Supplemental California Privacy Notice
Effective from January 1, 2023
- From employees or job applicants in their capacity as employees or job applicants; 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 to Which We Disclose Personal Information for Business Purposes||Categories of Third Parties to Which We Sell or Share Personal Information|
|Identifiers (such as name, address, email, phone number, retailer loyalty ID number, online identifier, mobile advertising ID, payment account information, or tokenized payment cards)|
|Retailer Online Account Credentials||N/A (we do not sell/share)|
|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., from your device or inferred from your IP address or web beacon)|
|Financial Information (e.g. PayPal account information or other payment related information needed to transfer funds to you)|
|Professional Information (e.g., from representatives of our business partners and vendors that we collect in the course of our business relationship)|
|Contact Information collected from the “Contact Us” form on our websites or mobile app|
|Sensitive Personal Information, as that term is defined by the CCPA (See below for details on Sensitive Personal Information collected)|
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 Purposes for Our Use of Your Information
With the exception of financial information, retailer online account credentials, professional 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, processing rebate and coupon redemptions or 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
C. Opt Out of Sale or Sharing of Personal Information
D. Limit Use of Sensitive Personal Information
Quotient uses certain categories of information deemed to be “sensitive personal information” under the CCPA. Specifically, we collect the following sensitive personal information:
Account Login Information
Financial Account Login Information, e.g. PayPal®
Precise geolocation data
We collect this information to better tailor the services and advertisements/offers to you. The CCPA allows you to request that we limit our use of your sensitive personal information to only those uses needed to provide the Services or to comply with applicable law. If you would like to request that we limit use of your sensitive personal information, please fill out the form available here.
E. California Residents’ Information Rights
In addition to the opt-out right and limit use of sensitive personal information rights described above, California residents have the right under the CCPA to request (subject to certain limitations) 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.
- Correct inaccurate personal information we have about you.
Note that some information we hold about you may be associated with a device identifier only. In response to requests to access certain information that we hold about you that are only associated with a device identifier, we cannot provide such information because we are unable to adequately verify that the person who has submitted the request is the actual owner of the device associated with a given data set. Because this data is not associated with other personal information such as name, address, email address with this data that is associated with a specific device identifier only, we do not have methods to adequately verify the identity of an actual device owner.
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, correction, or sale/sharing 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. Asking us to delete your information may impact your ability to use our services, including closure of your user account and you may no longer be able to access or use all or parts of the Services.
If you would like to exercise any of these CCPA rights, please visit our privacy portal or you may send an email to [email protected]. If you submit your request by email, please include “CCPA REQUEST” in the email subject line and include, in the body of the email, your name (First and Last), email address, state and zip code of residence, and a description of the CCPA rights you wish to exercise.
Additionally, you may submit a request to delete or a request for information by calling 1-888-914-9661. When prompted for your PIN, enter 741594, which will take you to the Quotient Technology privacy line. Please listen carefully and follow the instructions. When prompted to provide your name and email address, please speak clearly and spell out your name and email address. When you have finished providing the information requested, you must press “#” to submit your request. If you do not press “#” to end your recording, your request will not be submitted. Note, when submitting your requests by phone, a separate call is required for each request you are exercising (e.g. one request to submit a request to know and another request to submit a request to delete). If we are not able to understand the information you have provided, we may call you on the number you used to call the toll-free number, if it is available, in order to confirm your information.
After submitting your request(s), we are required to verify your request(s) to ensure it is not fraudulent. To verify your request, we will contact you via the email address you provided with, or to submit, your request. Further, we may require you to confirm ownership of the email address associated with your request or provide additional information necessary to verify the validity of your request. For example, we may ask for you to provide additional information to determine if it matches information we have. Please be sure to check your SPAM/junk folder in case the email is filtered out by your mail system. If you do not receive an email from us regarding your request(s) within 48 hours, your request or contact information may not have been submitted properly, and you will need to submit a new request.
You may also designate an authorized agent to make a request on your behalf. To do so, you must provide us with a copy of 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.
F. Data Retention
We retain your information for as long as is necessary to provide the Services or for other necessary purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. In determining how long to retain information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the information, applicable legal requirements, and our legitimate interests. The purposes for which we process information (as well as the other factors listed above) may dictate different retention periods for the same types of information. If you opt out of email marketing, we maintain your email on our suppression list for an extended time to comply with your request. We may delete or de-identify your information sooner if we receive a verifiable deletion request, subject to exemptions under applicable law. We may retain cached or archived copies of your information.
G. CCPA Request Metrics
For metrics related to CCPA requests received during the previous year, please go here.