Our Sub-processors
The list of businesses that process client program data for RewardCo, and where.
https://rewardco.com/legal/sub-processors/
The short version
- These are the businesses that process our clients' program data for us, as sub-processors.
- For each one, the list says what it does, where it processes the data and what data it receives.
- We give clients at least 30 days' notice before we add or replace a sub-processor, and clients can object.
- Our reward and payment suppliers are on this list too, and our Suppliers page has more about them.
This summary helps you find your way. The full text below is what applies.
1.About this list
This page forms part of our Data Processing Addendum (/legal/data-processing-addendum/), and is the list section 7 of that Addendum refers to. It also forms part of the Service Agreement (section 10.5) and is referred to in our Privacy Policy.
A sub-processor is a business we engage to process personal data in our clients' Client Data on their behalf. The terms Client, Client Data and Order Form have the meanings given in the Service Agreement.
This list does not include:
- our own staff and contractors, who work under our direct control, including in the Philippines;
- providers a Client engages directly, such as its own Airwallex account when Payouts are paid from it, its Microsoft Entra ID tenant for sign-in, or a supplier of physical items; or
- providers that handle only RewardCo's own business information, such as the hosting, forms and email for rewardco.com. Our Privacy Policy describes those.
Changes. When we add or replace a sub-processor, we update this page and email each Client's notice address at least 30 days before the change, as section 7 of the Data Processing Addendum sets out.
2.The list
| Sub-processor | What it does | Where it processes data | Data it receives |
|---|---|---|---|
| Hetzner Online GmbH | Hosts the platform, its database and its backups | Finland (platform) and Germany (backups) | All Client Data held on the platform |
| Twilio Inc. (SendGrid) | Sends the platform's emails, such as invitations, notices and reward emails | United States | Participants' and Administrators' names and email addresses, and the content of each email |
| Google LLC | RewardCo's email and business software, and the reCAPTCHA bot check on Program Site registration forms | United States and other countries where Google operates | Support emails and their content; for reCAPTCHA, IP address and browser and device details |
| Cloudflare, Inc. | The Turnstile bot check on Program Site registration and password reset forms, where a Program uses it | United States and other countries in Cloudflare's network | IP address and browser and device details during the check |
| GiftPay | Digital Gift Cards in Australia, New Zealand, Singapore, the United Kingdom, the United States and Canada | Australia | Name, email address, and the Gift Card and value chosen; mobile number only if a Program delivers Gift Cards by SMS |
| Gifted | Digital rewards in the Philippines, including credit to a GCash wallet | Philippines | Name, email address, and the reward and value chosen |
| Airwallex | Payouts to local bank accounts, where they are paid from RewardCo's Airwallex account | Australia (see the Suppliers page for its entities) | Name, bank account details, country, the Payout amount and currency, and any other details Airwallex needs to make or check the payment |
Our Suppliers page (/legal/suppliers/) gives more detail on GiftPay, Gifted and Airwallex, and links to each one's own terms.
Airwallex also runs its own checks on Payouts, such as sanctions and fraud screening, under its own terms. For those checks Airwallex decides how the data is used.
3.Contact us
Questions about this list, or an objection to a change, go to legal@rewardco.com.
Related documents
Data Processing Addendum
For Client organisations and agencies
How RewardCo processes clients' personal data under the UK and EU GDPR, including the transfer clauses.
Last updated
Our Reward and Payment Suppliers
For Participants, clients and agencies
The one maintained list of the businesses that deliver rewards and payouts.
Last updated
Privacy Policy
For Everyone: visitors, clients, agencies and participants
How RewardCo handles personal information, for itself and on behalf of client organisations.
Last updated
Questions about this document
- legal@rewardco.com
- Company
- Rewardco International Pty Ltd, trading as RewardCo
ABN 84 169 704 938 - Post
- 1/6 Hassall Street
Parramatta NSW 2150, Australia