Privacy Policy

The Privacy Policy for Benefits+ (hereinafter referred to as the Policy) is an integral part of the Terms of Service and the Public Contract that was entered into with us at the time of service ordering (order creation). It also applies if you have ordered a derivative service (e.g., additional payment) from another company (e.g., a partner). In this case, these third parties may also have their own privacy policies (other similar documents) that apply when collecting information about you. Additionally, this Privacy Policy and the use of cookie files apply to the personal data of the recipient for whom the dispatch is made in their interests.

1. Basic Definitions

  - Benefits+: a program, application (software) that consists of a set of instructions in the form of words, numbers, codes, schemes, symbols, or in any other form expressed in a usable format, designed for AndroidTV, allowing users to browse collections of TV applications, receive information about promotional offers from Partners, such as from trading networks or other Partners (hereinafter referred to as Partners), with the possibility of further use of the received information about Partners on their direct web resources and trading networks or offline.

  - Application: refers to the Benefits+ application installed on the user's television [(together with any mobile versions and related websites), regardless of the access method] along with all features and functionalities, user interfaces, as well as all content and software related to them.

  - Confidential Information: means any information, technologies, intellectual property rights, technical processes, data, trade secrets, or know-how, including but not limited to those related to research, products, services, business, suppliers, clients, markets, software, developments, inventions, processes, design, drawings, engineering, marketing, or finances, which are Confidential Information by their nature or by the circumstances of their disclosure, and which are designated as confidential or proprietary in writing, or if they were provided in oral or other form, may be reasonably identified at the time of disclosure as confidential or proprietary.

  - Intellectual Property Rights regarding a defined object mean all patents, trade secrets, know-how, trademarks, trade names, copyrights, personal non-property rights, industrial designs, advertising rights, rights to use industrial designs, utility models, and other rights of industrial or intellectual property of a similar nature, regardless of whether they are registered or not; all grants and registrations worldwide in connection with the above, as well as all other rights to them that exist, except those arising from a grant or registration; all applications for any such issuance or registration, all priority rights under international conventions for filing such applications, and the right to control their consideration, as well as all amendments, reissues, additional patents, extensions, and renewals of any such issuance, registration, or right.

  - Users: any natural person who has reached the age of majority according to the requirements of the user's country of residence or country of location, has opened the Benefits+ application, registered, and agreed to the terms of use.

  - Cookie Files: small text files stored on your user device when visiting the Benefits+ application. Cookie files are widely used to ensure or improve the application's performance.

  - Registration: actions of the User to fill out and submit a registration form posted on an online service and to create a Personal Cabinet.

  - Authorization: entering by the User of their login and password to access their Personal Cabinet on the online service.

  - Personal Cabinet: an interface element of the platform that makes the user experience more personalized. Thanks to this option, users gain access to functionality specific to their own accounts (such as personal data, discount programs, payment cards, etc.).

2. General Provisions:

The Administrator is KIVI SMART PURCHASING Kft, registration code 01-09-345540, registered and operating in accordance with the laws of the Republic of Hungary, with a location address at 7 Liberty Square, Budapest, Hungary, 1054.

This Policy applies to the processing of personal data that Benefits+ may obtain from individuals (data subjects) based on the laws applicable in the territory of the Republic of Hungary, as well as the General Data Protection Regulation (EU) 2016/679 dated 27.04.2016 (EU GDPR) and other applicable European data protection laws.

Before using the Benefits+ application, please familiarize yourself with these Rules. When using the Benefits+ application, personal data collection, processing, use, and storage, as well as the transfer of personal data to third parties, are carried out.

By using and interacting with the Application, installing apps from other partners offered in it, viewing, receiving, and using electronic vouchers through the Application, using other Application features, the User automatically agrees to this Privacy Policy, which regulates the use of the Application. By registering, the User automatically accepts the terms of use of the Application and this Privacy Policy.

The Application is created on the AndroidTV platform and is managed by the Administrator or its affiliated representatives.

The Privacy Policy ("Policy") describes the cases in which the Application may use, collect, and store information about Users when interaction with the Application begins. Please also familiarize yourself with the User Agreement for using the Benefits+ application to learn more about the terms governing the use of the Application and purchases made within it.

3. Terms of Use of the Application:

To interact with the Application, its content, and services, the User must be at least 18 years old. The User does not need to be a subscriber to Benefits+ services to interact with the Application.

The Application is not intended for underage users, in accordance with applicable laws. All responsibility for the use and viewing of the Application by underage Users lies with their parents, guardians, and legal representatives.

If you have any questions regarding our Privacy Policy or this Application, please contact the Administrator via email at [email protected] with the subject "PRIVACY INQUIRY." Please indicate your country of location if you are contacting us.

4. Collection and Use of Information:

4.1. Collection of Information

To provide access to the Application, the Administrator and/or our Application partners (as defined in section 2 below) may collect certain information and/or content from the User, including but not limited to:

- Identifiers (such as name, email address, mailing address, postal code, phone number, IP address, payment information, device identifiers used by the User for connection, network characteristics)

- Commercial information (e.g., products, tickets/reservations considered, received or purchased services, as well as payment information; this may include things like size or style choices, as well as general preferences or purchasing habits)

- Internet or other electronic network activity information (such as interaction with the Application)

- Geolocation data (e.g., IP address or GPS coordinates)

By providing their personal data in the Application, the User automatically consents to the processing and storage of their personal data for the Application, as well as the transfer of personal data to relevant regulatory authorities in case of potentially hazardous incidents. The Administrator guarantees the use of the User's transferred personal data strictly within the scope of this Policy in accordance with applicable legal norms.

If the User provides any personal information about other individuals in the Application, the User automatically confirms that they have the authority to do so and allow the Administrator to use this information in accordance with the terms set forth in the Privacy Policy.

4.2. Use of Information

1. This information will be used to communicate with the User and to process and complete User transactions, purchases, returns, and inquiries. The Administrator and our Application Partners will use the information and content provided by the User for Application administration, including personalizing our offerings to the User, marketing to the User, analyzing other data collected by the Administrator, identifying potential clients (e.g., determining the number of clients of a certain size), as well as developing and/or integrating new products and services. This information may also be used to allow the User to participate in surveys, contests, promotions, and competitions that may be available in the Application, as well as to administer these events. This information may be used to create a User account in the Application.

2. The Administrator may also use Personal Information if deemed necessary or appropriate for certain important purposes, including but not limited to: compliance with applicable laws and judicial processes; responding to requests from governmental and governmental bodies, including governmental and other regulatory bodies outside your country of residence; detecting, preventing, or investigating potentially hazardous incidents; facilitating the functionality of our mobile applications and websites; providing important product safety information and product recall notices; enforcing our terms; protecting our operations or the operations of our affiliates; protecting our rights, privacy, security, or property, as well as the safety and/or security of our affiliated persons, you, or other persons; and allowing us to use available legal means of protection or limit damages we may incur.

3. The User may register to receive the Benefits+ newsletter via email or updates about delivery/tracking of products via SMS/email. The User may unsubscribe from such communications at any time by clicking the "unsubscribe" link in the footer or following other instructions provided for unsubscribing.

4. When the User interacts with the Application, certain information may be collected automatically. Examples of information include: computer operating system type, device characteristics and software (such as type and configuration), transition URLs, IP address (which may indicate your general location to us), statistical data about page views or interaction with activity, and browser and standard web server log information. This information is collected using technologies such as cookies and other tracking technologies. For more information on how we use these technologies and your choices, please see the "Use of Cookies, Pixels, and Similar Tracking Technologies" section below.

5. Registration and Partner Offers

When registering on the Benefits+ platform, the User gains access to information about Partner applications, which can be subsequently used for personal, non-commercial purposes, such as staying informed about Partner news and offers. Through Benefits+, the User can also navigate to Partner websites for further registration and utilization of the offers provided by them, obtaining information about the possibility of using Partner products when redirected to the Partner's website to receive the Service provided directly by the Partner. (together "Offers"). The Administrator is not responsible for the operation and provision of offers by Partners.

If the User receives an offer within the Application itself, the Administrator transfers certain basic information (identifiers, commercial information) to the Partner so that the Partner can complete the transaction for the User and fulfill their order.

Regarding offers presented by Partners in the Application, the Administrator clearly informs:

(a) that the offer is provided by the Partner, and

(b) the name and URL of the website managed by such Partner.

Receiving offers from Partners, including those whose offers are posted on third-party websites, may require the User to accept the Partner's terms of use or Privacy Policy. Please review these documents before conducting any transactions. This Policy does not apply to such websites when navigating to them via a link.

6. Use of Cookies, Pixels, and Similar Tracking Technologies

The Application may use cookies and similar tracking technologies (e.g., web beacons or pixels) for various reasons, such as facilitating access to our services by remembering the User when they return; providing, analyzing, understanding, and improving the use of our services; complying with our terms, preventing fraud; enhancing the performance of the Application or other related resources, monitoring visitor traffic and actions on our site; as well as providing and adapting our marketing or advertising and understanding interactions with our emails, marketing, and online ads on third-party resources.

Cookies are small data files that are typically stored on the User's device when browsing and using websites and online services. Similar to cookies, these or similar technologies may store small amounts of data on the User's device. Web beacons (also known as clear GIF files or pixel tags) often work in conjunction with cookies.

The User can adjust the permissions of the Application in their device settings to control whether the device accepts or rejects cookies. If the User chooses to reject cookies, they may not be able to use certain features of the Application. The User can delete cookies from their device, but this means that any settings controlled by these cookies will also be deleted, and the User may need to reset them manually. Depending on the device, the User may not be able to control tracking technologies through settings. The emails sent by the Administrator may contain a web beacon or similar technology that informs us whether the User has received or opened the email and whether they clicked on any links in it.

The list of third-party services that the Application uses for data collection, storage, and analytics includes:

- Google Analytics. This Application may use Google Analytics, a web analytics service provided by Google. Google Analytics helps the Administrator collect analytical and statistical data related to the Application. On behalf of the Administrator, Google processes this information to analyze the use of the Application, generate reports on Application activity, and provide other services related to the use of the Application and the Internet. If the User has any questions or concerns about Google Analytics' privacy practices, they can review their Privacy Policy at https://policies.google.com/privacy?hl=en.

- Social Networks. If the User interacts with the Application on social media platforms (e.g., meta-platforms such as Facebook or Instagram, TikTok, Twitter, Pinterest, Snap), the Application may collect publicly available profile information about the User, including their username and name.

- Commercial Partners. Occasionally, the Application may collaborate with third parties to make the use of the Application more productive for consumers. These may include Affiliated Partners, "buy now, pay later" Partners, Marketplace Partners, as well as Booking or Ticket Sale Partners. If the User interacts with features managed by these commercial Partners, the Application may provide limited information to these Partners to allow them to provide their services and fulfill orders the User may place.

- Social Plugins. The Application may provide the User with the ability to share information via email, social media, or other information exchange programs using clients and applications on their smart device. Social plugins (including those offered by Facebook, Twitter, Instagram, and Pinterest) allow sharing information on these platforms. Social plugins and social programs are governed by the respective social network and fall under its terms of use and privacy policy.

- The Administrator uses reasonable administrative, logical, physical, and managerial measures to protect your information from loss, theft, and unauthorized access, use, and modification. The Administrator may retain information in accordance with the requirements or permissions of applicable laws and regulations, including to achieve the purposes described in this Policy.

7. Disclosure of Information

The Administrator may disclose User information for specific purposes and to third parties listed below:

- Entities within the KIVI company group: The Administrator may share User information among KIVI group companies as necessary for the purposes described in the "Data Collection and Use" section of this document.

- Other companies, agents, product-related third-party Partners, or subcontractors: The Administrator may use other companies, agents, product-related third-party Partners, or subcontractors to provide services on our behalf or to assist the User in this Application. For example, the Administrator may use Store Providers to provide infrastructure and IT services (e.g., installing the Application) or to facilitate commercial operations (e.g., "buy now, pay later" feature or easing reservations). The Administrator does not allow Store Providers to use information except in connection with providing their services, considering such security matters: The Administrator and our Partners may disclose and otherwise use information if the Administrator and/or Partners reasonably believe that such disclosure is necessary for:

 - (A) complying with any laws, regulations, court processes, or government requests,

 - (B) enforcing this Policy, including investigating potential violations,

 - (C) detecting, preventing, or otherwise addressing issues related to illegal or suspected activities, security issues, or technical problems, or

 - (D) protecting the rights, property, or safety of KIVI Entities, our Partners of content, users, or the public, as required or permitted by law.

- International Data Transfers: If during information exchange the Administrator transfers personal information to countries outside your region, we take measures to ensure the transfer of information in accordance with this Statement and in compliance with applicable data protection laws.

8. International Data Transfers

Each time the Administrator transfers personal information to countries outside the EU and other regions with comprehensive data protection laws, the Administrator ensures that personal information is transferred in accordance with this Privacy Policy and in compliance with applicable data protection laws. The Administrator ensures the presence of appropriate contractual, technical, and organizational measures.

9. User Information and Rights

- User Rights: The User can request access to personal information or correct/update outdated or inaccurate personal information that the Administrator holds about the User. The User may object to the processing of personal information, request the Administrator to restrict the processing of such personal information, or request the transfer of personal information. If the Administrator has collected and processed personal information with the User's consent, the User can withdraw their consent at any time. Withdrawal of consent will not affect the lawfulness of any processing conducted by the Administrator prior to such withdrawal, nor will it affect the processing of personal information based on other lawful processing grounds.

- Questions and Concerns: If there are any questions regarding the privacy practices, send an email to [email protected] with the subject line "PRIVACY REQUEST." The Administrator will respond to all requests received from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

- Right to Lodge a Complaint: You have the right to lodge a complaint with a data protection authority regarding the collection and use of your personal information.

- Third-Party Websites: The Application may contain links to other websites owned and operated by third parties ("Third-Party Websites"). These links are provided to the User for convenience, and visiting any Third-Party Website is at the User's discretion. Neither the Administrator nor KIVI Entities are responsible for the content on such third-party websites, and neither the Administrator nor KIVI group companies make any representations or warranties regarding this. Access and use by the User of any such third-party websites are governed by their terms of use and Privacy Policy.

- Marketplace Transactions: Similarly, if the User completes a transaction on a third-party Marketplace or through it (e.g., Amazon or Walmart), the User's access to it and its use are governed by their terms of use and privacy policy, and neither the Administrator nor any other KIVI group companies make any representations or warranties regarding the security of the User's personal data on such sites.

- Acceptance of Policy: By using, visiting, browsing the Application, receiving offers from Partners, and using vouchers through the Application, the User unequivocally accepts this Policy and agrees to it.

10. Account Deletion

To delete your account, the data subject must send an email to the support service at [email protected]. The email should contain a request to delete the account in any format. The email must be sent from the email address that matches the one provided in the data subject's account. The account deletion period is 72 hours from the moment the support service processes the email.

11. Changes to this Policy

Changes and additions to this Policy may be made periodically and without prior notice to the User, including changes in legal requirements. Any changes will be posted on the website https://benefitsplus.eu/info/privacy-statement/. New terms may be displayed on the screen, and the User may need to read and accept them to continue using any/all Benefits+ Services.