Supplemental California Privacy Notice
Effective from January 1, 2020.
- From employees or job applicants in their capacity as employees or job applicants;
- Personal information we collect from employees, owners, directors, officers, or contractors of businesses in the course of our provision or receipt of business-related services; and
A. Categories of Personal Information that We Collect and Share
|Categories of Personal Information We Collect||Categories of Sources of Personal Information||Categories of Third Parties that We Share Personal Information With|
|Identifiers (such as name, address, email, phone number, retailer loyalty ID number, online identifier, tokenized payment cards)|
|Commercial Information (such as transaction data)|
|Internet or Other Network or Device Activity (such as browsing history, interactions with our Services, search history, interaction with advertisements|
|Demographic Information (such as state of residence, household income range, education level, occupation, and certain legally protected characteristics such as gender, age, ethnicity, and military service)|
|Location Information (e.g., through Foursquare or inferred from your IP address or web beacon)|
Please note that we may also disclose all personal information to (a) comply with federal, state, or local laws; (b) comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (c) cooperate with law enforcement agencies concerning conduct or activity that we believe may violate federal, state, or local law, (d) when we sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction), or (e) to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
B. Categories of Business/Commercial Purposes for Our Use of Your Information
With the exception of financial information, location information and certain mobile phone numbers (as described further below), all of the categories of personal information we collect about you (as detailed above) are used for the following purposes:
- Providing our Services (for example, delivering targeted offers or promotions to you)
- For our operational purposes
- Improving our existing Services and developing new products and services
- Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity
- Bug detection, error reporting, and activities to maintain the quality or safety of our Services
- Auditing consumer interactions (for example, measuring ad impressions, coupon activity)
- Short-term, transient use, such as customizing content that we or our service providers display on the Services
- Providing services for, and products to, our business customers and partners (such as brands and retailers), including advertising, marketing, measurement and analytics services on our Services and elsewhere
- Advertising, marketing, measurement and analytics, on our Services and elsewhere
- Other uses that advance our commercial or economic interests, such as third-party advertising and communications about relevant promotions or offers from third parties
- Other uses that we notify you about
Mobile phone numbers given to us in order to print or install our coupon printing software are used only for verification, security, fraud, identity and audit purposes. Financial information is used only for payment of rewards or rebates, and location information is used only to personalize your experience on our Services.
C. California Residents’ Privacy Rights
Subject to certain restrictions, California residents have the right under the CCPA to request that we:
- Provide you the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information.
- Provide access to and/or a copy of certain information we hold about you.
- Delete certain information we have about you.
- Honor your opt-out of the “sale” of your information.
You may have the right to receive information about the financial incentives that we offer to you (if any). You also have the right to not be discriminated against (as provided for in applicable law) for exercising your access, deletion, or sale opt-out rights. We will not discriminate against you for exercising your rights. Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the Services to you, for financial auditing purposes, and for compliance with applicable law. If you ask us to delete certain information, you may no longer be able to access or use the Services.
The CCPA defines “sale” and “personal information” very broadly. Certain uses of your data described above may constitute a sale under the CCPA, as we currently understand it. If you would like to opt out of our use of your information for purposes that are considered a “sale” under California law, you may do so here. If you want us to delete tracking cookies that enable targeted advertising, which allow us to provide promotions and offers relevant to you, you may do so here. If you clear your cookies after you asked us to delete tracking cookies, we will not be able to know that you made this request so you will need to opt-out again. You can also submit a sale opt-out request by emailing us at [email protected] and include “CCPA REQUEST” in the email subject line. Please note that we do not knowingly sell the personal information of minors under 16 years of age without legally-required affirmative authorization.
If you would like to exercise any of these CCPA rights, please visit our privacy portal or contact us at [email protected] and include “CCPA REQUEST” in the email subject line. You will be required to verify your identify before we fulfill your request. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.