This Policy describes the types of information that we gather from you and the other people who visit the Site ("Users"), how we may use that information and how you can contact us regarding this Policy and your personal information. This Policy also describes additional rights that California Users have under the California "Shine the Light" law and the California Consumer Privacy Act ("CCPA").
Please read this entire Policy carefully before using the Site or providing us with any information that is personally identifiable to a User ("PII") and information that is not personally identifiable to a User ("non-PII") (together, "Information"). When you access or use the Site, you consent to the collection, use, processing, and disclosure of your Information in accordance with this Policy by us, our third party marketing partners, and our parent, subsidiaries and entities under common control with us ("Affiliates"). If you do not agree to the terms of this Policy, you are not authorized to use the Site.
We and our marketing partners and Affiliates collect Information in a number of different ways. We collect Information submitted by a User on our Site, including PII such as their name, email, address, phone number, date of birth, age and gender. We also use technological means to collect Information about a User such as the type of device and browser they are using, where they were browsing before they arrived at our Site, their IP address, their MAC address, their browser information, and if a User is on a mobile device then which carrier they use. This Information may be supplemented or verified by third party services.
Non-PII that a User submits could be associated with your PII.
If you reached the Site by clicking on a link or an ad from another website or from an email sent from one of our marketing partners, then we may also capture that information to understand the interests of our Users and to keep track of third parties who direct Users to our Sites.
In order for a User to take full advantage of the Site, we ask Users to voluntarily provide their PII to us. If a User chooses not to provide us with their PII by simply not entering it on the Site or not otherwise providing it to us, the User will not be able to access or use certain of the services or features available through the Site that require the submission of that PII. For example, a User that chose to provide us with the PII required to register, but chose not to provide us with PII would not be able to claim your benefits.
We use technologies such as "cookies" (small text files placed/dropped on a User's device), "web beacons" (single-pixel GIF files) or similar technologies to track the User's online behavior and interaction with the Site, including Google Analytics-related cookies, Pushly-related cookies, and AdRoll-related cookies. We may permit these or other third parties to use these technologies to track your online behavior for our purposes described below or their own purposes. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
We may use the Information (whether PII or non-PII) that a User provides us to, among other things:
We may use Google Analytics and similar tools provided by our third party partners to help analyze how Users interact with the Site and display customized ads and other content to our Users during a current browsing session or in the future when the User is online. These analytics are performed by using the technological means described above to monitor a User's interactions with the Site and may include the collection of PII described above.
We and our Affiliates and marketing partners may advertise and promote the Site and we may permit our marketing partners to place ads and other content, including links to other websites, on the Site. While we try to post links only to third-party websites that share our respect for privacy, this Policy and our privacy practices do not extend to and may differ from those of third-party websites that can be accessed through links on this Site. You should review the applicable privacy policies of the third-party websites before registering with, providing Information to or navigating those websites.
The Site is intended to comply with the Children's Online Privacy Protection Act (COPPA) and CCPA. COPPA requires that web site operators never knowingly collect PII from anyone under the age of 13 without prior verifiable parental consent. The Site is not intended for minors under the age of 18 and we do not knowingly collect or use PII from minors under the age of 18. If we discover personal data from a minor under the age of 18, we will eliminate that data. Only adults age 18 or over are permitted to be Users.
By using the Site, you agree to provide us with accurate information concerning your age or identity if we request it. You also agree not to assist children under the age of 18 in accessing the Site or to attempt to contact children under 18 through the Site.
The Site is also not intended for persons not resident in the U.S. We use filters that are designed to prevent non-U.S. residents from accessing the Site.
Users may opt-out from receiving future offers from us, including having their email address removed - unsubscribed - from email marketing lists or our no longer selling or leasing your PII to unaffiliated third parties, by:
We may request authentication or verification of a User's request to opt-out, for example by requesting that a User reenter their email address or other PII, by requiring authorized agents of a User to provide additional PII of the User and authorizing documents to confirm their authorization by the User, or by sending a confirmation email to a User which the User must confirm prior to the Opt-Out request taking effect.
Users may opt out from the collection of online viewing data for behavioral advertising purposes by companies who have elected to participate in one of the behavioral advertising opt-out mechanisms such as the Digital Adverting Alliance's opt-out program. As is the case with most websites, we have not elected to participate in any of these programs at this time, and such opt-outs will not constitute an Opt-Out request under this Policy.
Users may disable cookies, web beacons and other technological means placed by our Affiliates and third party partners by adjusting their browser or email client settings. Users may also opt out from the collection of online viewing data for analytics purposes performed by Google Analytics by going to Ad Settings under their Google account. As noted above, we may identify you by your email address, third party cookies, or other means, and will use these methods to tailor your experience on our Site if you visit our Site or one of our Affiliate's sites in the future.
Users may revoke their consent to receive telemarketing calls from us and/or the persons named in the consent by indicating that do not want to receive any further telemarketing from us or the persons named in the consent.
We use commercially reasonable efforts to prevent unauthorized access or disclosure, or accidental loss or destruction of your Information. We currently do not encrypt Information that we store except for health related information. Given the nature of the Internet, your Information passes through entities that we are unable to control. Therefore, we cannot guarantee that our security measures or those of our Affiliates or third parties who access or transmit your Information will prevent your Information from being illegally accessed, stolen or altered.
Users have a right to request the PII we have stored about them. Users may request the PII we have stored about that User by contacting us at firstname.lastname@example.org with the subject line "Request to Know" or by sending a letter to our postal address below with the same request.
Users who provide their Information to us may modify, correct, or delete some or all of their Information by modifying their Information in the "My Account" webpage on the Site, by contacting us at email@example.com with the subject line "Request to Modify or Delete" and include the Information to modified or deleted in the body of the email, or by sending a letter to our postal address below with the same request.
The California "Shine the Light" law permits Users who are California residents to request information regarding our disclosure of their Information to third parties including the categories of Information shared and a list of the names and addresses of third parties with whom the Information was shared. If you are a California resident and would like a copy of this notice, please send an email request to firstname.lastname@example.org and identify that it is a "Shine the Light Request" in the subject line of the email, or by sending a letter with the request to:
Rewards Service Center
Attention: Privacy Request
PO Box 8788
Virginia Beach, VA 23454
Most browsers contain a "do-not-track" setting. In general, when a "do-not-track" setting is active, the User's browser notifies other websites that the user does not want their personal information and online behavior to be tracked and used, for example, for behavioral advertising. If your browser is set to do not track, our Site will respond in accordance with that setting so that, for example, we will not be able to access any cookies stored in your browser. The impact a do not track setting has on a website's operation varies from browser to browser. You should be aware that we use other means to identify Users who have previously visited our Site, including their email address and tracking a User's online behavior while on our Site. We may use this information to tailor the User's experience should they visit our Site or sites belonging to our Affiliates in the future. Setting your browser to "do not track" will have no impact on these practices.
We reserve the right to revise and update this Policy at any time. If we make material changes to this Policy, we will post a notice on our Site from the date we post the revised Policy until at least 10 days after the revised Policy has been in effect. Any such revisions will be effective 10 days after posting to the Site and will apply to all Information collected by us both before and following the effective date. Your use of the Site following any such revisions will be deemed your acceptance of such revisions. Users should periodically visit this page to review our current policies on our collection and use of Information.
Users may designate an authorized agent under the CCPA to act on their behalf by sending a letter to the postal address above with a signed letter that includes the name, email address, and date of birth of the User for verification, along with either the User's signed designation of the authorized agent or a court order or similar legal document designating the authorized agent as acting for the User (for example, a power of attorney or letters testamentary).
For additional Information or if you have any questions, comments, complaints, or suggestions regarding our Policy or one of our Sites, please contact us at email@example.com.
Effective Date: April 20, 2020