Precision Marketing, LLC
Last Modified: January 1, 2020
By accessing and using one of our websites that we own and operate which offer rewards and/or other content (collectively, “Promotions”) to users (collectively, the “Websites” and individually, a “Website”), you understand and agree to our collection, use, disclosure and sale of your Information. If you do not understand and agree to how we collect and handle Information, please do not use or visit the Websites or participate in the Promotions. Please note if you are not a U.S. resident, you are not permitted to use the Websites, participate in the Promotions and/or otherwise access the other Precision Marketing offerings.
NOTICE OF COLLECTION OF PERSONAL INFORMATION
This Policy provides notice to users, including those who are California residents and fall within the definition of “consumers” as provided for in the California Consumer Privacy Act of 2018 (“CCPA”), that we collect Information. As required by the CCPA, the following sections of the Policy also details the categories and sources of Information collected and the business and commercial purposes for the collected Information. We also include a description of rights afforded to California consumers at “RIGHTS OF CALIFORNIA USERS WITH REGARD TO THEIR INFORMATION” including rights to know the Information we have collected and sold and the right to opt-out from the sale of Information and the right to deletion.
TYPES/CATEGORIES OF INFORMATION WE MAY COLLECT REGARDING USERS
Here are the types and categories of Information that we may collect regarding users (see below for additional descriptions of the categories of Information collected that are provided to California residents):
HOW WE COLLECT INFORMATION - SOURCES
Here are ways we collect Information from and about users (see below for additional descriptions of the methods of Information collection that are provided to California residents):
We also collect Information from our servers that host the Websites and combine that Information with Information on users that we have already collected via other means. Here are some sources of Information and the methods we use:
HOW WE MAY USE INFORMATION
We may use Information in many ways and for many purposes including the following (see below for additional descriptions of Information uses that are provided to California residents):
HOW WE MAY DISCLOSE AND/OR SELL INFORMATION
We may share and/or sell Information that we have about users in many ways and for many purposes, for which we may be compensated, including the following (see below for a description of the augmented rights that California residents have with respect to opting-out of the sale of their Information):
When we share and/or sell Information, we enter into agreements that describe the purpose for which the Information is shared/sold, restrict its use to the agreement’s specified purpose and require that all Information remain confidential, and be protected from unauthorized disclosure. I
SMS Alerts Program. If you provide your consent to receive SMS messages concerning your reward status, we do not sell or otherwise transfer your telephone number or other personal information as a consequence of this consent to third parties.
MINORS AND NON-US RESIDENTS
The Websites are designed to comply with the Children's Online Privacy Protection Act (“COPPA”). COPPA requires that website operators not knowingly collect PII from anyone under the age of 13 without prior verifiable parental consent. In compliance with COPPA, we do not knowingly collect or retain information from the Websites from children under the age of 13 and may only collect a limited amount of Information from users who are between the ages of 13 and 18. We do not sell the Information of users who are under eighteen (18) years of age.
The Websites are intended for use only by residents of the contiguous United States, Alaska and Hawaii.
COOKIES, INTEREST-BASED ADVERTISING AND THIRD-PARTY ANALYTICS
We may use Google Analytics and similar tools provided by our third-party partners to help analyze how users interact with the Website and to display customized ads and other content to our users during a current browsing session or in the future when the user is online. These analytics are performed by using the technological means described above to monitor a user’s interactions with the Website and do not involve the collection of any additional PII.
Most computers are initially set up to accept Cookies, but users can reset their Internet browsers to refuse all Cookies or to indicate when a Cookie is being sent. To disable and reject certain Cookies, follow the instructions associated with your Internet browser. Even where you reject a Cookie, you may still use the Website but your ability to use certain features or offerings may be impaired. For example, if you return to our Website, you may have to re-enter Information you previously supplied to us. We may retain Cookie data indefinitely.
Users may opt-out from interest-based advertising delivered to their web browser by companies who have elected to participate in one of the interest-based advertising opt-out mechanisms such as the Digital Adverting Alliance’s opt-out program located here or the National Advertising Institute’s opt-out program located here. Users may also choose to opt-out of interest-based advertising on their mobile devices. For more information, please click here.
Please note that opting out of interest-based advertising does not mean you will no longer see advertising online. Rather, it does mean that the company or companies from which you opt-out will no longer show ads that have been tailored to your interests.
OPTING-OUT FROM MARKETING
Users may opt-out from receiving future contact from us using the following methods:
In addition and as described below, residents of California (and, in certain circumstances, residents of Nevada) have the right to opt-out of the sale of their Information.
ACCESSING, CORRECTING AND DELETING YOUR INFORMATION
We ask individual users to identify themselves and the Information requested to be accessed, corrected or deleted (suppressed) before processing such requests and, to the extent permitted by applicable law, we may decline to process requests that we are unable to verify, are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or would be extremely impractical (for instance, requests concerning Information residing on archive servers).
Our surveys may ask health-related questions which we may share with our third-party marketing partners who advertise health-related products and services on our Websites, or who otherwise promote health-related products or services. We will use this health information - with your consent - to display offers for health-related products and services or to provide Information to these providers so they can contact you.
MEDICARE SUPPLEMENT PLANS DISCLOSURE
Some of our third-party advertisers offer Medicare Supplement plans. Medicare Supplement plans are not connected with or endorsed by the U.S. Government or the Federal Medicare program and all related offers on our Websites comply with applicable Federal civil rights laws and do not discriminate on the basis of race, color, national origin, age, disability, or sex.
SECURITY OF YOUR INFORMATION
We use commercially reasonable efforts to prevent unauthorized access or disclosure, or accidental loss or destruction of your Information. Access to your Information is strictly limited and we take reasonable measures to ensure that your Information is not accessible to the public. We restrict access to our users’ Information to only those persons who need access to perform or provide their job or service, both internally and with our third-party service providers.
We don’t generally collect sensitive Information such as medical information, driver’s license/ID card number, health insurance information, data collected from an automated license plate recognition system, Social Security Number and credit card information. If and when we do collect, store and transmit sensitive information, that Information will be encrypted with advanced TLS (Transport Layer Security).
Given the nature of the Internet, your Information passes through entities that we are unable to control. Therefore, we cannot guarantee that our security measures or those of third parties who access or transmit your Information will prevent your Information from being improperly accessed, stolen or altered. In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies if we learn of an information security breach of your Information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.
CALIFORNIA NOTICE REGARDING CATEGORIES, SOURCES AND BUSINESS AND COMMERCIAL USES OF INFORMATION
The following chart contains the categories of information, as enumerated in CCPA Sec. 1798.140(o), of Information we collect, use, disclose and sell, the sources of the Information and our business and commercial uses of such Information:
RIGHTS OF CALIFORNIA USERS WITH REGARD TO THEIR INFORMATION
California users have several rights regarding the collection, use, disclosure and sale of their information under the CCPA. One of these rights, notice of collection of Information, is described above; the balance of these rights are described below and include the following rights:
Exercising Your Rights, Verification and Timing. To exercise your CCPA rights, click on the “Do Not Sell My Personal Info” link on the bottom of the Website page where we collect Information,; or email us at [email protected] To prevent an unauthorized third party from accessing or making decisions regarding a user’s Information, we verify all requests to exercise these rights (a verifiable consumer request). We do not charge a fee to process or respond to a verifiable consumer request unless it is excessive, repetitive, unfounded or abusive.
In general, we will verify a request by matching the identifying information supplied by the user with the Information we already have for the user. If we cannot verify the user using the foregoing method, we may request additional information which we will not retain or use for any other purpose.
For all verifiable consumer requests, we strive to respond within forty-five (45) days of receipt. If we require additional time, which can be up to ninety (90) days in the aggregate, we will provide written notice. Any disclosures we provide will cover only the 12-month period preceding the verifiable consumer request's receipt and will be delivered electronically in a secure fashion. If, for some reason, we cannot fulfill or comply with your request, our response will explain that decision.
Disclosure of Information Collected and Sold. While users have the right to request different levels of disclosure regarding the collection, use, disclosure and sale of Information, we have elected to treat all requests from California residents as an exercise of expanded disclosure requests by businesses that sell Information. Once we receive and confirm your verifiable consumer request, we will disclose to you for the 12 months prior to your request:
Right to Opt-Out. Users have the right to opt-out from the sale of their Information. We provide a “Do Not Sell My Personal Info” link on each Website page where we collect Information that links to an online request form. You can access the form here or you can email us at [email protected] and elect to opt-out from the sale of your Information. We reserve the right to verify all opt-out requests using the methods described above.
While our agreements with third parties to whom we sell or disclose Information prohibit the further sale or use beyond the scope of our agreement with them, if a California user opts-out, we will notify all third parties to whom we have sold or disclosed the California user’s Information within the previous 90 days and remind them not to further sell the Information. We will not ask a California user who has opted out to re-opt-in for one year after the California user opts-out. If the user requests a transaction with us that requires the sale of their Information, we will inform them that they have opted out and if they want to proceed with the transaction, we will offer the opportunity to opt-in by completing a two-step process.
Deletion of Information. You have the right to request that we delete any of your Information that we collected from you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request using the process set forth above, we will delete or deidentify (and direct our service providers, vendors and other applicable third parties to delete) your Information from our system other than from our archive servers (which we maintain for compliance purposes), unless there is an applicable exception.
We may decline to process your deletion request if the Information is necessary for us or our service providers, vendors or other applicable third parties for a number of reasons. The following are some of the reasons we may decline your deletion request:
If we do not comply with a deletion request, we will provide the grounds for our denial.
Access and Portability. California users have the right to access the Information we have collected about them in the previous twelve (12) months. Upon receipt of verified consumer request, we will provide the information in a readily usable format. You cannot request access more than twice in any 12-month period.
Nondiscrimination. We are committed not to discriminate against California users who exercise their CCPA rights. As such, unless otherwise permitted by the CCPA, we will not deny, charge you different prices or rates, or provide a different quality level of goods or services, including through granting discounts or other benefits, or imposing penalties, and/or suggest that you may receive a different price, rate, or quality level of goods or services. While we do not provide financial incentives for users who do not exercise their CCPA rights, please note that some of the functionality of our Website may be unavailable if consumers exercise their rights to have their personal information deleted.
Authorized Agent. The CCPA enables California users to appoint an authorized agent to act on their behalf to submit disclosure requests and or deletion requests under the CCPA. The authorized agent must register with the California Secretary of State. We will honor a request from an authorized agent provided you provide written authorization to the authorized agent to act on your behalf and we can verify your identity and the agent submits proof of authorization.
CCPA Metrics. We are required to compile certain annual metrics regarding the CPPA including the number of disclosure, deletion and opt-out requests we receive, the median number of days it takes us to respond and how many of each were denied. We will provide this information starting in 2021 by posting a link in this Policy.
CALIFORNIA ONLINE PRIVACY PROTECTION ACT
Shine the Light Rights. In addition to the CCPA-mandated disclosures described above, the California Online Privacy Protect Act (“CalOPPA”) contains a Shine the Light section that permits users who are California residents to request information regarding our disclosure of their Information to third parties, including the categories of Information shared and a list of the names and addresses of third parties with whom the Information was shared. If you are a California resident and would like to exercise your rights under the Shine the Light provision, please submit a request by emailing us at [email protected] In your request, please specify that you want to exercise your rights to disclosure under the Shine the Light provision please specify the Website that you visited and the email address you registered with. Please allow thirty (30) days for a response.
Browser “Do Not Track” Signals. Most browsers contain a “do-not-track” setting. In general, when a “do-not-track” setting is active, the user’s browser notifies other websites that the user does not want their personal information and online behavior to be tracked and used, for example, for interest-based advertising. As required by CalOPPA, we are required to inform you that, as is the case with most websites, we do not honor or alter our behavior when a user to one of our Websites has activated the “do-not-track” setting on her/his browser.
NEVADA PRIVACY RIGHTS
Nevada State residents have the right to submit opt-out requests to website operators instructing those website operators not to sell any “covered information” that the website operators have collected about the Nevada State residents to any third party data broker(s). Covered information includes a consumer’s name, postal and email addresses, telephone number and Social Security Number, and includes the Information described above in the “TYPES/CATEGORIES OF INFORMATION WE MAY COLLECT REGARDING USERS” section. If you are a Nevada State resident and you wish to exercise your right to request that we to stop the sale of your Information to third party data brokers, please submit your request by clicking on the link “Do Not Sell My Personal Info” or emailing [email protected] with the subject line “Nevada Privacy Rights.” In your request, please specify that you want to exercise your rights to opt-out from the sale of covered information under the Nevada Privacy Law and specify the Website that you visited and the email address you registered with. Please allow thirty (30) days for a response.
CHANGES TO THIS POLICY
We reserve the right to revise and update this Policy at any time. If we make material changes to this Policy, we will post the updated Policy on our Website. Any such revisions will be effective thirty (30) days after posting to the Website and will apply to all Information collected by us both before and following the effective date. If we expand the way we use Information, we will notify users by: (a) sending the modified Policy to our users via email or (b) by any other reasonable means acceptable under applicable state and federal law. You will have a choice as to whether we use your Information in this different manner and we will only use your Information in this way where you opt-in to such use. Users should periodically access this Policy to review our current policies regarding the collection and use of Information.
QUESTIONS, SUGGESTIONS, OR TO CONTACT US
If you have any questions, comments, complaints, or suggestions regarding this Policy or our Website(s), please contact us here.