Police Effective Date: January 1, 2018
Description of Users and Acceptance of Terms
1. Collection of Information
We collect, process, and use your information when you:
Register for our Services or sign in to an existing account;
Visit our website(s);
Access our Services through our application(s);
Connect to our Services using third-party accounts, such as your email, social media, or payment account(s);
Contact us for support; and/or
Enter a sweepstakes, contest, promotion, survey, or poll
Further, we and our service providers automatically collect certain information about you through:
Interaction with our Services;
Cookies and other tracking technologies;
Location-identifying technologies; and
Monitoring and analyzing trends, usage, and activities
The types of information you provide may include Personal Information. “Personal Information” means information that can be used to identify you (whether alone or in combination). The Personal Information you may provide to us includes, but not limited to, the following:
First and last name;
The nature of the product or service requested or purchased;
How you connect to our Services, such as your IP address, unique device identifiers, device or session IDs, and information regarding the network and connected hardware (e.g., computer or mobile device);
Your geolocation; and
Click-stream data (the page-by-page paths you take as you browse through our Services)
2. Use of Information We Collect
We may use information about you in the following ways:
Manage Your Account
If you provide us Personal Information, we may use it to: (i) process your registration with our Services, including verifying whether your email address is active and valid and enrolling you into our programs; (ii) monitor your purchase transactions; (iii) deliver you rewards or payments, and identify opportunities for rewards and/or offers; (iv) send you technical notices, updates, security alerts, and administrative messages; (v) provide you member services regarding your account and reply to your questions, comments and requests; and (vi) comply with legal and regulatory provisions in force and with the competent judicial authorities in each geographical jurisdiction that the Company operates in. We may also use your information to assess risk and prevent fraud.
Improve Our Services
We may process information through analyzing and monitoring usages and trends and performing statistical analyses to improve our Services and the websites, applications, marketing efforts, and the products and services of our affiliates to provide a better service to you in the future. We may also use this information to adapt Service content to be more likely to be of interest to you.
Provide You Marketing Information
To provide you more personalized offers and/or special offers, discounts and similar information, Company may send you newsletters, rewards, codes, events and general information about the service if you consent. To match your profile and interest, we may create a profile of your preferences and provide advertisements, content or features.
Administer Contests, Sweepstakes, and Promotions
From time to time, Company may invite you to enter various contests, sweepstakes, surveys or promotions. If you choose to participate in a contest or promotion, your Personal Information may be used to administer the contest, such as to determine your eligibility for the contest or to award a prize.
3. Sharing of Information
We may share the information we collect, including your Personal Information, under the following circumstances.
Service Providers and Business Partners
We do not sell your Personal Information and only share it with third parties to operate our Services. We may share your Personal Information with our service providers that perform marketing services and other business operations on our behalf, under our instructions and in compliance with appropriate technical and organizational security measures to protect your data. For example, we may partner with other companies to provide you support services, authentication services, prevent fraud on our Services, administer our promotions, referral programs, sweepstakes, and surveys, perform analytics, maintain the accuracy of our databases, and administer your rewards or payments. Further, we may share your information with our financial institution partner, Sutton Bank, for the purposes of providing rewards or benefits to you and marketing our co-branded prepaid credit cards to you. We will not sell your Personal Information or your payment information, but we may rent, sell, and share other information that cannot be used to identify you with merchant partners, third parties, or affiliates. Information that we may rent or sell will not include your Personal Information and will not include payment information.
Protection of Rights and Other Legal Purposes
We may share the information we collect, including Personal Information, to the extent permitted by applicable law, (i) in response to subpoenas or other legal process or if in our good faith opinion such disclosure is required or permitted by law; (ii) at the request of governmental authorities conducting an investigation; (iii) to defend our terms and conditions or other policies applicable to our Services; and (iv) to protect the rights, property, life, health, security and safety of us or any third party.
We may share the information we collect, including Personal Information, with any third party in connection with, or during negotiations of, any proposed or actual merger, purchase, sale (including a liquidation, realization, foreclosure, or repossession), or any other type of acquisition of all or any portion of Company assets, conveyance or transfer of all or a portion of our business to another company.
4. Your Choices
You may in some cases have the option to decline providing us information. However, your choice to not provide information may impact your use of certain features or services. You may unsubscribe or opt out of receiving marketing communications from us by using the unsubscribe link on the footer of our marketing emails, by logging into your account settings, or by using the Contact Us option through the Services. Upon request, we will provide you with information whether we hold any of your Personal Information. We encourage you to maintain the accuracy of the information you submit to us, such as the information you provide us to register for your account. The Services may allow you to access, review, correct, update, and remove or make inaccessible Personal Information you have provided through your account settings. You may provide account updates and changes by logging into your account and changing settings or by using the Contact Us option through the Services. With respect to our mobile and other applications, you can prospectively stop all collection of information by the application by uninstalling the application. You may at any time opt out from further allowing us to have access to your location data by adjusting the permissions in your mobile device. We will make good-faith efforts to make requested changes in our then-active databases as soon as reasonably practicable.
5. Data Security and Retention
We take reasonable measures to protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. We use a secure, encrypted connection on all pages where you access or transmit Personal Information. Although Company uses reasonable efforts to help protect your information, transmission via the Internet is not completely secure and Company cannot guarantee the security of your information collected through our Services. Except as otherwise set forth under applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our control. We retain the information collected via our Services until such time as you choose to close your account. After that time, we may aggregate the data and retain it for analytical purposes. We may also retain your information on backup media to comply with applicable law, to support financial audits, to resolve disputes, to maintain compliance efforts, and for other legitimate business reasons.
6. Promotional Communications
By signing up for an account, you may receive periodic emails from Company. If you consented to receiving promotional email communications, you can opt out of receiving such communications from us at any time by (i) following the instructions provided in those communications; (ii) modifying your Email Preferences in the Account Settings of your account; or (iii) contacting us through the Services. Please note that even if you opt out of receiving promotional communications, we may continue to send you non-promotional emails and other types of communications, as permitted by law, such as service emails relating to our ongoing business relationship. Service emails contain service-related announcements that affect your account, such as product order confirmations, reward or payment updates, and responses to your comments and feedback submitted to us. Company mobile applications, browser extensions, and websites may send you notifications, such as alerts, sounds, and icon badges. Push notifications or in-app messages may include both operational messages and promotional messages regarding products, services, and offers that may be of interest to you. When using mobile applications, push notifications and other mobile alerts can be configured in the settings of your mobile device. As with emails, even if you opt out of receiving promotional communications, we may continue to send you non-promotional push notifications, such as those about your use of the applications or our ongoing business relations.
8. Analytics, Targeting, Tracking
9. Third-Party Data
10. Social Features
11. Referral Programs
Company may offer features which allow you to inform an individual about our Services. If you choose to use our referral features, we will ask you for your referral’s email address to send them an electronic communication inviting them to join our Services. Company will store this information for the sole purpose of sending this email and tracking the success of our referral program. If you choose to participate in our referral programs, you represent and warrant that you have a personal relationship with your referral and that you are authorized to share their information with Company for the purpose of sending this communication to invite them to join the Services.
If you believe that one of your contacts has provided us with your Personal Information and you would like to request that it be removed from our database, please contact us at firstname.lastname@example.org
13. Children’s Privacy
This Site is not designed nor intended to be attractive to use by children under the age of 13. We do not knowingly collect information from children under the age of 13. If you are under 13 please do not submit any information to us.
14. Contact Us