December 20, 2019.
THE INFORMATION WE COLLECT & HOW WE COLLECT IT
Personal Information, which will only be collected with your consent, may include your first and last name, email address, mailing address, telephone number, demographic information, and any other information that you provide to use that is linked to your identity. We will only collect Personal Information that is relevant to the Services and the maintenance of the Sites, which generally falls into these categories: (i) information you give us about you and/or your campaign; (ii) information you give us to process an online transaction from our Sites; (iii) information you give us to process a transaction in-store; (iv) information we collect when you use our Services; and (v) usage information we collect from other sources. In all instances, remember that you always have the option not to provide information to us by choosing not to use the Sites or Services or by not
(i) INFORMATION YOU GIVE US ABOUT YOU AND/OR YOUR CAMPAIGN
When you register or create an account for the Services, purchase offers through the Site, download and/or use our mobile application, contact our customer service or participate in our contests, promotions and surveys, we ask for your Personal Information. In addition to Personal Information, we might also collect details related to your fundraising campaign, cause information and buyers associated with your fundraiser.
(ii) INFORMATION YOU GIVE US TO PROCESS AN ONLINE TRANSACTION ON OUR SITES
(iii) INFORMATION YOU GIVE US TO PROCESS A TRANSACTION IN STORES
By registering a payment card in connection with transaction monitoring, you authorize us to share your payment information with our third-party service providers (including Swipe, Inc.) and payment card networks (e.g., Visa, MasterCard, American Express) (collectively, “Payment Card Networks”). You authorize Payment Card Networks to monitor transactions on your registered card(s) to identify your purchases in order to determine whether you have qualified for or earned an offer linked to your payment card, and for Payment Card Networks to share such transaction details with Swipe and for Swipe to share such transaction details with us to enable your card-linked offer(s) and target offers that may be of interest to you. You may opt-out of the Card Linking Program at any time by logging into your Genie Action account and clicking LINKED CREDIT CARDS with the MY ACCOUNT page and clicking “delete” next to the payment card. You must repeat this process for every card you wish to delete.
(iv) USAGE INFORMATION WE COLLECT WHEN YOU USE OUR SERVICES
We may collect non-personally identifiable information that relates to your Site usage or is necessary for the proper functioning of the Sites, such as the time and date and the extent of your usage of the Sites, the location of where you use the Sites, your usage preferences, how you interact with other users forums, bulletin boards, discussion groups, chat rooms or other methods of communication, your purchasing trends, the offers you view, purchase or redeem, which pages of the Site you visit and for how long, the mobile platform or service provider you use, your browser, your operating system, and your Internet Protocol (“IP”) address. We may also compile this data to enable statistical analysis of our services that would be used internally or with external assistance to make improvements to our Website. This usage information is not personally identifiable, though if we ever associate this type of information with you as a specific and identifiable person, we treat it as Personal Information.
If you purchase Offers as gifts for other people, we will collect certain information about the recipient, including their contact information, and create a record of the transaction.
If you use a social media platform or your mobile device (or other methods of communication) to interact with Genie Action or the Site(s), we may collect certain information made available to us by the social media platform or mobile carrier in accordance with their privacy policies, which you should review prior to use. For example, if you use the Genie Action mobile application and your mobile device’s settings allow it, we may collect mobile location information from your device. Our application may be designed to collect information even if you are not logged into the Genie Action application or the Site(s). If you have questions about the security and privacy settings of your mobile device, please refer to instructions from your mobile service provider or the manufacturer of your device to learn how to adjust your settings.
(v) INFORMATION WE COLLECT FROM OTHER SOURCES.
We may receive additional Personal Information from third parties, including social media platforms. We may use this Personal Information to enhance other information we have about you to help us better understand you and to otherwise enhance the Site(s) or Services.
HOW WE USE THE INFORMATION WE COLLECT
We may use the information we collect about you in a variety of ways, including:
- i. to identify you when you use our Services, and process your transactions;
- ii. to confirm a qualifying purchase or return to match transactions to confirm whether you qualify for a credit or an offer;
- iii. to communicate with you about orders, purchases, services, accounts, your campaign’s status and product features;
- iv. to administer and communicate with you about sweepstakes, contests, or other promotional activities or events sponsored by us or our partners;
- v. to send you customized offers including through email and social media platforms;
- vi. to track the redemption of offers and perform other analytics;
- vii. to administer surveys sponsored by us or our partners;
- viii. to respond to your customer service inquiries and requests for information;
- ix. to post your comments or statements on our websites and social media platforms;
- x. to inform you about our partners, brands, products, events, or other promotional purposes;
- xi. to help us offer you real-time deals nearby, if you have activated one of our mobile applications and permitted your mobile or other location-aware device to transmit location data when this service becomes available;
- xii. to maintain and improve our Sites and the products and services we offer;
- xiii. to detect, prevent, or investigate security breaches or fraud;
- xv. to issue fundraiser payments.
- i. use transaction data to confirm a qualifying purchase or return to match transactions to confirm whether you qualify for a statement credit or an Action;
- ii. share transaction data with the participating merchant where a transaction occurred as needed for the merchant to confirm a specific transaction occurred or points should be awarded; for example, the date and amount of your purchase and the last four (4) digits of your card number so the Merchant can verify your purchase with its records if there is a missing or disputed transaction;
- iii. provide participating Merchants or third-party service providers aggregated and anonymized information relating specifically to registered card activity solely to allow participating merchants and third-party service providers to assess the results of their campaign;
- iv. create a record of the transaction data and thereafter maintain and use data in connection with operating the Card Linking Program;
- v. conduct analysis for the improvement and optimization of the Card Linking Program; and
- vi. provide information in order to respond to a request from government authority or a payment organization involved in a transaction with you or a Merchant.
You authorize the sharing, exchange and use of transaction data described above by and among Genie Action and Genie Action’s applicable third party providers, Payment Card Networks and participating Merchants.
HOW AND WHEN WE SHARE THE INFORMATION WE COLLECT
We may share your Personal Information in the following circumstances:
- i. with service providers that provide services for us such as sending emails on our behalf and processing payments. Our service providers are bound by law or contract to protect the Personal Information and are only allowed to use the Personal Information in accordance with the terms of our service agreements with them;
- ii. with Payment Card Networks that administer in-store cash back;
- iii. with Merchants, but only to the extent you have purchased or redeemed an Offer created by the Merchant, or participated in an offer, contest, or other activity sponsored or created through Genie Action on behalf of the Merchant. We may also provide Merchants with Personal Information about the individuals who have purchased the Merchants’ Offers, to send customized offers, to validate the purchases, to aid and troubleshoot redemption, to combat fraud, as part of legal proceedings affecting Genie Action and the Merchant, and to facilitate a direct relationship between Merchants and customers and enable Merchants to communicate electronically with customers who purchased the Merchants’ offers;
- iv. with Merchants if you have opted-in to receive additional offers, promotions and information from them;
- v. with Genie Action business partners or advertisers as part of an offer, contest, or other activity that is provided by or in conjunction with Genie Action and its business partners and in which you have elected to participate. For example, if you are referred to Genie Action from a business partner's website or through an invitation facilitated by or in conjunction with a Genie Action business partner, Genie Action may provide that business partner with information relating to you or the transaction to validate the referral and to support the terms of the relationship between Genie Action and the business partner, which may allow such business partner to contact you directly and to advertise to you;
- vi. in the case of a merger, acquisition, or otherwise to support the sale or transfer of business assets; to enforce our rights or protect our property; to protect the rights, property or safety of others, investigate fraud, respond to a government request; or to support auditing, compliance, and corporate governance functions. If Genie Action is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or prominent notice on our Site of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information;
- vii. to defend ourselves in litigation or a regulatory action and when required or advised to do so by law, such as in response to a subpoena, or similar legal process, including to law enforcement agencies, regulators, and courts in the Canada, United States and other countries where we operate; and
- viii. if the disclosure is required by law, the disclosure is necessary to enforce our agreements or policies, or the disclosure will help us protect the rights, property, or safety of Genie Action, our customers or our partners.
We may also disclose information about you that is not personally identifiable information. For example, we may provide our merchants, business partners, or other third parties with reports that contain aggregated and statistical data about our users.
COOKIES, RELATED TECHNOLOGIES AND THIRD PARTY SERVICES
When you use our Site(s), we collect certain information by automated or electronic means, using technologies such as cookies, pixel tags and web beacons, browser analysis tools, and web server logs. As you use our Site(s) and applications, your browser and devices communicate with servers operated by us, our business partners and services providers to coordinate and record the interactivity and fill your requests for services and information.
When you visit our Site(s), GenieAction.com and our service providers may place cookies on your computers or mobile devices. A "cookie" is a small amount of information that a web server sends to your browser that stores information about your account, your preferences, and your use of the Site(s). Some cookies contain serial numbers that allow us to connect your Site activity with other information we store about you in your profile or as related to your interactions with the Site(s). Cookies allow us to recognize you when you return, track and target your interests in order to provide a customized experience. They also help us provide a customized experience and help us to detect certain kinds of fraud. Some cookies are temporary, whereas others may be configured to last longer. "Session" cookies are temporary cookies used for various reasons, such as to manage page views. Your browser usually erases session cookies once you exit your browser. "Persistent" cookies are more permanent cookies that are stored on your computers or mobile devices even beyond when you exit your browser. We use persistent cookies for a number of purposes, such as retrieving certain information you have previously provided (such as your user id if you asked to be remembered), and storing your preferences (e.g., the fundraiser(s)for which you want to be shown offers). The information from cookies and related technology is stored in web server logs and also in web cookies kept on your computers or mobile devices, which are then transmitted back to our Site(s) by your computers or mobile devices. These servers are operated and the cookies are managed by us, our business partners, and/or our service providers.
Pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed specific actions. When you access these pages or open email messages, the pixel tags and web beacons generate a notice of that action to us, or our service providers. These tools allow us to measure response to our communications and improve our web pages and promotions.
We collect many different types of information from cookies and other technologies. For example, we may collect information from the devices you use to access our Site(s), your operating system type or mobile device model, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone of your device. Browsers routinely send these types of information to web servers. Our server logs also record the IP addresses of the devices you use to interact with the Site(s). An IP address is a unique identifier that devices use to identify and communicate with each other on the Internet. We may also collect information about the website you were visiting before you came to our Site(s) and the website you visit after you leave our Site(s), if this information is supplied to us by your browser.
In many cases, the information we collect using cookies and other tools is used in non-identifiable ways, without any reference to Personal Information. For example, we use the information we collect about Site users to optimize our Site(s) and understand its traffic and usage patterns. If we ever associate this type of information with you as a specific and identifiable person, we treat it as Personal Information.
You may manage how your mobile device and mobile browser share Location Information with Genie Action, as well as how your mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.
THIRD PARTY SERVICES AND THEIR PRIVACY PRACTICES
We use third-party analytics services to help understand your usage of our services. In particular, we provide a limited amount of your information (such as sign-up date and some Personal Information like your email address) to third parties for analytics purposes when you visit our website or use our product.
(i) Google Analytics
We may also collect information that your browser sends whenever you visit our Service (“Log Data”). This Log Data may include information such as your computer’s IP address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages and other statistics. In addition, we may use third-party services, such as Google Analytics, that collect, monitor and analyze this type of information in order to increase our Service’s functionality. We do NOT permit Google to use the data it collects from this website.
- i. Google Analytics service is provided by Google Inc. You can opt-out from Google Analytics service from using your information by installing the Google Analytics Opt-out Browser tool.
- ii. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page.
HOW WE PROTECT YOUR INFORMATION
Genie Action has implemented an information security program that contains administrative and technical controls that are designed to reasonably safeguard Personal Information (unless it is non-confidential by nature, for example, publicly-available information). For example, we use industry-standard encryption technology to secure Personal Information when it is being transmitted over the Internet. Personal Information is contained behind secured networks and is only accessible by a limited number of people who are required to keep the information confidential.
However, the Internet by its nature is not a secure environment and the nature of security risks is constantly evolving, as are the technical and organizational industry standards relating to management of those risks. While we strive to keep current our security technology and will review, refine, and upgrade our security technology as we deem appropriate based on new tools that may become available in the future, the complete security of any information collected, stored, or used by us cannot therefore be guaranteed. In the unlikely event that an unauthorized third-party compromises GenieAction’s security measures, GenieAction will not be responsible for any damages directly or indirectly caused by an unauthorized third party’s ability to view, use, or disseminate such information. If you ever discover inaccuracies in our data or your Personal Information, we urge you to notify us immediately.
ACCESSING AND CORRECTING PERSONAL INFORMATION
Keeping your Personal Information current and up to date helps ensure that we provide you with the highest quality Services and the best offers available through our Merchants and business partners. You can do several things to help keep Personal Information about you current. You can access, update and delete your Contact Information and the other information you provided to use in your profile by logging into your account and accessing the “User Settings” section of the Site.
DELETING YOUR ACCOUNT
If you want to close your account or have other questions or requests, please contact us by email through our Customer Support Center at info@GenieAction.com. While we are ready to assist you in managing your subscriptions, closing your account, and removing your active profile, we cannot always delete records of past interactions and transactions. For example, we are required to retain records relating to previous purchases on the Sites for financial reporting and compliance reasons.
We will retain your information for as long as your account is active or as needed to provide you services and to maintain a record of your transactions for financial reporting purposes. If you wish to cancel your account or request that we no longer use your information to provide you services, contact our Customer Support Center at info@GenieAction.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
USE BY MINORS
If you are under the age of sixteen (16), do not visit our Sites or use our Services.
The privacy of children is of the utmost importance and we are committed to complying with the U.S. Children’s Online Privacy Protection Act (COPPA). We do not intend for our Sites or Services to be used by anyone under the age of sixteen (16), and therefore, we do not knowingly collect, use, or disclose Personal Information from children under the age of thirteen (13). If we ever discover that we have inadvertently collected Personal Information from children under the age of thirteen (13), we will delete it as soon as possible. If you are the parent or legal guardian of a child under the age of thirteen (13) and believe we have collected Personal Information from your child, please email us at info@GenieAction.com and we will take steps to delete such Personal Information as soon as possible.
NOTICE TO RESIDENTS OF COUNTRIES OUTSIDE CANADA
STORAGE OUTSIDE OF CANADA
Your Personal Information may be used or stored by Genie Action or Genie Action’s service providers outside of Canada. Genie Action requires that Genie Action’s service providers safeguard your Personal Information.
ACTIVITY FEED & COMMUNITIES
CHANGES TO THIS PRIVACY STATEMENT
We welcome your questions, comments and concerns about privacy. You may use this form to ask Genie Action a privacy question or correct Personal Information found in your Genie Action profile, mobile application, or another Genie Action owned digital property. You can contact our Privacy Officer by email at info@GenieAction.com
The Privacy Officer will respond to all such inquiries or complaints within 14 business days of receipt.
The Privacy Officer will make reasonable efforts to resolve all such complaints within 30 days of receipt of the initial complaint. If Genie Action finds a complaint to be justified, it will take appropriate measures, including, if necessary, amending its policies and procedures.