Privacy policy

Finally updated on 03/06/2024

INSTRUCTION

You need to carefully read and understand the privacy principles of The Real Reward before you decide to disclose the data to The Real Reward.

The Real Reward is a product under Combo Power International Co., Ltd., The Real Reward (“The Real Reward,” “we,” or “our”) recognizes the importance of protecting the personal data of users who engage with our products and services. We understand your concerns regarding the collection, disclosure, and transfer of personal information and points, both locally and internationally, through The Real Reward App and the companies within our data ecosystem.

We are committed to respecting your privacy while delivering products and services that align with your needs and preferences. The Real Reward sincerely appreciates the trust you place in us and assures you that we handle your personal information responsibly, adhering to privacy principles to protect and respect your data.

The privacy principles cover onsite partners in person and in the App, including the call center and other communication means of The Real Reward to collect your personal data. In the privacy principles, “Personal Information” refers to any information that may be used to identify an individual, directly or indirectly, gained from that information separately or as a combination of other information on the individual that gave to The Real Reward.

The Real Reward reserves the right to modify and change the privacy principles at any time. Therefore, please read the privacy principles regularly to see if it has been amended or changed in any items and will be effective as soon as it is officially announced in The Real Reward App, which will give prior notice in case of any changes to the privacy principles in any contents related to your privacy. In case of any emergency, as determined by the laws of the Kingdom of Cambodia, the company has the right to change it immediately and notify you later as contained in other terms.

1. What kind of personal information does The Real Reward collect?

The purpose of collecting personal information is to provide you with products and /or services to ensure that The Real Reward has complied with the effective laws, provisions and requirements related to other applicable regulations. The Real Reward can collect or receive your personal information directly or indirectly through the following networks or other information sources or subsidiaries in partnership and cooperation, which the nature of the information collected by us depends on the context of your relationship with The Real Reward or the use of any services from The Real Reward and The Real Reward’s data ecosystem.You have the right to choose whether to provide the information requested by The Real Reward or not, but in case you don’t provide your personal information, The Real Reward cannot provide you with its product or service, or answer your questions and collection of your personal information includes:

  1. Personal information such as surname and first name, sex, nationality, date of birth, occupation/position, information in ID card/passport. If you are a legal person, you shall have the company’s name and information on the company issued by the Royal Government, having equal value.
  2. Contact information such as the address for home delivery service or address specifying your information, telephone number, e-mail and other communication means required.
  3. Member Registration Request Information such as member card number information, saving points, registration date/expiration date, member type, customer type, bank account number, payment and registration for other services, etc.
  4. Financial information such as information related to your credit card, due date, payment history, and detailed personal information related to the risks of business partners, including the rating of payment trust and other details related to finance.
  5. Transaction information such as information related to payments, total amount of payments, information related to a refund request, refunded cash amount, saving points, total points, date/place of payment/purchase order, order confirmation number, receiving date of service, booking information, information on filing complaints or including other information in connection with all transactions in The Real Reward App, etc.
  6. Technical information such as internet ID (IP address) Cookie, Media Access Control (Mac), web beacon, Log, Device ID, Internal Mobile Equipment Identity (IMEI), Electronic Serial Number (ESN), Mobile Equipment Identifier ( IEID) and Serial Number (SN) Serial and device type, software and hardware of the device used, activation time, network system, data of connection, access to the data system, information on single sign-on (SSO) usage, Login Log, Location, duration of using The Real Reward App, GPS, latitude, longitude, time zone as well as other technical information that The Real Reward App requires the confirmation of your ID.
  7. Information related to activities such as information on purchase order activities and information obtained from the use of your product or service.
  8. Details of your personal information such as username, password, image, purchase orders, history of purchase orders, ordered product, order quantity, putting the product in the basket, payment location, PIN, customer loyalty App, etc.
  9. Usage information such as information related to your search or use in the App, use of The River Reward products and services, products in the basket, interested products, special App notifications, shop follow, timestamp of last click, and answer any questions in the App or collaborative partners, including subsidiaries in our database.
  10. Marketing and communication information such as your requirements to receive promotion news, or new notifications and new messages.
  11. Sensitive information such as race, religion, political views, thumbprints, facial recognition, biometrics, facial data, contact lens data, health or physical or mental information, genetic information, medical history, disability and criminal history.

If you have provided The Real Reward with the personal information of a third party such as surname and first name, address and telephone number for emergency contact. Incomes of family members or in the event that you use The Real Reward’s services for any of The Real Reward App under your consent only, The Real Reward will collect the third party’s personal information related to you such as surname and first name, photos or phone number as well as personal and contact information of his/her family, friends and contacts in case of any emergency. The person, who has introduced or used it, shall confirm the accessibility from your mobile phone, etc. Please inform them of the privacy principles or ask for prior consent if necessary.

The Real Reward will collect, use or disclose your clear informed consent form or where the law allows, The Real Reward will collect the data of minors compared with incapacitated persons who need to obtain permission from a person having the parental power only. The Real Reward will not collect personal information from customers whom The Real Reward knows are under the age of 18 (eighteen) years without their guardian’s permission, in the event that The Real Reward receives a complaint or receives this information, The Real Reward will delete data, including other relevant information from the App based on the laws or regulations in effect.

2. Why does The Real Reward collect or use and disclose your personal information?
1. Purpose needs to obtain your consent

1.1 Marketing and Communications: The Real Reward collects, uses and discloses your personal information to provide privileges and special App, discounts, advertisements, information related to markets, and other communications in connection with the products, including services from us or subsidiaries to other collaborative partners.

2. Other purposes

2.2 For the benefit of preventing any eventual danger to the life, body, property or health of the individual, including for the public interest and to resolve disputes, we require the collection and disclosure of your personal information for the following purposes:
2.2 To prepare products and services for you to support various activities related to the services between The Real Reward and you successfully, The Real Reward requires a process related to payment transactions, including checking and confirming payment or cancellation of orders, return of products/services, delivery status notification, after-sales service, maintenance and provide easy access to services, etc.
2.3 Marketing and Communication: To provide special privileges and promotions, information, discounts, vouchers, advertisements and other contact information from The Real Reward and its subsidiaries, including collaborative partners.
2.4 Registration: Verifying your ID to apply for registration, checking, experimenting, and confirming your identity.
2.5 To care for and provide customer services: to communicate between you and The Real Reward in the use of services and to submit other requests such as disputes, guidance or claims for compensation, including requesting other technical troubleshooting as well as developing The Real Reward App better.

3. Who can we disclose or transfer your data to?

We can disclose or transfer your personal data to the following third parties domestically or internationally, using or disclosing personal information for the purposes of the privacy principles. You can read the privacy policies of these third parties to find out more about how they collect, use or disclose your personal information, which you are also subject to the privacy policies.

3.1 Companies in our Ecosystem

Because The Real Reward App is part of our data ecosystem that collaborates and shares other services or systems with customers, it can be necessary for The Real Reward to disclose or transfer your personal data to the companies in our ecosystem, or allow other companies in our ecosystem to access your personal information for the purposes set forth in the privacy principles.

3.2 Our service providers

We may use other companies or agents or contractors to perform services on our behalf or to assist in providing you with products and services. We can share your personal information with the following service providers indefinitely for: 1. Internet infrastructure, technology, Apps, websites and IT service providers, 2. Payment service providers, 3. Research agencies, 4. Analysis services providers, 5. Survey agencies, 6. Auditors, 7. Marketing, Media, and relation agencies, 8. Call centers, 9. Campaign and event organizers, 10. Sales representatives, 11. Telecommunication and communication service providers, 12. Payments, payment systems, verification of accuracy, and service providers and chip agents, 13. Informal administrative service providers, 14. Data storage and cloud service providers, 15. Verification and inspection of service provider data, 16. Document delivery agents, 17. Printing service providers.  

While providing such services, these providers may have access to your personal data; however, we will only provide them with personal data necessary for the operations of their services and we request them not to use your information for any other purpose.

3.3 Our business partners

We can transfer your personal data to our business partners in the fields of banking, finance, credit, loan, asset management, investment, insurance, credit card, telecommunication, retail, e-commerce, warehouse, health, products and services, lifestyle, spa, fitness, rewards and loyalty Apps and data analysis. This includes vendors or service providers where we can jointly provide products or services, or their products or services may be offered to you. Data shared in this way will be governed by the privacy principles of third parties and not the privacy principles.

3.4 On other websites or social media

We allow you to access our websites and platforms, using the social media login system by doing so, allowing you to access and store public data from your social media accounts (e.g., Facebook, Google, Instagram) as well as other data mentioned during the use of such login system. In addition, we can link your email address to social media to determine whether you are already a relevant social media user and to post personalized relevant ads on your social media account where appropriate. We also partner with some third parties that allow you to sign up for their services or participate in their promotions.

For example, some companies allow you to use your loyalty App number or online access to obtain or sign up for their services. In addition, your social media account provider can allow you to link your social media account to your online service account; when you sign up for those services, we will share your personal data with third parties. If you do not wish to share your personal data in this way, do not provide your loyalty App number or reward for any third party; do not use your online service account to sign up for advertisements from third parties and do not link your online service account to an account on third party services, data shared in this way will be governed by the privacy principles of third parties and not the privacy principles.

The disclosure of your information as permitted by law, in some circumstances, we can be required to disclose or share your personal data to comply with any legal obligations or provisions, including law enforcement agencies, courts, regulators, authorities, government or other third parties that we believe is necessary to comply with any legal obligations or provisions or to protect our rights, the rights of third parties or the personal safety of individuals, or to seek, prevent or resolve fraud, security or safety issues.

3.5 Technical Advisors

Includes lawyers, technicians and auditors who assist in operating our business and defend or bring any legal claims.

3.6 Assigns and Obligations

Third parties are our designators in the event of reorganization, merger, transfer of business (whether in full or in part), sale, purchase, joint venture, designation, transfer or other arrangement of all or any part of our business, assets or shares will comply with the privacy principles to comply with your personal data.

4. Transferring your personal information abroad

The Real Reward may disclose or transfer your personal information to outsiders or overseas service providers who may or may not have unequal personal information protection. Various ways to ensure that your personal information is transferred securely and that the recipient has the most appropriate level of protection for your personal information in accordance with the laws of those countries.

5. Duration of your personal information storage

The Real Reward will retain your personal information for a necessary and reasonable period to achieve the purposes for which we obtained this information and to comply with the stipulated law in the event of any amendment, The Real Reward can collect your additional personal information or delete it as stipulated by law.

6. Duration of your personal information storage

The Real Reward emphasizes the significance of maintaining your personal information security and fully strives to protect the data efficiently and in compliance with the standards of data retention and protection from damage or loss. With regard to access, modification, destruction, use, fraud, or disclosure without permission or unlawfully, we will check the data, including taking the legal proceedings outlined during that time.

7. Information ownership rights

In the provisions of the law and exemption of the relevant laws, you have the right to the following certifications:

  1. Access: You have the right to request access to or receive copies of personal information that The Real Reward collects, uses or discloses the information on you for your privacy and security. The Real Reward can request you to verify your identity before providing the requested information.

  2. Modification: You have the right to request any modification to the personal information that The Real Reward collects, uses or discloses the information on you in a complete and accurate manner without causing any confusion.

  3. Data Mobility: You have the right to access the personal data which The River Reward has about you in the existing format and via an electronic means to send or transfer that information to other personal data controllers that shall be (a) the personal data you provide to The Real Reward and (b) in the event that The Real Reward obtains your consent to collect, use or disclose or to comply with any contract between us.

  4. Monitoring the Settings

    We recognize that the privacy concerns vary from person to person. Therefore, we provide examples of methods for you to set strict conditions for the collection, use, disclosure or process of your personal information and to manage your privacy settings:

    If you have previously agreed with The Real Reward to use your personal information for any of the above purposes, you can change your mind at any time, by writing or sending an email to The Real Reward.

    • Objection: You have the right to object to certain uses or disclosures of your personal data such as direct objection to markets.
    • Restriction: You have the right to restrict the use of your personal data in certain circumstances.
    • Deletion: You have the right to request us to delete or remove any personal data we collect, use or disclose about you; however, we are not obligated to do so if we need to retain such data to comply with the legal obligations or create, implement or defend the legal claims.
    • Filing a complaint: You have the right to file a complaint with the competent authorities if you believe that the collection, use or disclosure of your personal data is illegal or noncompliant with the applicable data protection law.
8. You are notified when The Real Reward collects and uses your personal information without your consent under the following circumstances:
  • Personal information is important for national security and defense;
  • Personal information that is not identified in statistical or research results that serve the public interests;
  • Personal information is important for public safety, public health and important public interests;
  • Personal information related to a criminal investigation, sentence, trial or execution of judgment;
  • Personal information that is made public at the owner’s discretion;
  • Personal information that is important to maintain the security and stability of the operations, products and/or services provided such as the exploration and troubleshooting of products and/or services.
9. Waiver or deletion of the real reward service or account

Please note that deleting The Real Reward account will not prevent you from using all products and services to protect the legal rights of you and others, The Real Reward will decide whether your deletion request should be supported based on the services and products you use.

Example: If you still have money related to your account, we can’t immediately support your request.

If you wish to delete your The Real Reward account, you can follow the steps in the settings for the account deletion request, which may take up to one (1) week after the account deletion request, in case the account has remaining points or benefits.

10. Governing law and dispute resolution

The privacy principles shall be governed by and construed in accordance with the laws of the Kingdom of Cambodia.

If any dispute, controversy, or claim arises in connection with the privacy principles, the parties shall resolve it through a peaceful negotiation. If it cannot be peacefully resolved, the parties can forward it to the court of competent jurisdiction of Cambodia.

10. More information on the real reward

The Real Reward welcomes all your questions, comments and suggestions and shares your concerns regarding this privacy issue. If you have any questions about the privacy principles, or use of The Real Reward services, or wish to distance yourself from the relationship with The Real Reward, or would like to request the storage of your personal information by The Real Reward,

Please contact The Real Reward via:
Phone number: 069 – 623 – 547
Email: [email protected]
Address: St B2 #015. Koh Pich, Tonle Basak, Chamkar Mon, Phnom Penh
Working hours: Mon-Fri 9: 00-6: 00