Effective Date: 4/19/2016
Personally-Identifiable Information (PII)
The Company may collect PII, including, but not limited to, your name, e-mail address, and telephone number during the registration process and during the redemption of awards.
Non-personally-identifiable Information (Non-PII)
The Company will collect non-PII from your survey answers and the information you provide to Organizations with regard to feedback and assistance.
The Company may also use analytic and reporting technologies to collect anonymous information from you about your patterns of use or other statistical patterns. Examples of this anonymous information are: your device’s operating system, date/time of access to the Software, geographic information, and device type. This is not an exhaustive list of the types of Non-PII we may collect; it merely provides examples of the kinds of data we may collect.
Method of Collection
(a) Collection of PII
The Company collects your information, including PII, when you create an account with us or redeem points.
If you choose to log into the Software with a social media service, such as Facebook, we may collect information about you or your connections from that site or app.
The Company may also collect PII as a result of your answering survey questions and providing feedback or asking for assistance from Organizations. To prevent the collection of PII in this manner, you may mark your conversations with a “Don’t share my identity” status (“Anonymous”.) Anonymous conversations still allow for two-way communication between you and the Organizations but contain only Non-PII.
Some Organizations such as health care, financial, or legal providers may request PII including, but not limited to, your name, date of birth, and social security number, to verify your identity before providing services via the Software. Any such request is purely optional. If you choose to share this PII, the information is restricted to the specific Organization to which you provided it. We will not share this Organization-specific information with other Organizations or other users of the Software.
(b) Collection of Non-PII
The Company will collect Non-PII as a result of your answering survey questions and providing feedback or asking for assistance from Organizations.
The Company may collect passive non-PII by using various analytic and reporting technologies (such as cookies, web beacons, web storage, and unique device identifiers). This collection of non-PII may be done passively (i.e., without your affirmative consent) while you are using our Software. The Company shall not use any of these passive analytic and reporting technologies to collect PII.
Storage of Your Information
The Company stores the information it collects in servers owned by a reputable cloud provider located only in the United States. Your use of our Software acts as your consent to transfer your PII outside of your country of residence if such servers reside outside of your country of residence.
Use of Your PII
The Company does not sell, rent, or share your PII.
Use of Your Non-PII
You have consented to the Company’s use of your non-PII by your use and download of our Software. The Company reserves the right to make full use of your non-PII. The Company’s use of your non-PII may include, but is not limited to, the following:
(a) The Company may share your non-PII with the Organizations with which you have chosen to engage.
(b) The Company may use your non-PII for the purposes of demographics and analytics. The Company may use your non-PII for the purpose of analyzing traffic to our Software. This use may include those to provide better service to users of our Software, to customize our Software based on your preferences, and to compile and analyze statistics about our Software.
(c) The Company may use your non-PII to analyze trends and statistics on our Software.
(d) The Company may use your non-PII to assist the Company in our operation, evaluation, and improvement of our Software or our services in general.
(e) The Company may use your non-PII if necessary for compliance with applicable legal requirements, industry standards, or Company policies.
Electronic Communications Privacy Act
The Company abides by the Electronic Communications Privacy Act of 1986, 18 U.S.C. §§ 2701-2711 (“ECPA”). All e-mail messages, text messages, and other electronic communications sent through our Software are only viewable to those to whom they are sent and are considered as confidential and private except as required by law, including without limitation, the ECPA. Our Software is not considered a “secured communications medium” under the ECPA. We have a limited ability to intercept and/or disclose electronic messages. Some of the situations under which we are allowed to intercept and disclose electronic messages is when we receive a court order, subpoena, warrant, or other legal demand and when we receive information that appears to be related to a criminal act.
Protection of PII
The Company uses reasonable practices and technologies to safeguard your information against illegal intrusion and unauthorized access. No security measures are 100% reliable, however. Therefore, the Company cannot warrant the security of your PII.
The Company does not guarantee that your PII will never be compromised because no electronic transmission is completely secure. Even though the Company will employ every reasonable security measure to protect the privacy of your PII, the Company cannot guarantee that these security measures will be sufficient or that they will never fail or be circumvented.
YOU UNDERSTAND AND AGREE THAT YOU ARE USING OUR SOFTWARE AT YOUR OWN RISK. YOU ASSUME ALL RESPONSIBILITY AND RISK FOR YOUR USE OF OUR SOFTWARE AND UNDERSTAND THAT INFORMATION YOU SHARE THROUGH OUR SOFTWARE IS SHARED AT YOUR OWN RISK.
ACCESS TO PII
The Software will disclose your PII to your Organizations in non-Anonymous communications. However, the Software will only share your PII with those Organizations to which you have explicitly provided it (for example, for identity validation before they provide service to you via the Software).
(b) Service Providers
The Company may disclose your PII to service providers including, but not limited to, our IT personnel who maintain our Software. These trusted service providers will have access to your PII but may not use your PII for any purposes other than those to which they have been entrusted. The Company shall use reasonable efforts to ensure that these service providers hold your PII in confidence. In addition, the Company shall only disclose your PII to third parties that the Company believes in good faith follow acceptable privacy and security policies.
(c) Legal Enforcement
The Company may disclose your PII to investigate or enforce violations of our rights. The Company may also disclose your PII to protect the security of our Software. In addition, the Company reserves the right to disclose your PII if the Company has a good faith belief that this disclosure is necessary to satisfy a legal process or enforceable government request (such as a subpoena) or to be in compliance with any law or regulation.
The Company may transfer your PII as part of a sale, merger, acquisition, or any other change of control. In addition, the Company reserves the right to transfer your PII to protect the Company’s legal rights in the unlikely event of a bankruptcy, reorganization, receivership, assignment, or any application of creditors’ rights.
Policy with Regard to Children