Privacy Policy

What does this Policy cover?

This Policy tells you how we collect and use your personal data (also known as personal information). It also informs you about how we keep your data safe and the choices you may have, so please make sure you read it.

We want this Policy to be easy to read. In some sections, you can click to get more detail about what we do. Please note, all parts of this Policy apply to all the things we do. We may give further notices for some Services and places, and these should be read in conjunction with this Policy.

Our Services may contain links to other sites. We do not control these sites and we encourage you to read their privacy notices.

Our Services should not be used by individuals who are less than 16 years old.

What data do we collect, use, and share? (summary)

This section constitutes our notice at collection pursuant to the CCPA. During at least the past 12 months, we have disclosed personal data for the following business or commercial purposes:

Categories of Personal Information:

Personal Identifiers, such as your name, alias, postal address, email address, telephone number, online Protocol address, account name, education, employment, credit or debit card number, any financial information as well as information considered sensitive such as social security number, account log-in, and any information on your government identification cards.

Protected Classification Characteristics, such as your age, race, ancestry, national origin, citizenship, marital status, and sex, all of which are considered sensitive personal information.

Commercial Information, such as products or services you purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Internet or Network Activity Information, such as your browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement.

Geolocation Information, are data that is derived from your device by using satellite or cell phone tower signals to locate you within a geographic area. Precise geolocation data is equal to or less than the area of a circle with a radius of 1,850 feet and is considered sensitive personal information.

Audio or Visual Information, such as audio or screen records (with your permission).

Inferences, drawn from the data above which could create a profile reflecting your preferences, characteristics, create a profile reflecting your preferences, characteristics, predispositions, behavior, abilities, and aptitudes.

Purpose for Collecting Personal Information(depending on the nature of your interactions with us)

Providing our Services and carrying out your requests.

When providing our Services we may use your data (as applicable):

• To register and secure your account.
• To receive and respond to calls and messages from you.
• To check your identity and eligibility for our Services.
• To help you get the best pricing and products we have.
• To direct you to the websites of our partners.
• To process transactions between you and us, or our partners.
• To personalize the Service you get.
• To keep your data up to date.
• To provide customer service and support.
• To complete data rights requests you have made.
• To enable you to use social sharing tools.
• To track sales and get paid by our partners.
• To allow you to use our Services on one device and pick up seamlessly where you left off on another device.

 

Improving and promoting our Services and those of others.

To help improve and promote our Services, and the Services of our partners, we may use your data:

• To carry out analysis and market research.
• To help present our Services clearly and in the most effective way.
• To run sweepstakes and surveys.
• To help us and our partners create better products for you.
• To process any rewards we may offer to you.
• To send updates and Service messages about your products and services.
• To let you know about our services and promotions by email, social media (e.g., Facebook), and using push notifications (where you agree).
• qTo build, train, and augment models which help us understand your likely interests and those of other consumers.
• To target advertising to you, on this and other websites, based on data we have collected or created.
• To provide location-based offers based on your device’s physical location (where you agree).
• To help us understand if and how our and others marketing works.

Please note:We do not use profiling in a way that could have legal or similar effects.

 

Operating our business.

In the course of running our business we may use your data:

• To conduct tasks necessary for running our Services and business.
• To help secure our business and prevent fraud.
• To create reports for internal or external purposes.
• To comply with legitimate legal requests.
• To audit our business and processes.
• To protect the interests of our business, and those of our partners.

For other purposes not described in this Privacy Policy that you consent to (from time to time) and as otherwise permitted by law.

Other disclosures: We may share your personal data with your consent or to comply with laws or other legal processes.

Sale of Personal Data: We do not sell, rent, or loan your personal data to third parties for money. However, subject to your privacy choices, we may share your data (Identifiers, Internet or Network Activity Data, and Geo-location Information sections of the above chart) to social media platforms, analytics providers, and advertising companies, and this may be treated as a “sale” under certain laws. See the How Can You Control Your Data section of this Policy for more detail on your privacy choices.

Data Retention: We keep your data for as long as we need to in order to provide you Services and to comply with our business and legal obligations. To work out how long we need to keep your data, we consider the amount of data, the type of data, the risks that unintended use or disclosure could bring, and whether we can do what we need to by using less data, and other legal reasons. When we no longer need your data for our stated purposes, we securely delete it.

Collection of Data from Children: We recognize the importance of protecting the privacy and safety of children. Our Services are not directed towards children. We do not knowingly collect data about children under the age of 16 or minors otherwise defined in local law or regulation without verifiable parental consent. If we learn that someone under 16 has given us their data, we will use reasonable efforts to remove that data from our databases.

What data do we collect?

When you use our Services, we collect and use data.

We collect this data in four main ways:

1. You give us data when using our Services (such as your name or email).
2. Data is collected automatically as you use our Services (such as your IP address).
3. We obtain data from other parties to help run our Services.
4. We use or combine the data we get to infer things about you (such as, what appears to interest you).

We collect the data needed for our legitimate purposes.

See below for more detail.

To provide our Services to you, we use data. Some of this data is personal data. That means it relates to someone we may be able to identify. We collect some of this data from you and others, and some of it we create.

Some personal data is sensitive, this includes data about race, politics, religion and beliefs, health, as well as SSN. Generally, we do not collect sensitive data but it may be necessary to use some of our Services. Where this is the case, you have a choice to provide the data (and use the Services) or not.

Data you provide to us

To use some of our Services, you need to share some of your data with us, using online forms or other means. What data we need will depend on the Service you wish to use, but it may include the following:

• Name or username
• Email
• Postal address
• Billing address

• Phone number
• Payment card
• Car make and model
• Education

Sometimes, the data we need to offer our Services is sensitive, such as:

• Military service
• National identifier, such as SSN
• Credit history
• Income and account balances

You may choose to share other data with us, such as your status, images, comments, interests, likes and dislikes, and survey answers. When giving us feedback or asking for help, you may provide us with the data you think is needed so that we can respond.

Having obtained any consent that may be needed, you may also share the data of others with us (for example, if you refer a friend to receive one of our email newsletters).

Data collected automatically

When you use our Services, we and our business partners may collect some data automatically.

The data we collect will depend on the Service you use, but it may include:

• ISP
• Source (how you got to our site)
• Clicks, page views, and other actions
• Visit length
• Cookie and other IDs

• IP address
• Device and browser data
• Replays of your sessions
• Emails you have opened

With your consent, we may also collect more precise location data.

Data we get from other sources

Depending on the Service you are using, we may obtain data from other parties. The data we get will depend on the Service you use, but it may include:

• Name
• Email
• Address
• Phone number
• Business
• Role
• Age
• Gender

• Family size
• Education
• Likely interests
• Purchases
• Off site actions (e.g., banner ads clicked)
• Public data (e.g., online posts)
• Credit reports

We may also ask for your consent to obtain data about you from other sources (e.g., financial service providers)

Data we create

We may use or combine any data we get to create new data. The data we create about you will depend on your use of our Services, but it may include:

• Approximate location
• Inferences about your interests and preferences
• Interest cohorts
• Linked devices

Please note: We do not use the data we collect to infer sensitive data about you.

Anonymous data

We may combine your data with the data of others (e.g., count of the total number of website users per day). This data we create by doing this cannot be used to single you out, it is not considered to be personal, and we do not try to re-identify you from this data.

 

How do we use your data?

We use your data to serve you and operate our business.

Depending on the Services you use and the choices you make, we will use your data to:

• Provide our Services and carry out your requests.
• Improve and promote the Services of us and others.
• Operate and secure our business.

See below for more detail.

Providing our Service and carrying out your requests.

When providing our Services we may use your data (as applicable):

• To register and secure your account.
• To receive and respond to calls and messages from you.
• To check your identity and eligibility for our Services.
• To help you get the best pricing and products we have.
• To direct you to the websites of our partners.
• To process transactions between you and us, or our partners.
• To personalize the Service you get.
• To keep your data updated with the best information we have.
• To provide customer service and support.
• To complete data rights requests you have made.
• To enable you to use social sharing tools.
• To track sales and get paid by our partners.

Improving and promoting the Services of us and others.

To help improve and promote our Services, and the Services of our partners, we may use your data:

• To carry out analysis and market research.
• To help present our Services clearly and in the most effective way.
• To run sweepstakes and surveys.
• To help us and our partners create better products for you.
• To process any rewards we may offer to you.
• To send updates and Service messages about your products and services.
• To let you know about our services and promotions by email, social media (e.g., Facebook), and using push notifications (where you agree).
• To build, train, and augment models which help us understand your likely interests and those of other consumers.
• To target advertising to you, on this and other websites, based on data we have collected or created.
• To help us understand if and how our and others marketing works.

Please note: We do not use profiling in a way that could have legal or similar effects.

Operating our business.

In the course of running our business we may use your data:

• To conduct tasks necessary for running our Services and business.
• To help secure our business and prevent fraud.
• To create reports for internal or external purposes.
• To comply with legitimate legal requests.
• To audit our business and processes.
• To protect the interests of our business, and those of our partners.

For other purposes not described in this Privacy Policy that you consent to (from time to time) and as otherwise permitted by law.

How do we use cookies?

Cookies are small text files and are widely used when you visit websites. We use cookies and other similar tools on our websites. They help us to see returning visitors, store data for later use, and target our advertising.

You can adjust the settings in your browser to stop the use of cookies, but some of our Services may not work if you do so. To learn more about the cookies we use and why we use them, please read our Cookie Policy.

When do we share data with others?

To offer our Services and run our business, we must share some data.

We may share data with third parties to provide our Services. For example, with the partners whose products you have selected.

We may share data with third parties whose services we use to run our business. For example, we pay for a third party to host our databases for us.

We may share data with third parties to comply with the law and defend our interests, and those of our partners. For example, we share data with lawyers, external advisors, and other professionals.

See below for more detail.

Buying and selling assets: Sometimes we may need to share your data with a party that wants to buy our company or an asset that we own, or when we buy the assets of others. Before we do this we will make sure we appropriately safeguard your data.

Client businesses: When we collect data on behalf of our clients, we will share your data with them.

Service Providers: We may share your data with parties whose services we use to run our business. Where we use these third party services, our providers are not allowed to use our data for their own purposes.

Partner Promotions: We may offer contests, sweepstakes, or other events with third party partners. If you enter one of these, your data will be shared with the third party. Please note that they will have their own rules for using your data and you should read their policies.

Audience Measurement: We may share your data with companies who help us to learn about who is using our Services, and how they are used.

Watching videos: With appropriate consent, we might share data about what videos you watch with other companies, like advertisers or social media sites, but only if it’s allowed by the law.

Ads and marketing: With your permission (as needed), we might share data with companies that show ads, like Google, Live Ramp, The Trade Desk, and Facebook. This helps us to show you ads that match your interests. We also help other people advertise their products, so you might see their messages on our sites or other places online.

Legal requirement: We may share your data with others, if we believe the law says we have to do it, or if the government asks for it. We also need to protect our rights and the rights of our clients, so we might also share your data to get advice from lawyers and experts.

Emergencies: If we believe someone is in danger, we reserve the right to share data to help protect them.

Other people and messages: When you agree, some Services might share your data with other companies that want to send you messages about their services. They might contact you by email, phone, mail, or other ways. Please note that they have their own privacy rules too.

Anonymous data: We create and share general data about our consumers – you cannot be singled out within this data.

Please note: we only share sensitive data when providing you with Services and for other purposes permitted by law.

Social features

Some of our Services let you use “Social Features” that are offered by third parties. For example, you may be able to ‘like’ or ‘share’ things on Facebook / Instagram, Google / YouTube, Linked In, Snapchat, Tik Tok, and Twitter. To use these features you may need to have an account with the provider, and you should make sure you understand their privacy practices.

If you choose to use Social Features on our Services or access our Services from Social Features, both we and the provider may have access to data about your use. If you are logged in to a provider’s services, they may be able to connect your visit with other personal data they hold about you. We (and others) may use this data to place ads based on your interests on these providers’ services. In addition, we may ask you if we can access and collect data from your accounts, and post content to your contacts for you.

When you link a Social Feature provider with an account for one of our Services, you grant us access to certain data about you to provide content and services. This access is governed by the privacy policy and choices you make with that provider.

Why we can use your data

To collect and use your data, we must have a valid reason.

These reasons vary based on what we are doing but they will normally be because:

• you have given us your consent to use your data.
• we need fulfill a contract we have with you or take steps towards forming a contract,
• it is our legal duty to use your data in certain ways, or
• using your data for certain reasons is legitimate.

See below for more detail.

We need to have good reasons to collect and use your data. Our key reasons are:

Contract: We use your data when we have an agreement with you, or when we need to do things before making an agreement.

Consent: You give us your consent to use your data in certain ways (you can change your mind later if you want).

Legal requirement: We (or another company) must use your data to follow the laws or regulations to which we are subject.

Other legitimate purposes: We have good reasons to use your data to better serve you, to help us make our services better, or to keep our business running well. Some examples include:

• Sharing data with our partners as part of our Services.
• Sharing data with partners who help us offer rewards and benefits.
• Sending you emails of your results when you use our Services.
• Getting in touch to let you know about our Services, and changes to them.
• Doing research to learn more about what people like (or don’t like) about our Services.
• Checking and improving our processes to make sure everything is done right.
• Keeping our services safe and available online.
• Stopping fraud to protect you and others.

Sometimes, we might use your data if we think it will help protect an individual (either you or another consumer)

How long do we keep your data?

We keep your data for as long as it is needed to provide you with our Services.

To determine how long we need to keep your data, we consider:

• the amount of data,
• the type of data,
• the risks that unintended use or disclosure could bring, and
• whether we can do what we need to by using less data.

In addition, we may also keep and use your data for as long as it is needed for legal or contractual reasons, dispute resolution, fraud prevention, and security.

See below for more detail.

We keep your data for as long as we need it to offer our Services to you, and for other valid business reasons, such as:

• Financial record-keeping
• Complying with the law or other regulatory requirements
• Ensuring the security and availability of our Services

When we decide how long to keep your data, we think about how much we have, what kind of data it is, the risks that unintended use or disclosure could bring, and what the law says. This means we may keep some of your data for longer than we hold other data. Of course, you have choices too – you may request that we delete or correct your data.

At any time, we may make your data anonymous, which means it can’t be linked with you.

When we no longer need to keep data for our purposes, or when we get a valid request to delete, we begin a process to safely delete the data from our systems.

How do we keep your data safe?

We take the protection of your data very seriously.

We use best practices to help keep your data safe. However, there is always some risk when storing data or sending it over the internet. As such, we cannot guarantee the security of your data, and you should know that sharing it is done at your own risk.

We work hard to keep your data safe and secure. We use tools and techniques to monitor and protect the data we collect and use about you. We also have rules in place to make sure that your data can only be used by those who have valid business reasons, such as providing our Services to you.

While we work hard to protect your data, it’s important to know that no method of sending data online or storing it is perfect. Sometimes things can happen beyond our control. If we ever need to tell you about a problem with your data, we will let you know as best we can using messages, letters, or phone calls.

If you create an account on our websites, you may need to create a password. It’s really important to keep this password to yourself and not share it with anyone. You are responsible for making sure nobody else can access your account using your password or device. If you ever think someone else might be using your account, please tell us right away so we can help.

How can you control your data?

You can make certain choices about the way we collect, use, store, and share your data.

Sometimes these choices apply to everyone who uses a Service (for example, anyone who gets a newsletter from us can opt-out of future emails); other times these choices only apply to those covered by a certain privacy law.

We manage all of the requests raised to us as the law requires. This means there may be legal reasons why we cannot complete all requests.

Please note: we may need proof of your identity before we can start your request.

To make these choices you should use the links to the forms below to submit a request.

See below for more detail.

Your data choices

You have choices about your data and how we communicate with you, using our online form here

• Access to your data: You can request access to the data we have about you, and we will honor valid requests.
• Changes to your data: It’s important to keep your data accurate and up to date. If you need to update your data, please let us know. Sometimes, we have to keep data for legal reasons, but we will try to update it.
• Deleting your data: You can request that we delete the data we have about you. Sometimes we have to keep your data for specific reasons, like following the law or resolving problems, but we’ll delete what we must.
• Objecting to certain uses: If there’s something you don’t like about how we use your data, please tell us. We’ll listen and see if we can make changes. For example, you can opt-out of targeted advertising by using our cookie controls, and if you’re in California, you can tell us Do Not Sell or Share My Personal Information with other companies.
• Withdrawing your consent: If you change your mind and want to withdraw your consent for things you previously agreed to, you can tell us. Just remember that, if you do that, we might not be able to provide some Services to you.

If you choose to submit a request to us, it may limit your ability to use some of our Services (e.g., if we have deleted the data used to provide the Service), but we will not alter how we provide our Services to you.

To protect your data, we need to make sure it’s really you making these requests. So, we often ask for some information to verify your identity. Once you submit a request to us, we will email you with a link to our identity verification service.

If you want to make any of these choices but prefer not to use our online form, you can contact us by email, using the details below.

We recognize the Global Privacy Control preference signals so you can make your own privacy choices.

Authorized agents: If someone else, like the parent or guardian of individuals aged 16 to 18, needs to make these choices for you, they can do it too. They just need to follow the same steps we mentioned.

If you submit a request and we can’t honor it, we’ll tell you why. We will also make an appeal form available to you, if you are not satisfied with our decision.

Communication preferences

You can also choose how we communicate with you. Here are your options:

• Promotional Emails: If you don’t want to receive emails with special offers or surveys, you can unsubscribe by following the instructions in the emails. But don’t worry, we may still send you important messages about our Services.
• Promotional Mailings: If you don’t want to receive physical mail from us, like offers or catalogs, just let us know. Send us an email with “NO SNAIL MAIL” in the subject line, along with your name, address, and zip code. Even if you ask us to stop, you might still get some mailings that were already on their way before we removed your name.
• Text Messages and Push Notifications: If you receive text messages with promotions from us, you can opt-out by replying with “STOP” or “UNSUBSCRIBE.” You can also control push notifications on your device.

Please note: We may still need to communicate with you for transactional or Service reasons. For example, sending a password reset email or updates to our terms.

Contact Us
If you have any questions or concerns about our Privacy Policy, please contact us at: