SMILE MATES LOYALTY PROGRAM


Overview

This Privacy Notice sets out how Smile Mates processes and protects the privacy of your personal information. This policy describes how we treat personal information about you when you visit smilemates.com. We recommend you review this privacy policy.

At Moonline Travel and Trade Ltd (hereinafter referred to as “Moonline”, “We”, Our”, “Us”) Owner of smilemates.com (Smile Mates) and its associated mobile application called Switch (the “App”), understand our users (“you,” “your”) care about how your personal information is used and shared, and we take your privacy seriously. This privacy policy describes how Smile Mates, a provider of a loyalty rewards platform, collects and uses the personal information you provide on our website or the App. By visiting or using the Website or the App in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy and you hereby consent that we will collect, use, and share your information in the following ways. Any capitalized terms used herein without definition shall have the meaning given to them in the Smile Mates Terms and Conditions.

We are committed to protecting the privacy of your personal details every time you provide us with your basic required personal information when purchasing our services.
Please note that this Policy applies only to information collected by our website or App and not to information collected or obtained by other means or media. Our policy ensures that any information you provide us remains private and secure.

This privacy policy is applicable to smilemates.com only and does not apply to any affiliated websites or Apps/portals or any other third-party websites/Apps, even if they are linked to smilemates.com. It is recommended that you read the privacy policy of the other parties you interact with. By using our portal, you signify your acceptance of this Privacy Policy.

We use Personal Information in order to provide you with information on our services and its website or App, in order to properly provide you with our services.

As a registered member of smilemates.com, you will be entitled to a number of discounts, savings, special deals, updates and other benefits on air tickets, hotel bookings/reservations, holiday packages, car rentals, etc. Moonline is entitled to change details of deals and discounts at its own discretion.

How do we collect your data/information?

Some data are collected when you provide it to us voluntarily. This could, for example, be data you enter on the Contact Form embedded to our website or App.

Other data are collected automatically by our IT systems when you visit the website or the App. These data are primarily technical data such as the browser and operating system you are using or when you access the page. These data are collected automatically as soon as you enter our website or App. Some information is mandatory submission for example when you register as a subscriber/member or make an online payment.

We collect information about customer points activity in order to track how many points a customer has collected and whether or not they qualify for punches when engaging in activities that the participating business has elected to award additional points for. We and also our third-party Partners may collect information about customer visits to the website or the App for the purpose of awarding punches, redeeming rewards and/or improving the customer experience.

Below is the list of how the data are collected from you:

Voluntary information:

Some information is voluntarily provided to us by you, such as name, physical address, email address, IP address, phone number, credit card information, as well as details including gender, occupation, location, purchase history, and other demographic information when you wish to buy and/or apply to use any of our services, consult with any of our teams or customer service team, send us an email, post on our blog or any other of our social media networks or communicating with us with any other ways;

Mandatory information:

Collected personal information provided by you at the time of registration, making a reservation, applying for a vacancy/career opportunity or making online payment, included but not limited to, are the only mandatory submission you are required to make as a user of our services.

Automatically collected information: This information is collected when you browse our website or App for the services we offer, such as your visit to our Website or App, your usage of the Services, and your web browsing. That information may include your IP address, your operating system, your browser ID, your browsing activity, and other information about how you interacted with our Website and App;

Cookies and tracking:

Our partners and we may use various technologies to collect and store information when you use our Services, and this may include without limitation using cookies and similar tracking technologies on our Website or App, such as pixels and web beacons, to analyze trends, administer the website or the App, track users’ movements around the website or the App, serve targeted advertisements, and gather demographic information about our user base as a whole;

Information from other sources:

From time to time, we may obtain information about you or your Subscribers from third-party sources, such as but not limited to public databases, social media platforms, third-party data providers and our joint marketing partners.

What do we use your data for?

- Part of the data is used to ensure the proper functioning of the website or the App. Other data can be used to analyze how visitors use the site and also for offering you our services in the best way possible and to bill and collect money owed to us;

- To promote the use of our services to you and others. For example, if we collect your Personal Information when you visit our website or App and do not sign up for any of the Services, we may send you an email inviting you to sign up. If you use any of our Services and we think you might benefit from using another Service we offer, we may send you an email about that. You can stop receiving our promotional emails by following the unsubscribe instructions included in every email we send. In addition, we may use information we collect in order to advertise our Services to you or suggest additional features of our Services that you might consider using. In addition, we may use your Personal Information to help us advertise our Services to potential or other users like you;

- To send you System Alert messages. For example, we may inform you of temporary or permanent changes to some our services, such as planned outages, new features, version updates, releases, abuse warnings, and changes to our Privacy Policy;

- Account data:

We may use your information for the account data and may be processed for the purposes of operating our website or App, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our websites and business;

- Transaction data:

We may process information relating to transactions, including purchases of services, that you enter into with us and/or through our website or App ("transaction data"). The transaction data may be processed for the purpose of supplying the purchased services and keeping proper records of those transactions;

- Newsletter data:

We may process information that you provide to us for the purpose of subscribing to our newsletters and other notifications ("newsletter data"). The newsletter data may be processed for the purposes of sending you the newsletters and other notifications, and analysing their use. The legal basis for this processing is consent;

- Message data:

We may process information contained in or relating to any communication that you send to us by email or any similar communications system ("message data"). The message data may include the communication content and metadata associated with the communication. The message data may be processed for communicating with you (including sending you sales or marketing materials) and record-keeping where appropriate.

What rights do you have regarding your data?

You always have the right to request information about your stored data, its origin, its recipients, and the purpose of its collection at no charge. You also have the right to request that it be corrected, blocked, or deleted. You can contact us at any time if you have further questions about the issue of privacy and data protection.

Analytics and third-party tools

When visiting our website or App, statistical analyses may be made of your surfing behavior. This happens primarily using cookies and analytics. The analysis of your surfing behavior is usually anonymous, i.e. we will not be able to identify you from this data.

Contact Form

Should you send us questions via the contact form, or request for any registration, services, applying for a job vacancy, etc we will collect the data entered on the form, including the contact details you provide, to answer your question (s) and request (s). We do not share this information without your permission.

You may revoke your consent at any time. An informal email making this request is sufficient. The data processed before we receive your request may still be legally processed.
We will retain the data you provide on the contact form until you request its deletion, revoke your consent for its storage, or the purpose for its storage no longer pertains (e.g. after fulfilling your request).

Information Collection and Use

Your use of the Smile Mates website or the App constitutes a business relationship and agreement wherein we provide travel and tourism-related services for your use. In exchange, Moonline reserves the right to use the contact information collected during site submission to deliver notices regarding changes or updates to our services, provide free newsletters, inform you of additions to the Smile Mates website or the App, or to send important announcements.

When you make a purchase, we might be obligated to provide appropriate personal information to third party agencies/suppliers to facilitate your travel arrangements.

Personal information, which includes name, IP address, email address, mailing address, telephone number, credit card information, and travel information, etc. that the client provides voluntarily will be transmitted using secure SSL (Secure Socket Layer) encryption, which enables your browser to scramble and encode your information before it is transmitted to our servers.

You may remove yourself from any or all of our notice and announcement mailings at any time if you wish so. Any mailing received from our company is identified and includes a valid company email address.

Is personal information transferred overseas?

We may disclose your personal information to our certain local partners or overseas recipients, we ensure that any such international transfers are either necessary for the performance of a contract between you and the overseas recipient or are made subject to suitable safeguards as required by your local data protection laws.

Registration

- Users are asked to provide certain personal information when signing up for our Services, including name, address, telephone number, email, etc. The personal information collected during the registration process is used to manage each User’s account (such as for billing purposes, etc). Moonline does not rent or sell email addresses or any other personal data.

- When you register your loyalty card (i.e. creates an account); you will be asked for some PII (Personally Identifiable Information) so the card starts working/functioning (i.e. Card Merging) and also for the purposes of securing your account and customizing the User experience. Such information will include; but not be limited to; the customer's first name and email address and phone number.

- When unregistered customers use their cards; we also track their points and redemption history. This information is associated with the card only; and not the holder (i.e. we obtain no Personally Identifiable Information). Only when the customer explicitly registers the card, then the PII is required for Loyalty Card. Customers are also not required to register their cards to use the "Soft Card" option.

- In instances where Moonline and an affiliated company or a partner jointly promote the Services, Moonline may provide the related partner certain personal information who subscribed to the Services as a result of the joint promotion for the sole purpose of allowing us and the partner to assess the outcome of the promotion. In this case, the partner may not use personal information for any other purpose.

Cookies

Some of our web pages use cookies. Cookies do not harm your computer and do not contain any viruses. Cookies help make our website or App more user-friendly, efficient, and secure. Cookies are small text files that are stored on your computer and saved by your browser.

Most of the cookies we use are so-called "session cookies." They are automatically deleted after your visit. Other cookies remain in your device's memory until you delete them. These cookies make it possible to recognize your browser when you next visit the site.

You can configure your browser to inform you about the use of cookies so that you can decide on a case-by-case basis whether to accept or reject a cookie. Alternatively, your browser can be configured to automatically accept cookies under certain conditions, always reject them, or automatically delete cookies when closing your browser. Disabling cookies may limit the functionality of the website or the App.

A "cookie" is a small data file that can be placed on your hard drive when visiting certain websites or Apps. Moonline may use cookies to collect, store, and sometimes track information for statistical purposes to improve the products and services we provide. These cookies do not enable third parties to access any of your customer information.

Advertisers and partners may also use their own cookies. We do not control the use of these cookies and expressly disclaim responsibility for information collected through them.

Security

Your personal information is stored in a protected server. Access is restricted to Moonline staff only.

We ensure the website’s or the App’s compliance with the Iraqi related applicable laws with respect to electronic services and the collection and processing of personal data.

In addition, Cybersecurity is also adopted by the portal in order to achieve protection against criminal or unauthorized access or use of electronic data. We apply appropriate security measures on our systems (such as access permissions, anti-virus software…) to prevent the loss, destruction, falsification, alteration and leakage of your data and personal information.

The website or the App shall also exert all possible efforts to ensure that external parties who have access to the data maintain strict controls and confidentiality.

Our website and the App shall implement the following security measures:
• Encrypted data, whether stored in the e-service or transmitted to our servers, thus making it unreadable as it flows over the internet.
• Secure authentication (using login credentials, security PIN, fingerprint, QR code, etc.), which allows you to access the website or the App using your credentials only and requests you to change your password regularly.
• Automatic time out, which automatically signs you out after a period of inactivity.
• Remote data wipe, which can be executed remotely by the portal or by yourself if the phone is lost or stolen. This action wipes your data as well as the keys used to encrypt said data and information.

We use regular Malware Scanning.

Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.

We limit the amount of information that we retain; especially from end users; who are not obligated to provide any PII. Passwords are never saved; only Encrypted Salted Hashes.
All transactions are processed through a gateway provider and additional information required to complete the transaction is not stored or processed on our servers.

Updating information

Please let us know if the personal information that we hold about you needs to be corrected or updated.

Questions & Concerns

If you have any questions or comments, or if you want to update, delete, or change any Personal Information we hold, or you have a concern about the way in which we have handled any privacy matter, please use our contact form/details to send us a message.

Change of Ownership

In the event of a change in ownership or a direct merger or acquisition of Moonline with another entity or multiple entities, all (or selected proportion) of Smile Mates customer information (including email addresses) may be transferred to a separate entity or entities. All Smile Mates subscribers and registered users have to check and review the Privacy Policy to become aware of any changes in the policies. Subscribers and users may choose to access and modify any of their registration and subscription information at that time.

Changes to this Privacy Policy

This privacy policy is reviewed from time to time, and periodic changes may be made to our policies in regards to those reviews. All updates and amendments are effective immediately upon their uploading on our website or the App. For the most recent version of the Privacy Policy, it is advised to check back on this page to ensure that you have the latest version of our privacy policy and stay informed of changes that may affect you, as your continued use of the Website or the App signifies your continuing consent to be bound by this Privacy Policy.

Thank you for visiting and using the smilemates.com and also for reading this document.