Legal and privacy centre

Rewallo is a digital loyalty service operated by AviaTravel OÜ, registration number 17586406, Tornimäe tn 5, Kesklinna linnaosa, 10145 Tallinn, Estonia. Contact us about privacy at support@rewallo.com or through /support. This notice explains how we handle personal information when you use our website, business workspace and loyalty-card services.

Who is responsible

We act as controller for our business-account contacts, subscriptions, accounting, support and service security. A participating business normally decides why its customers join its loyalty programme and how rewards work. For membership information processed on that business’s instructions, the business is the controller and Rewallo acts as processor under the Data Processing Agreement. Contact the business first about its programme; we can help identify the relevant business and pass on a request.

Information and purposes

Business registration collects your name, business name and type, email, phone, business address, country and password; some address and website fields are optional. We use these details to establish and operate your workspace and subscription. Passwords are hashed rather than stored as readable passwords.

Customer membership collects name, email and phone, a membership identifier, stamps, rewards and activity records. These details operate the chosen loyalty programme and deliver service messages. Joining a programme does not subscribe a customer to marketing.

Billing information includes contact and optional company/tax details, plan and processor identifiers, payment status and invoice records. Payment card information is entered with the payment processor. The application does not store complete payment card numbers or card security codes.

Support correspondence contains what you submit and our response. Please do not send passwords or payment card details. Operational/security records can include technical request information, account identifiers, error categories and authentication/session records. Hosting and mail providers may separately keep infrastructure delivery/access records.

Legal bases

For account and billing contacts, we rely on performing a contract where the individual is the contracting party, or legitimate interests in administering a business relationship where the individual represents a business. We process accounting records to meet applicable legal obligations. Support and proportionate service-security processing rely on providing the service and legitimate interests in responding to enquiries and preventing abuse. Where optional processing requires consent, it must be offered separately and may be withdrawn without losing essential service access. Customer-programme legal bases are determined and communicated by the participating business.

Recipients and international transfers

Information is shared only as needed with authorised personnel and contracted providers supporting hosting, email, payments, and optional wallet or editorial-AI features. See Service Providers for the services and recipient categories involved. Apple or Google receive information when you choose the corresponding Wallet flow. Editorial-AI inputs are described in AI Usage Disclosure; membership data is not automatically included in those prompts by this integration.

Where a transfer outside the EEA requires safeguards, the responsible controller must establish an applicable adequacy mechanism or appropriate safeguards, such as standard contractual clauses and supplementary measures as required. We do not promise that every provider stores every record exclusively within the EU. Ask support@rewallo.com for information about the safeguards applicable to your data and how to obtain a copy.

Retention

Account records are kept for the active relationship and subsequently only as required for closure, security, disputes and legal obligations. Membership information is held on the participating business’s instructions; cancellation of a subscription is not itself a request to erase every membership or accounting record. Support records are retained while resolving the enquiry and for a justified follow-up/dispute period. Financial records are retained for applicable statutory accounting periods. Backups and infrastructure logs have separate rotation schedules. Retention is determined by the purpose of the record, whether the account or enquiry remains active, controller instructions, outstanding disputes and applicable legal duties. Accounting source documents are generally retained for seven years from the end of the relevant financial year under Estonian accounting rules. Contact us for information about your records. Deletion from active systems and expiry of backup copies can occur at different times; retained copies remain subject to access restrictions.

Your rights

Subject to the applicable rules, you may request access, correction, erasure, restriction and portability, object to relevant processing, and withdraw consent where processing relies on consent. We may need proportionate identity checks to protect your information. Some information may need to be retained to meet legal obligations or establish/defend claims; we explain applicable limits when responding. Send requests to support@rewallo.com. We respond without undue delay and normally within one month; where the law permits an extension because of complexity or the number of requests, we explain the extension within that first month. For customer-programme records, we coordinate with the responsible business.

You may complain to a competent supervisory authority, including the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), https://www.aki.ee/en. This does not prevent contacting an authority in your country where applicable.

Storage, security and automated decisions

Cookie Policy explains essential browser storage and privacy controls. Data Security describes implemented safeguards and their limits. The editorial-AI integration does not decide customer eligibility or automatically award stamps or rewards. We do not sell membership data through this service.

Changes

The page shows its update date and version. Material changes to purposes or contractual commitments require appropriate notice and, where necessary, a new choice or agreement. A changed notice does not retrospectively create consent.

This policy covers Rewallo browser storage. Privacy settings can be reopened from the public footer or Legal and privacy centre.

Current storage

This version does not install analytics, advertising or session-replay scripts. Fonts are served from our application’s own assets, rather than loaded from Google Fonts servers. We do not ask you to agree to tracking that is not present.

• The application session cookie supports sign-in, security checks and form/session state. Its configured session lifetime is normally 120 minutes, subject to the deployed configuration and session activity. The session cookie is intended to be Secure on HTTPS and HttpOnly.
• XSRF-TOKEN supports protection against forged requests. It is intentionally readable by application JavaScript; it is not the sign-in session cookie.
• rewallo_locale remembers your chosen language for up to one year. You can change it with the language selector.
• rewallo_privacy_v1 in local storage records your necessary-only preference and its date for up to 180 days before the notice is shown again. It contains no advertising identifier and does not authorise marketing or accept subscription terms.
• Session storage may hold temporary editor/generation state while an authorised administrator works. Customer card URLs and wallet identifiers also function as access credentials; keep them private.

Browser expiry and server-side retention differ. Clearing browser storage does not delete invoices, a membership or all server-side records.

Your choice

Necessary storage supports the service you request. “Necessary only” records an acknowledgement of that configuration. There are no enabled optional tracking categories to accept in this release. You can clear this storage in your browser; doing so may sign you out or reset preferences. If optional trackers are introduced later, they require a new inventory and appropriate prior consent controls before activation.

Other services

Stripe’s hosted checkout and billing portal, Apple Wallet and Google Wallet operate their own interfaces and privacy/storage rules when you choose those services. A privacy choice on Rewallo does not control storage on their separate sites or apps.

For questions, contact support@rewallo.com and read Privacy Policy.

Scope

Rewallo provides subscriptions to businesses. This document describes how to request a review of a charge. Cancellation of renewal and a refund request are separate actions.

Request a refund review

Contact support@rewallo.com with your business name, invoice reference, charge date and the reason for your request. Do not send full payment card details. Report duplicate or incorrect charges and problems accessing a paid service so we can investigate.

Cancellation

You can cancel automatic renewal through Workspace → Plan. Cancellation takes effect at the end of the current paid period. Cancelling renewal does not itself create a refund or a credit for unused time.

Review and payment handling

We review the payment record, the circumstances of the request and your applicable contractual and statutory rights. Any approved refund is processed through the payment provider. Your bank or payment provider determines when it appears in your account.

Eligibility and your rights

Refund requests are assessed individually. We consider duplicate or incorrect charges, failure to provide the purchased service, the applicable subscription agreement and any mandatory legal rights. A change of mind or stopping use of an accessible service does not by itself establish an entitlement to a refund. This policy does not exclude a remedy required by law or an express commitment made to your business.

Outcome and questions

We communicate the result of our review to your account or billing contact. Contact support if you disagree with a charge or the outcome, and provide any relevant supporting information. No fixed bank settlement time is guaranteed.

Related documents

Read Terms of Service and Subscriptions and Cancellation for billing and cancellation information.

Rewallo business subscriptions are offered to businesses acting for commercial or professional purposes. These terms govern your business’s use of the service and the subscription confirmed at checkout.

Provider and service

Rewallo is operated by AviaTravel OÜ, registration number 17586406, Tornimäe tn 5, Kesklinna linnaosa, 10145 Tallinn, Estonia. Contact: support@rewallo.com. Rewallo provides participating businesses with a workspace for digital loyalty memberships, stamps, rewards and related subscription tools. Features and limits follow the subscribed plan.

Accounts and authority

Provide accurate registration and billing information. The person accepting these terms on behalf of a business must have authority to do so. Keep credentials secure and contact support promptly about suspected misuse. Do not use the service to access another tenant’s records, issue fraudulent stamps, send unlawful communications or distribute malicious/unauthorised content.

Loyalty programmes and customer information

Each business defines its offer, qualifying purchases and reward fulfilment. The business must describe those terms clearly to customers, honour applicable commitments and provide its own privacy information. Rewallo does not turn the business’s loyalty reward into a cash balance or guarantee the business will fulfil an offer. The Data Processing Agreement forms the contractual framework for processing customer-programme information on the business’s instructions.

Plans and charges

Review the active plan’s price, currency, billing interval, member limit, included features, tax treatment and any applicable trial in pricing and checkout before confirming. Trials are offered only where configured and eligible; a zero-day trial setting means no trial. Subscriptions renew automatically at the agreed billing interval until renewal is cancelled. Payment processing is provided through Stripe. See Subscriptions, Cancellation and Refunds for the renewal and cancellation process.

Cancellation and refunds

Cancelling future renewal and requesting deletion are different actions. Cancellation normally takes effect at the end of the current paid or trial period as confirmed in the Plan page. Refund requests are reviewed individually under our Refund Policy. Cancellation alone does not create an automatic pro-rata refund entitlement. Mandatory rights and remedies for an incorrect charge or failure to provide the agreed service remain unaffected.

Content and intellectual property

Businesses retain their rights in their logos, authored offers and uploaded material. They grant the permissions needed to display and process that material to provide the service. Only upload material you are entitled to use. Rewallo’s brand and software remain subject to their respective ownership and licences.

Availability and changes

The service may require maintenance and may change as features develop. No uptime/service-level guarantee is created unless separately agreed. Material commercial changes require appropriate notice and must not be silently substituted for the price/interval confirmed at checkout. Report access problems through support.

Suspension, termination and records

Access may be restricted where needed to address non-payment, abuse or a material breach, subject to applicable law and contractual obligations. Contact support about export, closure and deletion before ending the relationship. Legally required accounting records may remain after closure. We coordinate customer-programme data return or deletion with the responsible business under the Data Processing Agreement.

Responsibility and disputes

Nothing here excludes liability or statutory rights that cannot lawfully be excluded. Each party is responsible for its obligations under this agreement and applicable law. These terms do not introduce a special monetary liability cap. Estonian law governs the business service agreement, subject to mandatory applicable rules. Disputes may be brought before courts having jurisdiction under applicable law; no exclusive foreign forum is imposed by this notice. Contact support first so we can investigate and attempt to resolve a dispute.

Other documents and acceptance

Privacy Policy is a notice about processing, not blanket consent. Cookie choices and marketing permissions are separate from contract acceptance. The service records the version of published contractual documents accepted at registration. Read AI Usage Disclosure, Data Security and Service Providers for the relevant operational information.

Rewallo subscriptions are sold to businesses, renew automatically, and can be cancelled at the end of the current billing period.

Before subscribing

The Plan page and checkout show price, currency and billing interval. Check the final total and applicable taxes before confirming. A configured trial applies only where you are eligible; no trial is offered when trial days are zero. A payment method may be required for a trial, and the subscription can move to paid billing after the trial unless cancelled in time.

Renewal information

The subscription’s current period and cancellation status appear in Workspace → Plan. An active automatically renewing subscription can result in another charge according to the agreed billing interval. The upcoming-invoice reminder integration sends service notices when Stripe delivers invoice.upcoming events. The timing depends on the processor configuration and event delivery; this is not a guarantee that every monthly charge generates a separate reminder a fixed number of days in advance.

How to cancel renewal

Open Workspace → Plan and choose Cancel renewal where available, or use Manage subscription to open the processor’s billing portal. Review the effective date before confirming. An at-period-end cancellation stops the next scheduled renewal while preserving access until the confirmed end date, subject to the subscription’s status. Keep the confirmation and contact support if the status does not update. You can also contact support@rewallo.com about cancellation; contacting support immediately before a charge is not a guarantee it can be stopped in time.

Refund requests and disputes

Send your business name, invoice reference and reason to support@rewallo.com. We assess duplicate/incorrect charges, service problems and applicable contractual/statutory rights. Refunds are assessed individually under our Refund Policy. Cancellation alone does not automatically create a partial-period refund; applicable statutory and contractual rights remain unaffected. Stripe processing status and bank timing may affect how quickly an approved refund appears.

Trials, plan changes and cancellation of checkout

Leaving or cancelling an unfinished checkout does not itself cancel an existing subscription. Plan changes may have different effective dates or prorations as disclosed by the processor before confirmation. Do not assume that a changed plan price retroactively changes an already agreed billing period.

Data and invoices

Subscription cancellation is not an erasure request. Existing customer rewards, record access, exports and retention should be handled with the participating business and Rewallo support. Accounting documents can remain subject to legal retention obligations after cancellation.

Rewallo includes optional provider-side tools for generating editorial blog and solution-page drafts. The platform operator chooses whether to enable a supported AI provider and selects its model. Supported integrations include OpenAI, DeepSeek and Google Gemini; support in the software does not mean all providers are active.

What the integration sends

Editorial prompts can contain a topic, instructions, business niche/audience, language, brand facts and recent article titles. An administrator should not paste passwords, customer memberships, private card links or sensitive personal information into an editorial brief. The integration does not automatically include the membership database, customer balances or payment-card data in these prompts.

Review and limitations

AI text may be inaccurate, incomplete or resemble other material. Administrators are responsible for checking factual claims, product capabilities, rights and publication decisions. Some editorial automation can be configured by the operator; the presence of an AI tool is not a guarantee that every generated sentence has received human review. The operator must maintain a publication/review process appropriate to the content and applicable transparency duties.

Customer decisions

These editorial integrations do not themselves decide whether a customer can join, award stamps, redeem rewards or determine a subscription payment. They do not provide individual legal, medical or financial advice.

Provider processing

Inputs are transmitted to the selected provider’s API. The selected provider processes inputs under its applicable API terms, including its retention and international-transfer arrangements. Contact support to identify the provider used for a particular published article. Setting an API option such as store=false is not a promise of zero retention for every provider purpose. No claim is made that editorial prompts are always processed exclusively within the EU.

Questions or concerns about generated content can be sent to support@rewallo.com. See Privacy Policy and Service Providers.

Rewallo uses technical controls intended to protect business and membership information. This page describes controls in the application; it is not a security certification, guarantee against incidents, or promise that an unpatched server is safe.

Application controls

Business and provider endpoints require authentication and role/tenant checks. Passwords are hashed. State-changing browser requests use CSRF protection; selected public flows use server-side security challenges and rate limits. Stamp/reward actions use transactional processing and replay/idempotency controls. Card links and QR tokens are bearer credentials, so anyone holding a valid private card link may access that membership’s card.

Sensitive configuration and selected mail/billing payloads use application encryption at rest. This does not mean every database field or backup is encrypted with an independent key. Authorised administrators and relevant providers may access information as required to operate and support the service. Rich content and logo inputs are subject to validation/sanitisation controls.

Deployment responsibilities

HTTPS, server package patches, restricted administrative access, key management, backups, recovery testing, monitoring and provider configuration remain operational responsibilities. Application headers, CAPTCHA and a cookie popup do not fix vulnerabilities in PHP, the operating system or infrastructure. Native Wallet/device storage and third-party checkout follow their own platform controls.

Reporting an issue

Contact support@rewallo.com with a concise description, affected public route, approximate time and safe reproduction information. Do not include passwords, private keys or another person’s complete card token. Do not perform destructive tests or exploit production without an agreed scope.

Incident response and data requests

We assess reported incidents, take containment steps, investigate affected data and make notifications required by applicable law. Where we act as processor, we notify the affected business of a personal-data breach without undue delay after becoming aware of it. A universal notification deadline or claim that no breach can occur is not made here. Contact support about access, correction, deletion, export or a lost card link; we may verify identity and coordinate with the participating business.

Parties and scope

This agreement forms part of the Rewallo business service agreement. The subscribing business is the controller of its customer loyalty programme. AviaTravel OÜ, registration number 17586406, operating Rewallo, acts as processor for customer-programme information processed on the business’s behalf. Rewallo remains controller for its own account, billing, support and service-security activities described in the Privacy Policy.

Processing instructions

The processor processes personal data only on the controller’s documented lawful instructions, including instructions concerning international transfers, unless required by applicable law. The subscription, programme settings and authorised support requests constitute instructions. Where law requires different processing, the processor informs the controller before processing unless that law prohibits disclosure. The processor informs the controller if an instruction appears to infringe applicable data-protection law.

Subject, duration and data

Processing provides and maintains the customer loyalty programme for the service relationship and the subsequent return, deletion and legally required retention process. Operations include collection, organisation, storage, retrieval, display, updating, transmission and deletion. Data subjects are programme members and authorised business contacts. Data may include names, email addresses, phone numbers, membership and card identifiers, stamps, rewards, activity timestamps and optional wallet-pass/device identifiers. The standard service does not request special-category personal data. The controller must not submit such data without a separate lawful arrangement.

Confidentiality and security

The processor restricts access to authorised personnel subject to confidentiality obligations and uses appropriate technical and organisational measures considering the risk, nature and context of processing. The Data Security page describes application controls, including authentication, tenant checks, password hashing, input validation, CSRF protection and transactional loyalty actions. Neither that description nor this agreement represents a security certification or a guarantee that incidents cannot occur.

Subprocessors

The controller provides general written authorisation to engage infrastructure and delivery subprocessors needed to provide the service. The Service Providers page describes the recipient categories and supported services. The controller may request the current identities and relevant processing information at support@rewallo.com. Before adding or replacing a subprocessor handling customer-programme information, the processor gives the controller notice and an opportunity to object on reasonable data-protection grounds. The parties work to address an objection; if no suitable arrangement is available, the affected processing must cease and the parties arrange service closure and data return or deletion. The processor imposes materially equivalent data-protection obligations on subprocessors and remains responsible for their performance of those obligations.

International transfers

Where required, processing outside the EEA must rely on an applicable adequacy decision or appropriate safeguards, such as valid standard contractual clauses and supplementary measures. This agreement does not itself represent that standard contractual clauses have been signed with every supported integration. The processor provides information about the mechanism applicable to the controller’s data on request. Optional wallet features operate under the relevant platform arrangements described in Service Providers.

Requests and assistance

Considering the nature of processing and information available, the processor assists the controller with data-subject requests and its duties concerning security, breach assessment and notification, impact assessments and consultation with supervisory authorities. Requests received directly from members are referred to the controller where appropriate. The controller remains responsible for deciding the legal basis, programme notices and responses concerning its programme.

Personal-data breaches

The processor notifies the controller without undue delay after becoming aware of a personal-data breach affecting the controller’s information. Information is supplied as available, including the nature of the incident, affected categories and approximate scope where known, likely consequences, mitigation steps and a contact point. The processor cooperates with the controller’s investigation and required notifications.

Return and deletion

At the end of processing, the controller may choose return or deletion of its customer-programme information, except where applicable law requires retention. Contact support to arrange a suitable electronic export and confirm the scope and timing of closure. Residual backup copies expire through backup rotation and remain protected from ordinary use. If a backup is restored, previously agreed deletion instructions must be reapplied. Information retained for a legal obligation is restricted to that purpose. Cancellation of renewal alone is not an instruction to erase all customer records immediately.

Evidence and audit

The processor makes information necessary to demonstrate compliance with this agreement available to the controller and permits audits and inspections by the controller or its mandated auditor. The parties coordinate scope, timing, confidentiality and security so an audit does not expose another business’s data or unnecessarily disrupt the service. These arrangements do not remove statutory audit or supervisory-authority rights.

Contact and precedence

Send privacy instructions and incident questions to support@rewallo.com. This agreement prevails over conflicting general service terms for processing carried out on the controller’s behalf. Mandatory applicable data-protection law remains unaffected.

This page describes the services and recipient categories involved in Rewallo. A supported optional integration is used only when configured and invoked. Contact support@rewallo.com for the current contracting entities, processing locations and safeguards relevant to your account or programme.

Hosting and infrastructure

Rewallo uses Hetzner infrastructure administered by Rewallo. Hosting processes account and programme records, application files and operational information needed to run the service. CloudPanel is server-administration software; using it does not itself mean that its publisher receives customer records. Administrative access is limited to service-operation needs.

Transactional email

The configured SMTP delivery service processes recipient addresses, service-message content and delivery metadata. Messages include account/security notices, loyalty-card delivery, support and billing communications. The delivery supplier can depend on the active mail configuration; request its identity and applicable processing information from support. Rewallo does not treat joining a loyalty programme or accepting service terms as permission to send marketing.

Payments — Stripe

Stripe provides hosted checkout, subscription processing and the billing portal where connected. Billing contact information, subscription references and payment status are exchanged as needed. Full payment-card details are entered with the payment provider. Stripe’s role, contracting entity and processing terms depend on the service and account location. Stripe Privacy Policy. Test mode does not collect a real subscription payment.

Apple Wallet and Google Wallet

When a customer chooses an available wallet integration, pass information may include the business name, reward description, card identifier, balance, barcode and update/device identifiers. The wallet platform processes information under its own terms and privacy arrangements and may act independently for platform operations. Apple Privacy Policy and Google Privacy Policy.

Optional editorial AI

Supported editorial integrations include OpenAI, DeepSeek and Google Gemini. The selected provider receives editorial prompt information when an authorised administrator uses that integration. Customer membership records and payment-card data are not automatically included by these editorial tools. Consult AI Usage Disclosure for the information sent and limitations. Contact support to identify the provider used for a particular article or request.

Analytics, advertising and fonts

Fonts are served locally. The current application does not enable Google Analytics, advertising tags or session replay. These services may be introduced later, but this page does not authorise future tracking. Before activation, the relevant disclosures and consent controls must be updated. A saved necessary-only choice is not permission for analytics or advertising.

Transfers and provider changes

Providers may process information outside the EEA according to their services and applicable arrangements. Where required, the responsible controller establishes an applicable transfer mechanism, including adequacy or appropriate safeguards. Ask support for details and copies of relevant safeguards. Customer-programme subprocessor changes follow the notice and objection arrangements in the Data Processing Agreement.