Privacy Policy

INTRODUCTION
1. This Privacy Policy describes how Ignition Digital LLC, a Delaware limited liability company (“Treatley”, “Provider”, “we”, “us”, or “our”), handles your Personal Information and explains your privacy rights when you:
  1. subscribe to Treatley through our inbound sales call;
  2. create and use your Treatley account;
  3. visit or use the Treatley Home Page;
  4. receive and redeem Voucher(s) from Selected Retailers as part of your Subscription; and
  5. contact us through our customer support email channel.
2. For purposes of US Data Protection Laws, Treatley acts as a ‘business’ (or controller) when collecting and processing Personal Information.
3. Please read this Privacy Policy together with our Subscription Agreement and Platform Terms and Conditions (‘’Terms’’). By subscribing to Treatley, using the Treatley Platform, or providing us with Personal Information, you acknowledge that you have read and understood both the Terms and this Privacy Policy. If you do not agree with them, you should not subscribe to or use Treatley.
4. This Privacy Policy also serves as our Notice at Collection under the CCPA. We collect the categories of Personal Information described in Section 3 for the purposes set out in Section 3.3. We retain each category of Personal Information for as long as needed to provide your Subscription and comply with legal obligations. We do not sell or share Personal Information as those terms are defined under the CCPA.
DEFINITIONS
1. “Applicable Laws” means all applicable federal and State laws, regulations, regulatory requirements and codes of practice in the United States of America including the FTC Act, as amended and in force from time to time;
2. “Consent” means a clear and affirmative action by which you indicate your agreement to the Processing of your Personal Information for a specific purpose;
3. “Contact Center” means the division of the Provider that manages inbound sales calls and facilitates Treatley Subscription sign-ups;
4. “Cookies” means small text files that are stored on your device when you visit a website. Cookies allow the website to recognise your device, remember your preferences, and support core functionality;
5. “FTC” means the United States Federal Trade Commission, and “FTC Act” means the Federal Trade Commission Act of 1914, as amended;
6. “Link” refers to the click-to-reveal link which discloses a unique digital code associated with a Voucher, and which is transmitted to a Subscriber via email;
7. “Login Details” means information captured to access the Platform such as a unique username and password;
8. “Monthly Subscription Fee” means the recurring monthly fee payable in advance by the Subscriber to the Provider, in USD, in exchange for access to the Platform. The amount of the Monthly Subscription Fee is specified in the pricing details provided by the Provider;
9. “Person” means, where the context so requires, an individual, firm, company, corporation, juristic person, local authority, and any trust, foundation, organisation, association or partnership, with or without a separate juristic personality;
10. “Personal Information” means any information as defined in the applicable US Data Protection Laws, including but not limited to:
  1. First name and surname;
  2. Billing information;
  3. Mobile Number; and
  4. Email Address;
11. “Platform” means the Provider’s web-based platform known as Treatley, which provides Subscribers with access to promotional offers. The Platform is intended for use in respect of the USA domestic market, and is accessible by signing in on the Treatley Home Page through the required Login Details;
12. “Policy” means this Privacy Policy that may be accessed on the Platform;
13. “Processing” means any automated or manual activity of collecting, recording, organizing, storing, updating, distributing and removing or deleting Personal Information;
14. “Provider” means Ignition Digital LLC, a corporation organized and existing in accordance with the laws of the State of Delaware with registered office at 1700 Market Street, Suite 3010, Philadelphia, 19103;
15. “Retailer Product(s)” means the goods purchased or available to purchase by the Subscriber from the Selected Retailer(s) when redeeming a Voucher;
16. “Selected Retailer(s)” means any participating retailer, as stipulated in the Terms and on the Platform, where a Subscriber can redeem a Voucher;
17. “Sensitive Personal Information’’ means information as defined in the applicable US Data Protection Laws, including but not limited to:
  1. Social Security, driver’s license, state identification card or passport number;
  2. Login or financial account number in combination with a security or access code, password, or other credentials that allow access to the account;
  3. Precise geolocation information.
18. “Service Provider(s)” means a third party that processes Personal Information on our behalf for a business purpose, under a written contract that prohibits the Service Provider from retaining, using, or disclosing the Personal Information for any purpose other than performing the services we have requested or as otherwise permitted by Applicable Laws;
19. “State” shall refer to any of the 50 (fifty) states of the USA;
20. “Subscriber(s)” means any Person(s) who takes all required actions, including creating a User profile and paying the Monthly Subscription Fee, to benefit from the use of the Platform;
21. “Subscription” means the Subscriber’s access to and use of the Platform as stipulated in the Terms;
22. “Treatley Home Page” means the https://treatley.co/ webpage, serving as the point where Users can create a profile and sign into the Platform;
23. “USA” or “US” refers to the ‘United States of America’, the country consisting of 50 (fifty) States located primarily on the North American continent, with Alaska in the northwest, and extending to the off-shore island nation of Hawaii located in the Pacific Ocean.
24. “US Data Protection Law(s)” shall mean all laws, regulations, and regulatory requirements, in any jurisdiction of USA, relating to the collection, use, disclosure, Processing, storage, and protection of Personal Information, personal data, or similar information, including but not limited to:
  1. the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”);
  2. the Virginia Consumer Data Protection Act (VCDPA);
  3. the Colorado Privacy Act (CPA); and
  4. any substantially similar or successor laws enacted or regulations promulgated by any State or federal authority of the USA relating to data privacy or data protection;
25. “User(s)” means any Person visiting or viewing the Treatley Home Page who is not yet a Subscriber;
26. “Voucher(s)” means a promotional voucher, accessible through a Link, which permits the Subscriber to receive a promotional offer which may be redeemed in accordance with the provisions of these Terms when purchasing Retailer Products from Selected Retailers. Each Voucher constitutes a promotional offer:
  1. provided to Subscriber free of any additional charges, and is not a gift card or prepaid card;
  2. with no stored or reloadable balance and no consumer balance tracking;
  3. that is non-transferable, carries no actual cash value, and may not be redeemed for cash or credit (except where required by law).
27. “You” or “your” means the Subscriber and/ or the User.
PERSONAL INFORMATION WE COLLECT AND HOW WE COLLECT IT
1. Categories of Personal Information We Collect
  Depending on how you interact with us, we may collect the following categories of Personal Information:
  1. Basic Personal Identifiers
    1. First name and surname;
    2. Mobile number;
    3. Email address;
    4. Residential and/ or billing address.
  2. Subscription and Account information
    1. Your Subscription status;
    2. Account credentials you create after email verification;
    3. Voucher selections;
    4. Voucher redemption status and history.
  3. Payment-related information
    1. Limited payment details such as the billing profile, payment token, and payment method type;
    2. We share payment-related information with our third-party payment processing provider, acting as our Service Provider, solely to process Subscription payments.
    3. During inbound sales calls, when you provide your card information, the part of the call in which this information is captured is masked in the recording so that your full card number and security code is not audible in the call recording to us. Treatley does not store full card numbers or security codes in its operational systems.
  4. Device and Log Information
    1. Login and authentication information;
    2. Basic technical information (such as IP address, browser type, and access timestamps) when you visit the Treatley Home Page.
    3. Treatley uses only strictly necessary Cookies for security, session management and core Platform functionality. We do not use analytics, advertising, or behavioural tracking Cookies. For more information, please see our Cookie Policy.
  5. Customer support and communications data
    1. Copies of communications between you and us. For example, emails to support@treatley.co or interaction notes captured by our customer support teams.
    2. These notes are intended to describe the interaction and typically do not include additional Personal Information beyond the details already associated with your Treatley account.
  6. Sensitive Personal Information
    1. We do not intentionally collect Sensitive Personal Information beyond what is necessary to authorise payments and prevent fraud through our third party payment processor acting as our Service Provider.
    2. When you provide card information, they are captured directly by our Service Provider for payment processing and we do not have access to or store your full card number or security code.
    3. We do not use or disclose Sensitive Personal Information for purposes that require consumers to exercise the right to limit such use under the CCPA. We use Sensitive Personal Information only for permitted operational purposes, including payment authorisation and fraud prevention.
2. How We Collect Personal Information
  1. Sales Call Subscription
    When you subscribe through our Contact Center, you may provide identifying and payment information. Sales calls are recorded, and we provide a notice at the start of each call stating that the call is being recorded.
  2. Activation and Account Creation
    After the sale is captured, Treatley sends a Welcome Email. Once you verify your email, you may create Login Details and manage your Subscription through the Platform.
  3. Voucher Selection and Redemption
    When you select Voucher(s) on the Platform. Selected Retailers do not receive your Personal Information when you redeem a Voucher.
  4. Customer Support
    1. If you contact us at support@treatley.co, we collect the content of your communication and any information you provide.
    2. This information is used to provide support, investigate and resolve issues, improve service quality, and maintain accurate records for compliance and dispute resolution purposes.
3. Purposes for Processing Personal Information
  We use Personal Information for the following purposes:
  1. creating, managing, and administering your Subscription;
  2. verifying your identity, processing payments, and managing billing;
  3. providing Voucher selection, delivery, and redemption statuses;
  4. recording inbound sales calls for quality assurance, dispute resolution, fraud prevention, billing verification, and compliance auditing;
  5. communicating with you regarding your Subscription, available Retailers, redemption reminders, or operational updates;
  6. maintaining the security, performance, and integrity of the Platform; and
  7. complying with Applicable Laws, including US Data Protection Laws, financial recordkeeping obligations, regulatory requirements and to cooperate with law enforcement or regulators where required.
4. We will not use your Personal Information for materially different, unrelated or incompatible purposes without providing you with notice and, where required by Applicable Laws, obtaining your Consent.
5. Whether We Sell or Share Personal Information
  1. We do not sell Personal Information, and we do not share Personal Information for cross-context behavioural advertising as those terms are defined under the CCPA and similar State privacy laws or for any purpose defined as ‘selling’ or ‘sharing’ under the CCPA.
  2. We only disclose Personal Information to Service Providers that process data on our behalf under written contracts that restrict their use of the information to the services we request.
  3. If we ever intend to sell Personal Information or use Personal Information for targeted advertising, we will update this Policy and provide additional notice and choice mechanisms as required by Applicable Law.
HOW WE DISCLOSE PERSONAL INFORMATION
We may disclose Personal Information to the following categories of Service Providers, in each case only as necessary for the operation of the Platform and subject to contractual obligations requiring them to protect the information and use it only as instructed:
1. Payment and Billing Providers
  Service Providers for card processing, billing and refunds. Card information is Processed by such providers in accordance with PCI DSS compliance and their own privacy and security obligations.
2. Voucher Fulfilment Providers
  Service Providers that enable Voucher catalogue management, Voucher generation and delivery. Selected Retailers do not receive your Personal Information when you redeem a Voucher.
3. Platform and Infrastructure Providers
  Service Providers that host and maintain Treatley systems, support data storage, provide IT support and security, and help us operate the Platform.
4. Group Companies and Subsidiaries
  We may disclose Personal Information to our parent company and subsidiaries where they support the operation, administration, infrastructure, or security of the Platform. These entities act as our Service Providers and may process Personal Information only on our behalf and under our instructions.
5. Legal, Regulatory, and Business Transfers
  1. We may disclose Personal Information to:
    1. regulators, law enforcement agencies, courts and other government authorities where we believe disclosure is legally required or appropriate to comply with Applicable Laws;
    2. third parties where disclosure is necessary to protect our rights, safety, or security of Treatley, our group companies, our Subscribers, or any other Person;
    3. any actual or potential buyer (and its agents and advisers) in connection with a merger, acquisition, financing, or similar business transaction.
  2. Any such disclosures will be limited to what is necessary for the purpose and will be subject to appropriate confidentiality protections.
CROSS-BORDER TRANSFERS OF PERSONAL INFORMATION
1. Some of our supporting teams and Service Providers are located outside the United States, including in South Africa and your Personal Information may be accessed or processed there. As a result, your Personal Information may be transferred to and processed in other countries.
2. These countries may have data protection laws that differ from those in your State of residence. Regardless of location, we take reasonable steps to ensure that Personal Information is protected in line with this Policy. These steps include:
  1. using data Processing and data transfer agreements;
  2. requiring Service Providers to protect Personal Information and use it only as instructed;
  3. applying technical and organisational safeguards such as access controls and secure transmission.
3. By subscribing to or using Treatley and providing Personal Information to us, you acknowledge that your information may be transferred to and processed in these other jurisdictions.
COOKIES AND SIMILAR TECHNOLOGIES
1. We use Cookies and similar technologies to support the security and functionality of the Treatley Home Page and the Platform, for example to:
  1. keep you signed in during a session;
  2. protect your account from unauthorised access;
  3. manage traffic and maintain the reliability of our services.
2. At present, we only use strictly necessary Cookies and do not use analytics, advertising, or behavioural tracking Cookies.
3. For more information about how we use Cookies and how you can manage them, please read our Cookie Policy.
DATA SECURITY
1. We take reasonable and appropriate technical, administrative and physical safeguards to protect Personal Information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or unauthorised access.
2. These measures include, for example:
  1. access controls and role-based permissions;
  2. secure storage of Subscription data in controlled environments;
  3. encryption and secure transmission of data, where appropriate;
  4. password protection and authentication controls for accounts;
  5. the use of PCI DSS-compliant payment processors for card information;
  6. internal policies, training and procedures to promote information security awareness.
3. Despite these measures, no method of transmission over our Platform or method of electronic storage is completely secure, and we cannot guarantee absolute security. However, we are committed to continuously improving our security practices in line with industry standards and Applicable Laws.
4. It is important for you to protect against unauthorised access to your password and to your computers, devices, and applications. We recommend using a unique password for your Treatley account that is not used for other online accounts. For general guidance on protecting yourself from fraud or identity theft, you may visit the Federal Trade Commission’s website at https://consumer.ftc.gov.
DATA RETENTION
1. We keep Personal Information only for as long as reasonably necessary to:
  1. provide you with access to the Platform and fulfil your Subscription;
  2. manage our relationship with you;
  3. comply with Applicable Laws;
  4. resolve disputes and enforce our agreements; and
  5. detect, prevent and investigate fraud or misuse.
2. We retain each category of Personal Information for as long as necessary to provide your Subscription, maintain business records, comply with legal requirements, and resolve disputes. This is generally 3 – 5 years, depending on the category. When information is no longer required, we delete or de-identify it.
YOUR PRIVACY RIGHTS (US RESIDENTS)
1. Depending on where you reside, you may have certain rights in relation to your Personal Information under US Data Protection Laws.
2. Subject to US Data Protection Laws and certain exceptions, you may have the right to:
  1. Right to Know and Access –
    You may request confirmation of whether we process your Personal Information and access to the Personal Information we hold about you. Where required by Applicable Law, we will provide this information in a portable and readily usable format.
  2. Right to Correction –
    You may request that we correct inaccurate Personal Information we maintain about you, taking into account the nature of the Personal Information and the purposes for which we Process it.
  3. Right to Deletion –
    You may request that we delete Personal Information we hold about you, subject to legal and operational exceptions (for example, where we must retain data to comply with Applicable Laws or to establish or defend legal claims).
  4. Right to Opt-Out of Certain Processing –
    You may request that we do not Process your Personal Information for:
    1. the “sale” of Personal Information;
    2. “sharing” of Personal Information for cross-context behavioural advertising; or
    3. targeted advertising or certain forms of profiling where regulated.
  5. As noted at Section 4, we do not currently sell Personal Information or share it for cross-context behavioural advertising.
  6. Right to Non-Discrimination –
    We will not discriminate against you for exercising your privacy rights. This includes not denying you goods or services, not charging you different prices or rates, and not providing you a different level or quality of services solely because you exercised your rights.
3. These rights apply to you to the extent required by applicable State privacy laws.
4. How to Exercise Your Rights
  1. You may exercise your privacy rights by contacting us at support@treatley.co.
  2. When you make a request, we may need to verify your identity to protect your security and privacy. Verification steps may include matching the information you provide with information we already hold.
  3. We will respond to your request within the timeframe required by US Data Protection Laws, typically within 45 days. If we need more time to complete your request, we will notify you and explain the reason for the extension.
  4. You may also authorise an agent to submit certain requests on your behalf, where permitted by law. We may require proof of such authorisation and may ask you to verify your identity directly with us.
  5. If we deny your request, you may appeal our decision by contacting us at support@treatley.co. We will review the appeal and respond within the timeframe required by applicable State law (typically 45–60 days).
COMMUNICATIONS
1. We may send you electronic communications in connection with your Subscription and use of the Platform, including:
  1. service or transactional communications such as account activation emails, confirmations, Platform notices, Voucher delivery emails, changes to the Terms or this Policy.
2. If we decide to send promotional or marketing communications in future, we will update this Policy and, where required, obtain your Consent before doing so.
CHILDREN’S PRIVACY
1. The Platform is intended for use by individuals 18 years of age or older. You must be at least 18 to subscribe to and use the Platform. We do not knowingly permit Subscriptions by individuals under 18 years of age.
2. We do not knowingly collect Personal Information from children under 13. If we become aware that we have collected Personal Information from a child under 13, we will take reasonable steps to delete the information and close any related account.
3. If you believe that a child has provided us with Personal Information, please contact us at support@treatley.co so we can investigate and take appropriate action.
INCIDENT RESPONSE PROCESSES
1. We maintain processes to help detect, investigate and respond to potential data security incidents. If we determine that a data security incident has occurred that affects your Personal Information, we will take reasonable steps to investigate the incident and mitigate its impact.
2. Where required by Applicable Laws, we will notify you and/ or the appropriate authorities about the data security incident and provide information as required by applicable State notification laws.
CHANGES TO THIS PRIVACY POLICY
1. We may update this Policy from time to time to reflect changes in our Processing activities, legal requirements, or the operation of the Platform.
2. When we make material changes, we will update the “Last Updated” date at the top of this Policy and, where required by law, provide additional notice such as by email or through the Platform.
3. Your continued use of the Platform after any changes to this Policy will constitute your acceptance of the updated Policy.
CONTACT US
If you have any questions about this Policy, wish to exercise your privacy rights, or would like to make a complaint, please contact us at support@treatley.co.

Cannot Issue Voucher

Cannot Add Voucher

Cannot Add Voucher

Cannot Add Voucher

Voucher Unavailable

Account Notice

Call Me Back

Your Cart Is Full

Already Downloaded

Select an Option

R100 p/m3 x R100 Gift Cards Every month

R50 p/m3 x R50 Gift Cards Every month

Welcome to Treatley

Forgot My Password

Set My Password

R100 p/m
3 x R100 Gift Cards
Every month

R50 p/m
3 x R50 Gift Cards
Every month