Privacy policy

2019-06-06 16:08:42


Privacy Policy of Rewardszz provided by gram Inc. at Tokyo, Japan


This Website collects some Personal Data from its Users.

Owner and Data Controller

gram Inc,

Tokyo Opera City Tower 24F, 3-20-2 Nishi Shinjuku, Shinjuku-ku, Shinjuku-ku, 13, 1600023, Japan.

Owner contact email: info@gra-m.com



Types of Data collected

Among the types of Personal Data that this Website collects, by itself or through third parties, there are: email address, Instagram account information, resident country, Cookies and Usage Data.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.

Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services.

Any use of Cookies – or of other tracking tools – by this Website or by the owners of third-party services used by this Website serves the purpose of providing the Service of this website Rewardszz.


Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not deviate, whenever the processing of Personal Data is subject to European data protection law;

provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;

processing is necessary for compliance with a legal obligation to which the Owner is subject;

processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;

processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.


The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located. Rewardszz is using Amazon AWS.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. Since system structure of Amazon AWS is globally distributed, the actual location of data processing and storing is difficult to identify. However, we believe it is commonly accepted way of data processing and storing in the age of “Cloud computing” technology. Enough security measures are applied by the service provider of AWS, Amazon.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.


Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.

Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes.

The Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erase, the right to rectify and the right to conduct data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Enabling sales functionalities for the sellers, Enabling buying functionalities for the buyers, Analytics, User database management, Displaying content and session recording.


Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:


The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.

Google Analytics with anonymized IP (Google LLC)

Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.

Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

This integration of Google Analytics anonymizes your IP address. It works by shortening Users’ IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.


Displaying content and service from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them.

This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Instagram (Facebook Inc.)

Instagram is a photo and video sharing service provided by Facebook Inc.

We use Instagram API, so users need to provide Instagram account information. But we don’t get any passwords connected with the individual account. Instagram API is used for identification purpose. Such usage is widely shown in Facebook connected applications and services.

Also profile images of all users are provided through Instagram API. 

Place of processing: United States


Handling payments

Buyers of Rewardszz need to buy Rewardszz prepaid token “RWZ” by using third-party payment service PayPal. By using PayPal, buyers can pay by Credit/Debit card or PayPal payment tool with established security environment.


PayPal Holdings, Inc. is an American company operating a worldwide online payments system that supports online money transfers and payment by credit card or debit card of widely accepted brand such as Visa.


Platform services and hosting

The whole services on Rewardszz are provided by web application platform (software) that is commonly used in many websites. This web application platform is run by Amazon’s AWS web hosting service.

Since Amazon’s AWS is using globally distributed data center networks, it is difficult to determine the actual location where the Personal Data are stored.

Amazon AWS

AWS is a world leading web hosting service of cloud service provided by Amazon. This is reputable and reliable service for us Rewardszz.

As to compliance and security matters, see following web page of AWS.



User’s right for their personal data

In order to comply with regulations on personal data legislated by governments, we take care of the right to access, the right to erase, the right to rectify and the right to conduct data portability. Functionalities for these rights are implemented on our website and services.


Further information about Personal Data

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, users have the right to do the following:

Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data. In such a case, users will not be able to keep using our Services accordingly.

Receive their Data. Users have the right to receive their Data in a structured, commonly used and machine readable format.

Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.

Have their Personal Data deleted. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner. In such a case, users will not be able to use our Services accordingly.


How to exercise these rights

Users can read how to exercise these rights in FAQ section. We provide easy interface to exercise these rights.

Additional information about Data collection and processing


Legal action

The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services.

The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.


Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.


System logs and maintenance

For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) to use other Personal Data (such as the IP Address) for this purpose.


Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Website. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.


Legal information

This privacy statement has been prepared based on provisions of multiple legislations.

You have the right to complain about the improper processing of your personal data (such as collection, storage, modification, transfer, deletion, etc.) by us with our supervisory authority:


gram Inc.

Tokyo Opera City Tower 24F, 3-20-2 Nishi Shinjuku, Shinjuku-ku, Shinjuku-ku, 13, 1600023, Japan.


If you have questions about data protection, please send email directly to following email address: