Privacy Policy

Last Updated: 1 October, 2025

1. Introduction

Welcome to RewardBox. We are committed to protecting your privacy and ensuring the security of your personal data. This Privacy Policy explains how we collect, use, share, and protect your information when you use our application and services.

Key Points:

  • Who we are and how to contact us

  • What data we collect and why we need it

  • How we use, share, and store your data

  • Your legal rights and choices regarding your personal data

  • How we protect your information

2. About Us

Data Controller: MAGIC CRYSTAL LIMITED ("we," "us," or "our") is the data controller responsible for processing personal data collected through RewardBox.

Contact Information:

  • Company Address: 66 Shanghai Street, Yau Ma Tei, Kowloon, Hong Kong

  • Data Protection Officer (DPO): dpo@reward.box

3. Data We Collect

3.1 Personal Information

  • Contact Details: Email address, phone number, and other contact information you provide

  • Account Information: Username, profile settings, and preferences

  • Identity Verification: Information required for account verification when applicable

3.2 Technical and Device Usage Data

  • Device Information: Operating system, device model, browser type, IP address, unique device identifiers, battery status, screen activity, network connectivity status

  • App Usage Data: Features used, session duration, interaction patterns, performance metrics

  • Web Activity: Targeted application visited, search terms, in-app interactions

  • Location Data: General location information for service optimization

3.3 Cookies and Similar Technologies

  • Session Cookies: Temporary cookies for registration, authentication, and preferences

  • Analytics Cookies: To understand app usage and improve functionality

  • Preference Cookies: To remember your settings and accessibility preferences

3.4 Sensitive Data

We do not intentionally collect sensitive personal data (health information, racial/ethnic origin, political opinions, religious beliefs, genetic/biometric data, sexual orientation, criminal records). If such data is inadvertently collected, it will be removed upon detection.

4. How We Collect Data

We collect data through:

  • Direct Collection: When you create an account, contact us, or provide information voluntarily

  • Automatic Collection: Through your use of the app, including background monitoring (with your consent)

  • Third-Party Sources: From partners or service providers (only when legally permissible)

  • Device Permissions: Accessibility permissions, network access, targeted app(s) usage monitoring

Important: We never and will not record the content of your calls, messages, or private communications. If such data is inadvertently collected, it will be removed upon detection.

5. Legal Basis for Processing

We process your data based on:

  • Consent: When you agree to data collection during app setup and grant permissions

  • Contractual Necessity: To provide and maintain the RewardBox service

  • Legitimate Interests: For app improvement, security, fraud prevention, and customer support

  • Legal Compliance: To meet regulatory requirements and respond to legal requests

6. How We Use Your Data

6.1 Primary Purposes

  • Provide, operate, and maintain RewardBox’s basic app functionality

  • Personalize your experience and remember your preferences

  • Improve app performance and develop new features

6.2 Secondary Purposes

  • Analyze usage patterns for service enhancement

  • Provide customer support and respond to inquiries

  • Send important notifications and service updates

  • Ensure security and prevent fraud or abuse

  • Conduct research and analytics (in anonymized form)

  • Comply with legal obligations

6.3 Marketing and Communications

  • Send promotional materials (with your consent)

  • Provide information about new features or services

  • Conduct surveys or request feedback

Opt-out: You can unsubscribe from marketing communications at any time.

7. Data Sharing and Disclosure

7.1 Service Providers

We may share data with trusted third-party service providers who help us operate our service, including:

  • Cloud hosting and storage providers

  • Analytics and performance monitoring services

  • Customer support platforms

  • Payment processors (if applicable)

All service providers are bound by strict confidentiality agreements and data protection requirements.

7.2 Business Partners

  • Research collaborators (anonymized/pseudonymized data only)

  • Technology partners for feature enhancement

  • Integration partners for expanded functionality

7.3 Legal Requirements

We may disclose data when required by law or to:

  • Respond to legal processes, court orders, or government requests

  • Protect our rights, property, or safety, or that of our users

  • Investigate potential violations of our Terms of Service

  • Prevent fraud, security breaches, or other illegal activities

7.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your data may be transferred to the new entity, subject to the same privacy protections.

8. Data Security

8.1 Technical Safeguards

  • Encryption: Data encrypted both in transit and at rest using industry-standard protocols

  • Access Controls: Multi-factor authentication and role-based access limitations

  • Secure Infrastructure: ISO 27001 compliant data centers and security practices

  • Regular Security Audits: Penetration testing and vulnerability assessments

8.2 Organizational Measures

  • Staff training on data protection and privacy

  • Regular security policy reviews and updates

  • Incident response procedures and breach notification protocols

  • Privacy by design principles in product development

8.3 Data Breach Response

In case of a security incident:

  • We will investigate and contain the breach immediately

  • Affected users will be notified within 72 hours (or as required by law)

  • Relevant authorities will be notified as legally required

  • We will provide guidance on protective steps you can take

9. Data Retention

9.1 Retention Periods

  • Account Data: Retained while your account is active and for a reasonable period after closure

  • Usage Data: Typically retained for 2-3 years for service improvement, then anonymized or deleted

  • Support Records: Retained for 3 years to provide ongoing assistance

9.2 Deletion Criteria

Data is deleted when:

  • No longer necessary for the original collection purpose

  • You withdraw consent (where consent is the legal basis)

  • Processing becomes unlawful

  • Required for legal compliance

10. Your Privacy Rights

Depending on your location, you may have the following rights:

10.1 Access and Portability

  • Request a copy of your personal data

  • Receive your data in a portable format

  • Obtain information about how your data is processed

10.2 Correction and Deletion

  • Correct inaccurate or incomplete data

  • Request deletion of your personal data ("right to be forgotten")

  • Withdraw consent for data processing

10.3 Processing Controls

  • Object to processing based on legitimate interests

  • Restrict processing in certain circumstances

  • Opt-out of automated decision-making or profiling

10.4 Exercising Your Rights

To exercise these rights:

  • Contact us at support@reward.box

  • Use in-app privacy settings where available

  • We will respond within 30 days (or as required by applicable law)

  • Identity verification may be required to protect your privacy

11. Children's Privacy

11.1 Age Requirements

RewardBox is not intended for children under 16. We do not knowingly collect personal information from children below these age thresholds.

11.2 Parental Consent

If we discover we have collected information from a child without proper consent:

  • We will delete the information promptly

  • We will terminate the child's account

  • Parents/guardians can contact us to request deletion of their child's data

11.3 Educational Use

If RewardBox is used in educational settings with children, schools must obtain appropriate parental consent and ensure compliance with applicable laws (such as COPPA in the US or GDPR in the EU).

12. International Data Transfers

12.1 Cross-Border Processing

Your data may be processed in countries outside your residence, including:

  • Countries with adequacy decisions from your local privacy authority

  • Countries where we use Standard Contractual Clauses or other appropriate safeguards

  • The United States under Privacy Shield successor frameworks (when applicable)

12.2 Safeguards

We ensure international transfers include:

  • Adequate legal protections for your data

  • Contractual commitments from data processors

  • Technical and organizational security measures

  • Regular compliance monitoring

13. Cookies and Tracking Technologies

13.1 Types of Cookies

  • Essential Cookies: Required for basic app functionality

  • Analytics Cookies: Help us understand usage patterns

  • Preference Cookies: Remember your settings and choices

13.2 Cookie Management

You can control cookies through:

  • Your browser or device settings

  • In-app privacy preferences

  • Third-party opt-out mechanisms

Note: Disabling certain cookies may limit app functionality.

14. California Privacy Rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act (“CCPA”):

  • Right to know what personal information is collected

  • Right to delete personal information

  • Right to opt-out of the sale of personal information

  • Right to non-discrimination for exercising your rights

We do not sell personal information to third parties.

15. Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at support@reward.box with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

16. European Economic Area (“EEA”)

If you are a resident of the EU, United Kingdom, Lichtenstein, Norway or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data. Please note that not all the features and functionalities of the Services are available to EU users due to legal, technical, business, or other reasons.

17. Brazil Resident Rights

If you are a resident of Brazil, you have additional rights under the Brazilian General Data Protection Law (“Lei Geral de Proteção de Dados Pessoais” or “LGPD”):

● Right to confirm the existence of the processing of your Personal Data

● Right to access your Personal Data

● Right to correct incomplete, inaccurate, or outdated Personal Data

● Right to anonymize, block, or delete unnecessary or excessive Personal Data, or Personal Data processed in noncompliance with LGPD

● Right to portability of your Personal Data to another service or product provider, subject to the regulation of the Brazilian data protection authority (ANPD)

● Right to delete Personal Data processed with your consent

● Right to information about public and private entities with which we have shared your Personal Data

● Right to information about the possibility of denying consent and the consequences of such denial

● Right to revoke your consent at any time

You may exercise these rights by contacting us at support@reward.box with the subject line “Brazil LGPD Request” and providing us with your name and the email address associated with your account. Please note that certain rights may be subject to legal limitations under LGPD.

18. Changes to This Policy

18.1 Updates

We may update this Privacy Policy to reflect:

  • Changes in our data practices

  • New legal requirements

  • Service enhancements or modifications

18.2 Notification

We will notify you of material changes through:

  • Email notification to your registered address

  • In-app notifications

  • Prominent notice on our website

  • Updated "Last Updated" date at the top of this policy

18.3 Continued Use

Your continued use of RewardBox after changes become effective constitutes acceptance of the updated policy.

19. Contact Information

For any privacy-related questions, concerns, or requests:

Email: support@reward.box
Data Protection Officer: dpo@reward.box
Response Time: We aim to respond to all privacy inquiries within 30 days.

Address: 66 Shanghai St, Yau Ma Tei, Kowloon, Hong Kong