Effective date: January 1, 2019
We may communicate with you if you have provided us the means to do so. For example, if you have given us your e-mail address, we may send you promotional e-mail offers on behalf of our business or other businesses, or e-mail you about your use of the Services. We may also deliver Instruments via other communication methods, including text messages. Subject to the terms of the TruCentive SMS Terms and Conditions (https://trucentive.com/sms_terms_and_conditions), TruCentive may send marketing messages on its own behalf or behalf of other businesses via text message, as well as non-marketing messages via text, for example, to deliver Instruments and messages regarding your use of such Instruments. For additional information about TruCentive’s sending of text messages, and about how you may opt in to receive marketing text messages from our licensees or Merchants in connection with the Services, please see the SMS Terms and Conditions.
Also, we may receive a confirmation when you open an e-mail or receive a text message from us. This confirmation helps us make our communications with you more interesting and improve our services. If you do not want to receive communications from us via e-mail, please indicate your preference by contacting us at firstname.lastname@example.org or by clicking “unsubscribe” at the bottom of any e-mail. If you do not want to receive any further marketing communications from TruCentive or our licensees or Merchants via text message, please follow the directions for opting out within the TruCentive or licensee/Merchant text message, as further described in our SMS Terms and Conditions. You may also respond “STOP” to a non-marketing text message sent by TruCentive, our licensees or Merchants in order to stop receiving such messages.
5. Sharing of Information that has been de-identified. We may de-identify your Personal Information so that you are not identified as an individual and provide that information to our partners. We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services as well as our partner’s services, so that they, too, can provide you with optimal online and in-person experiences. However, we never disclose aggregate usage or de-identified information to a partner in a manner that would identify you as an individual person.
6. Sharing of Information with our Advertisers, Merchant Partners and Licensees. We may allow advertisers and/or merchant partners and licensees (“Advertisers”) to choose the demographic information of users who will see their advertisements and/or promotional offers, and you agree that we may provide any of the information we have collected from you in personally identifiable form to our licensees and to other Advertisers in non-personally identifiable form to an Advertiser, in order for that Advertiser to select the appropriate audience for those advertisements and/or offers. For example, we might use the fact you are located in San Francisco to show you ads or offers for San Francisco businesses, but we will not tell such businesses, other than a licensee on whose behalf we first contacted you, who you are. Or, we might allow Advertisers to display their ads to users with similar usage patterns to yours, but we will not disclose usage information to Advertisers (other than those licensees) except in aggregate form, and not in a manner that would identify you personally. Note that if an advertiser asks us to show an ad to a certain audience or audience segment and you respond to that ad, the advertiser may conclude that you fit the description of the audience they were trying to reach.
We may provide certain Personal Information to our licensees and/or Merchants in connection with redemption of our Instruments and to otherwise allow the Licensees or Merchants to contact you regarding their service offerings, including offering promotions to you. By using the Services, you consent to our sharing such information with our Licensees and Merchants.
We may deliver a file known as a “web beacon” from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Because your web browser must request these advertisements and web beacons from the ad network’s servers, these companies can view, edit, or set their own cookies, just as if you had requested a web page from their site. You may be able to opt out of web beacon tracking conducted by third parties through our Services by adjusting the Do Not Track settings on your browser; please note that we don’t control whether or how these third parties comply with Do Not Track requests.
9. User Profiles and Submissions. Certain user profile information, including the user’s name, location, e-mail address and picture that such user has uploaded to the Services, may be displayed to other users to facilitate user interaction within the Services or address the user’s request for our services.
10. Transfers of our Business. In the event TruCentive is involved in a merger, acquisition or sale of all or a portion of its assets, we may share and/or transfer Personal Information in connection with such transaction. Also, if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third-party.
12. Security of your Personal Information. Your account is protected by a password for your privacy and security. If you access your account via a third-party site or service, you may have additional or different sign-on protections via that third-party site or service. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account. We endeavor to protect the privacy of your account and other Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.
Many browsers provide you an option to request that a web application disable either its tracking and/or cross site user tracking of an individual user. We do not track your online activities across different sites, and we only track your activity within a site to the extent you log into your account. Therefore, our practices remain the same whether or not you do not enable the “Do Not Track” feature. As noted above, however, third parties may not honor “Do Not Track” requests you have set using your browser or device, and we cannot control the actions of those third parties.
13. Accessing and Editing your Personal Information. You may access, and, in some cases, edit or delete the following information you’ve provided to us: name and password; e-mail address; billing and payment details; phone number; location; and social media account information. The information you can view, update, and delete may change as the Services change. When you update information, we may maintain a copy of the unrevised information in our records. Some information may remain in our records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. If you have any questions about viewing or updating information we have on file about you, please contact us at email@example.com.
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information that we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to: firstname.lastname@example.org.
14. Retention Period of your Personal Information. We will retain your information for as long as your account is active or as needed to provide you Services and up to a period of no longer than seven years thereafter. If you delete your account, to the extent permitted by applicable law, we may retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records and enforce our agreements.