• Tracking content usage. If you use the Rowan Rewards services and you post audio visual materials including, without limitation, text, logos, artwork, graphics, pictures, advertisements, sound and other related intellectual property contained in such materials (collectively, “content”) to your app site or to a third party app site, Rowan Rewards tracks and captures non-personal information associated with user accounts and the use of

OTHER INFORMATION YOU MAY SUBMIT

You may submit data to us for limited purposes such as requesting customer support; answering a questionnaire; participating in a study; entering contests or sweepstakes; or signing up to receive communications from us or another user.

PAYMENT PROCESSING AND PAYMENT PROCESSOR

Payments made by Rowan Rewards are made through PayPal payment gateway provider, credit or debit card. Information which you supply to PayPal, credit or debit card is not within our control and is subject to PayPal, credit or debit card privacy policy and terms and conditions.

AUTOMATICALLY-COLLECTED INFORMATION

We automatically collect certain types of data when you use our services, regardless of whether you have an account. This data includes your IP address, technical information about your device (e.g., browser type, operating system, and basic device information), the web page you visited or search query you entered before reaching us, and your activities. We may track your activities using cookies and similar technologies. By using our services, you agree to our use of these methods as set forth in our cookie policy.

HOW WE USE YOUR DATA

We may use your data for the following purposes:

• Identification and authentication: we use your data to verify you when you access your
• Communicating with you: we use your data when we communicate with you (e.g., when we respond to a customer support or other inquiry).
• Improving our services: we use your data to understand how our services are being used and how we can improve them. In general, we analyse aggregated data, rather than specific user data. We may, however, need to analyse a specific case to address a specific problem (e.g., a bug that affects only a few accounts).
• Customising your experience: we use your data to personalise the service to you. This may include remembering your preferences for language or volume or displaying app that you might enjoy, based upon your viewing
• Marketing and advertising: we use your data to display ads and send you offers. We may also use your data in delivering third-party advertisements to you. This may include "targeted ads" based upon your activities.
• Exercising our rights: where reasonably necessary, we use your data to exercise our legal rights and prevent abuse of our service. For example, we may use your data to detect and prevent fraud, spam, or content that violates our terms of
• Legal compliance: we use your data where we are legally required to do For example, we may need to gather your data to respond to a subpoena or court order.
• Protecting your information: where appropriate, we may anonymise, backup, and delete certain

We may use algorithms and other automated means to implement any of the above.

REMARKETING ON THE WEBSITE AND SERVICES

If you have provided your consent by accepting targeting cookies on the website, we may use Google AdWords (remarketing and Similar Audience features) and Facebook Ads. You can review the Rowan Rewards cookie policy which includes details on how to customise your cookie settings.

GOOGLE ADWORDS

Google AdWords enables Google, through the use of cookies, to identify the fact that you have visited the website, to identify aspects of your usage of the website and combine that with what it knows about your usage of other websites in the Google ad network.

We use these services to advertise to visitors of Google ad network websites who have previously visited our website or who Google deems to have shared interests with visitors of our

website. Google’s collection and use of your personal data is covered by the Google privacy policy. You can set preferences for how Google advertises to you using the Google Ad preferences page.

WITH WHOM WE SHARE YOUR DATA

We share data with third parties as follows:

• With your consent: we may share your data with third parties where we have obtained your express consent to do so. You may revoke these
• Authorised vendors: we may share your data with third-party vendors that help us operate our services, process payments, and comply with your instructions and our contractual obligations. This includes payment processors, content delivery networks (cdns), cloud-based hosting services, monitoring services, email service providers, quality assurance and testing vendors, fraud and abuse prevention vendors, customer relations management (crm) vendors
• Advertising: we may share your data with advertising companies to display relevant ads to you. Unless you expressly agree, we will not share or sell your name, email address, or physical address with such persons.
• Analytics: we may share your data with persons who provide analytics showing how customers are using our services.
• Affiliates and advisors: we may share your data with our affiliates company, and our auditors and advisors for planning, financial reporting, accounting, auditing, tax filings, and legal compliance. Unless you expressly agree, we will not share your data with our parent or any affiliate for other purposes, such as direct
• Certain legal situations: we may share your data where we believe disclosure is necessary to comply with a legal obligation or in connection with a corporate
• Aggregated or anonymised information: we may publicly disclose non-personal aggregated or anonymised information such as our number of visitors and registered

DATA RETENTION

We retain your data for as long as you have an account. When you close an account, we will delete your personal information. We may retain logs of automatically collected information (for internal analytics); your email address; your tax information; communications with you; and your transactional information (for auditing, tax, and financial purposes). When we no longer have a business reason for retaining data, we will delete or anonymise it.

If we receive legal process pertaining to your account, we will retain your data for as long as we in good faith believe is necessary to comply with the legal process. Similarly, if we believe that

your account has been involved in wrongdoing, we may preserve your data to defend or assert our rights.

YOUR PRIVACY CHOICES

We enable you to make numerous choices about your data:

• You may choose not to provide us with certain information. For example, you may choose not to create an account or not to provide optional account information.
• You may change your account and video privacy settings. You may change or correct information voluntarily submitted to us. We encourage you to keep your data current by viewing your settings page.
• You may opt out of receiving commercial emails from
• You may limit the use of See our cookie policy for options.
• You may close your account
• Users from certain countries may have additional

SECURITY MEASURES FOR SAFEGUARDING YOUR INFORMATION

Rowan Rewards takes appropriate security measures to protect against unauthorised access, alteration, disclosure or destruction of personal information. These include, but are not limited to, internal reviews of: (a) Rowan Rewards’s data collection; (b) storage and processing practices; (c) electronic security measures; and (d) physical security measures to guard against unauthorised access to systems where Rowan Rewards stores personal information. All Rowan Rewards employees, contractors and agents who access personal information are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution or unauthorised use or disclosure of personal information.

THIRD-PARTY APP SITE AND LINKS

The Rowan Rewards contents may contain links to third parties who may collect personal information and non-personal information directly from you. Additionally, Rowan Rewards may use third parties to provide components of the Rowan Rewards contents. In either case, such third parties may have separate privacy policies and data collection practices, independent of Rowan Rewards. Rowan Rewards: (a) has no responsibility or liability for these independent policies or actions; (b) is not responsible for the privacy practices or the content of such website; and (c) does not make any warranties or representations about the contents, products or services offered on such website or the security of any information you provide to them

EMAILS COMMUNICATIONS

By creating an account, you consent to receive commercial emails from us. This includes newsletters and offers. Users from certain countries may have the ability to opt out or opt in at the time of account creation. All users may decline to receive commercial messages in their account settings. Please note that any opt-out request may take several days to process and you will continue to receive transactional emails from us (e.g., emails confirming transactions and/or providing information about your account).

DATA SECURITY

We are committed to maintaining the security of your personal data and have measures in place to protect against the loss, misuse, and alteration of the data under our control. We employ modern and secure techniques to protect our systems from intrusion by unauthorised individuals, and we regularly upgrade our security as better methods become available.

Our data centers and those of our partners utilise modern physical security measures to prevent unauthorised access to the facility. In addition, all personal data is stored in a secure location behind firewalls and other sophisticated security systems with limited (need-to-know) administrative access.

All our employees who have access to, or are associated with, the processing of personal data are contractually obligated to respect the confidentiality of your data and abide by the privacy standards we have established. Please be aware that no security measures are perfect or impenetrable. Therefore, although we use industry standard practices to protect your privacy, we cannot (and do not) guarantee the absolute security of personal data.

The website may offer chat rooms, Chatbots, forums, message boards, or news groups to users. It is important to remember that any information disclosed in these areas becomes public information. Accordingly, as with any public forum, you should exercise extreme caution when deciding whether to disclose your personal information.

GDPR STATEMENT FOR (EEA USERS)

This applies only to natural persons residing in the European economic area (for the purpose of this section only, "you" or "your" shall be limited accordingly). It is Rowan Rewards' policy to comply with the EU'S general data protection regulation (GDPR). In accordance with the GDPR, we may transfer your personal information from your home country to United Kingdom (or other countries) based upon the following legal frameworks:

• Legitimate business interests: we could not provide our services or comply with our obligations to you without transferring your personal information to United Kingdom
• Consent: we may transfer your personal information when we receive your express, revocable

• Our use of standard contractual clauses (also known as "model clauses") where
• You have the right to: opt out of non-essential cookies (see our cookie policy); access, correct, delete, restrict, or object to our use of your personal information; be forgotten; port your data; and withdraw consents.

We enable exercise of these rights primarily through our services (which we reserve the right to modify). We also fulfil our obligations in response to direct requests. We will endeavor to process requests within one month. Please note that we may not be able to comply with requests to the extent that they would cause us to violate any law or infringe any other person's rights. We reserve the right to request appropriate identification. We will process requests free of charge unless they would impose an unreasonable cost on us.

If you have a request, complaint or inquiry, please contact our data protection officer at the address listed below. We are committed to working with you to obtain a fair resolution of any issue. You also have the right to file a complaint with the supervisory data protection authority of your jurisdiction.

PRIVACY COMPLAINTS PROCEDURE

Where you believe that we have not complied with our obligations under this Privacy Notice, or the applicable law, you may have the right to make a complaint to a relevant Data Protection Authority or through the courts. Although not required, we would encourage you to let us know about any complaint you might have and Rowan Rewards will respond in line with our complaints procedure – our contact details are set out in the contact us section below.

We want to deal with your concerns fairly, effectively and promptly. However, some complaints are more complex than others and may take some time to investigate.

• We will acknowledge your complaint promptly after receiving it
• We will keep you informed throughout any investigation

In order to assist in the speedy resolution of any complaint you may have, it’s important that we understand your complaint fully. Sometimes this means we may ask you to address your concerns to us in writing. This can be either by email or post to the addresses. We have established internal procedures for investigating any complaint, which may also involve experienced members of staff from Rowan Rewards Companies considering or investigation the complaint. Where appropriate, the complaint will be dealt with by someone who was not directly involved in the matter which is the subject of your complaint. The member of staff will either have authority to settle your complaint or will have ready access to someone who has the

authority. Our response will fully address the subject matter of your complaint and, if appropriate, will offer redress. If you phone us during our investigation and the member of staff handling your complaint is not available, then another member of our team will try to assist you.

Unless applicable data protection laws require responses within shorter timescales, we will try to resolve any privacy complaints you have within 15 business days of receiving your complaint and in exceptional circumstances, within 35 business days (and we will let you know if this is the case).

As noted above, if you are not satisfied with our reply/outcome, or otherwise with the handling of the complaint, you may have the right to lodge a claim before a relevant Data Protection Authority or the courts.

CHANGES TO ROWAN REWARDS’S PRIVACY POLICY

Rowan Rewards continually strives to implement new technologies and processes to better protect you, your privacy and your use of the Rowan Rewards service. As a result, changes to this privacy policy may be made by Rowan Rewards from time to time. In no event will these changes result in the degradation of any of the security measures designed to protect you from unauthorised disclosure, as such measures are described in this privacy policy.

COMPLAINTS OR QUERIES

If you have any query regarding our data collection and protection practices or your rights, please do not hesitate to contact our data protection officer, at support@rowanenergy.com.