PRIVACY POLICY
This website (“Website”) is owned and operated by the Administrator (“we,” “us,” or “our”). We are focused on building an online community of members who can read about and choose from a wide variety of digitally served reward programs (“Reward Services”). The protection of your privacy is of great importance to us. This privacy policy (“Privacy Policy”) describes our commitment to protecting your privacy and explains our practices and policies for collecting, using and sharing information collected from or about you when you visit, access, or use, or provide information to us in connection with this Website and any Reward Services. In order to fully understand your rights related to privacy issues, we encourage you to read this Privacy Policy and to consult our Terms of Use page. By visiting, accessing, or using, or providing information to us in connection with, the Website and any Reward Services, you expressly consent to our collection, storage, use, and sharing of your information as described in this Privacy Policy. Please note that if you disagree with anything in this Privacy Policy, you should not visit, access, use, or provide information to us in connection with the Website or any Reward Services.
As our services evolve, we may from time to time amend this Privacy Policy. Please revisit this Privacy Policy periodically and, if you have questions regarding either this Privacy Policy or our Terms of Use, contact us at csr@alldigitalrewards.com.
Section 1. Collecting Personal Information.
We gather information from members and visitors primarily through the following ways:
1. Member profiles, surveys, and e-mail list questionnaires
2. Contact, Registering Product Sales, Reward Fulfillment, Reservation Request, and Feedback Forms
3. Cookie technology
4. IP addresses
Information We May Collect
We collect and use information we believe is necessary to administer and promote our business and provide you with the products and services you request. We may collect and maintain both personal information and non-personal information needed for these purposes. Your personal information and/or non-personal information will be referred as your “information” in this Privacy Policy.
How We Collect Your Information
· Information You Provide to Directly Us. When you create an online profile as a member (“Member Profile”), complete a survey, enter an online promotion, make a reservation request, provide feedback, request information or fill out any other online forms through our Website, we collect certain personal information about you (as more fully described below). When creating a Member Profile, we ask for a member ID, your name, password, e-mail address, and physical address. Occasionally, we may also collect additional personal information if you choose to register a product sale, enter a contest, fulfill a reward product, make a reservation request, complete a survey or complete another type of online form. Once you create a Member Profile, we will use the information we receive from you to determine what reward information is most appropriate for you and what information you may find most relevant.
· Information Automatically Collected through the Website
· IP Addresses and Computer Data. We may collect information about your computer, including your IP address, operating system and browser type. An IP address is a number that is assigned to your computer automatically when you access the Internet. When you visit a particular page on our Website, our servers record your IP address. We may record IP addresses, operating system and browser type in order to facilitate systems administration or to report aggregate information to our advertisers (eg, how many visitors logged on to our Website).
· Cookie Technology. We use "cookies" to track and store your preferences in order to personalize our Website for you. A cookie is a small data file that is sent to your browser and is stored on your computer's hard drive when you visit the Website. A cookie assigns a random, unique number to your computer. Cookies allow us to recognize members and other users when they come to our Website. The cookies record "clickstream" information (data reporting the URLs or names of the pages on our Website that you have visited) and help us estimate our audience size, determine which areas of our Website are the most popular and serve targeted advertising. Cookies also make your experience easier by saving your preferences and passwords. Our cookies customize the Website and allow our members and other users to easily update their information. We do not allow anyone else to access your cookie. A cookie cannot read data off of your hard drive or read cookie files created by other websites. You can reject cookies by turning them off in your browser. This will, however, prevent you from using our customized services, may limit system performance and may cause certain features of the Website to malfunction or not work at all. You may also have to repeatedly enter personal information in order to participate in various services or promotions. By continuing to browse the Website, you are agreeing to our use of cookies.
Section 2. How We Use Your Personal Information.
We will use the information you provide to us for the specific purposes for which you provided the information, as stated at the time of collection, and as otherwise described in this Privacy Policy or permitted by law. Primarily, we will use your information to provide you with our Rewards Services, and to improve the products and services we provide you and develop new products and services. The following are some additional ways in which we may use your information to administer or promote our business and provide you with the products and services you request or may be of interest to you:
· Inform You of New Products and Services. From time to time, we add products and services, and our goal is to keep you informed. We will send you emails concerning new developments, but we encourage you to check back often to see what is new and happening in the digital rewards world.
· Customized Services and Experiences. We gather information from members and other users in order to provide them with personalized experiences. Every time you visit our Website, we provide you with what we believe will be your preferred functionality, the content that will be most relevant for you, and services that will be of the most interest to you.
· Targeted Advertising. In order to bring you offers that may be of interest to you, and to help finance the cost of making our Website available to you, we place advertisements on our Website. Gathering information from members and other users allows us to target advertisements and sponsorships. We believe this makes information on our Website more relevant to you and is more productive for our advertisers. For example, if you have indicated that you enjoy fine dining, we can target an advertisement to you about a special deal at a fine dining establishment near you.
· Optional E-mail Messages. When you register with our site and indicate you would like to receive e-mails relating to special offers and content, occasionally we may send you e-mail messages with information and special deals or promotions related to our services, or third-party products that you may find interesting. If you elect to receive such e-mails when you register, you may unsubscribe at any time thereafter. You can unsubscribe by clicking on the unsubscribe submenu in your e-mails and/or by contacting us directly at csr@alldigitalrewards.com.
· We may also use your information for the following additional purposes:
o to fulfill the purposes for which you provide it;
o to ask for your participation in our internal market research;
o to generate aggregate statistical studies about our users;
o to contact you in response to your inquiries, comments and suggestions;
o to provide you with a secure and safe environment;
o to protect and defend our rights or property or enforce our agreements with you;
o to contact you otherwise when necessary; and
o otherwise with your consent or as permitted or required by law.
Section 3. How We Share Your Personal Information.
As a general rule, we will not disclose your personal information to third parties, except to the extent necessary to provide you with a requested service, provide better services, or under circumstances required by law. We will disclose your personal information when we believe in good faith that any applicable law, regulation, or legal process requires it, or when we believe disclosure is necessary to protect or enforce our rights or the rights of another member or user. We will use, or supply to others, aggregated data (independent of any personal identifiers) for research and commercial purposes, such as describing our services, members and users to prospective partners, advertisers and other third parties.
As permitted by law, we may share the information we collect from and about you with third parties as follows:
· Our Affiliates. For business purposes, we may share certain information we receive from you, and about your transactions with us, with our affiliates and/or subsidiaries.
· Third Party Service Providers. Your information may be shared with or collected by third party service providers who provide us with services such as data hosting or processing, fulfilling travel reservations or purchases, and/or to ensure proper fulfillment. We require these providers exercise reasonable care to protect your personal information and restrict the use of your personal information to the purposes for which it was provided to them.
· Third Party Joint Marketing Partners. We may share certain limited information about you with other companies with whom we have joint marketing or similar agreements, or other businesses with whom we have a contractual relationship (“Joint Marketing Partners”), who may contact you with marketing and promotional offers. These businesses generally include service providers, such as airlines, hotels and car rental agencies, and retailers, but may include others. If you would like us to stop providing your information to these Joint Marketing Partners, you may opt-out in accordance with Section 5 below.]
· Business Transfers; Bankruptcy. In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets or business, we may transfer or allow third parties to use information owned or controlled by us. We reserve the right, in connection with these types of transactions, to transfer or assign your information and other information we have collected from our users to third parties or to authorize third parties to use any such information retained by us. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred user information will be subject to this Privacy Policy. However, any information you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity.
· Response to Subpoenas or Court Orders or to Protect Rights and to Comply with Our Policies. To the extent permitted by law, we will disclose your information to government authorities or third parties: (i) if required to do so by law, or in response to a subpoena or court order, search warrant or other valid legal process, (ii) to comply with legal, regulatory or administrative requirements of any governmental authorities, including but not limited to gaming regulators, (iii) in connection with any legal action, claim or dispute, including but not limited to the collection of debts, or (iv) if we believe in our sole discretion that disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large. You should be aware that, following disclosure to any third party, your information may be accessible by others to the extent permitted or required by applicable law.
· Aggregate Information. We may use and/or disclose aggregated, de-identified information about our users, and non-aggregated information that does not identify any individual, without restriction. While this information will not identify you personally, in some instances these third parties may be able to combine this aggregate information with other data they have about you, or that they receive from third parties, in a manner that allows them to identify you personally.
Specific uses of personal information that vary from this Privacy Policy (if any) may be found in the privacy policy applicable to a specific service provided by our Website (e.g., a contest, reservation request, booking travel, and/or survey). When you are notified that your personal information will be used in a manner that varies from those described in this Privacy Policy, the use of your personal information will be subject to the notification for that particular service, such as with sweepstakes, contests or promotions. Please look for privacy policies and terms and conditions that apply to the services in which you participate.
Section 4. Other Websites.
Our Services enable you to link directly to other websites. It is important to note that we do not control the privacy policies of such other unaffiliated websites, our advertisers and other third-party web sites for which we provide advertisements and submenu. If you click through an advertisement or link to and submit your information to an advertiser or to another website, you will be subject to that advertiser's or web site's privacy policies, if any. We do not assume responsibility or liability for such third-parties' policies or actions.
We also do not exercise control of other websites that may display information about ADR and our Reward Services, or direct how those other websites may collect, distribute, or otherwise use your personal information. Such websites may place their own cookies or similar files on your computer, collect data, or solicit personal information from you. We do not guarantee the security of any information that you may disclose on other websites, and we are not responsible or liable for those websites’ policies, actions, or content.
Section 5. Controlling the Use of Your Personal Information.
You can reject cookies by disabling them in your browser or you can configure your browser to alert you when cookies are sent. If you register with our Website and provide us with personal information, you will always have the option at any time to cancel your access or to request that your personal information be removed from our systems by contacting us. We will send to you an e-mail message confirming your request. You must acknowledge to us by e-mail your receipt of such confirmation. After you respond to our confirmation, we will remove your information from our database. Residual information may remain in our archives and/or records. Such information will not be used for commercial purposes; however, we may notify you of major changes to our service from time to time. We reserve the right to maintain information about registered members who violate our Terms and Conditions or whose access to the Website has been denied, in order to detect repeat offenders.
If you receive email communications from us and would prefer not to receive further email communications from us, you may click on the link found on the bottom of all our email communications and follow the instructions to either change your email preferences or unsubscribe from all emails. You can also unsubscribe from receiving email communications from us at any time by contacting us at csr@alldigitalrewards.com.
Regardless of your decision to unsubscribe from receiving email communications from us, we may still contact you to respond to an inquiry we receive from you, regarding transactions and for transactional purposes (e.g., sales confirmations, service/reminder notices, and account maintenance).
Section 6. EU General Data Protection Regulations
If you are a European Union resident, in addition to our general Privacy Policy, we would like to bring the following to your attention:
· Data Controller. The data controller is the Privacy and Security Officer at All Digital Rewards. The designated representative for purpose of the EU General Data Protection Regulation (“GDPR”) has been appointed. This representative can be reached at compliance@alldigitalrewards.com.
· Our Website generally uses cookies to distinguish you from other users of our Website. This helps us provide you with a good experience when you browse our Website and also allows us to improve our Website. A fuller discussion of what cookies are and how we use them appears in our general Privacy Policy. When you created a Member Profile you checked a box allowing us to use cookies. You may also block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies.
· Your rights as a data subject. To the extent you choose to provide personal information to us through this Website, we would like to bring the following to your attention with regard to our collection and processing of this data:
o The GDPR may provide you with additional rights as a data subject.
o We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
§ To fulfill a contract, we are about to enter into or have entered into with you;
§ Where it is in our legitimate interests (a legitimate interest is when we have a business or commercial reason to use your information in conducting and managing our business);
§ When it is our legal or regulatory duty; and
§ When you consent.
o Right to Access. You have the right to access information held about you. You may request, by contacting us at csr@alldigitalrewards.com, to review, revise, rectify or delete your personal information processed by us. You may also ask us to suspend the processing of your personal information. Unless otherwise required under applicable laws, we will promptly revise, rectify and/or erase your personal information upon receiving your request. Notwithstanding, your data that has been deidentified and aggregated shall no longer be considered personal information, and you cannot seek to have your information removed from an aggregated data set, nor is consent for further use required.
o Right to Object. You may object to processing of your personal information where we are relying on a legitimate interest (or those of a 3rd party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
o Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to process it.
o Data Portability / Request the transfer of your Personal Information to you or directly to another controller. This right only applies to automated information which you initially provided consent for us to use or where we used the personal information to perform a contract with you. We will (unless there is an exemption) assist you by securely transferring your personal information directly to another controller where technically feasible or by providing you with a copy in a structured commonly used machine-readable format. The data we can provide is:
o Data Storage. We retain your personal information and information stored and collected through the Website for as long as we have a business or tax need, or as applicable laws, regulations, or government orders require. When your information is no longer necessary or relevant for the identified purpose or to fulfill a legal or business requirement, we will use reasonable commercial efforts to securely dispose of and destroy your information collected through the Website.
o Data Location. This Website is maintained and managed outside the European Union. In providing personal data, you will be transferring it outside the European Union. We take organizational and technical measures which we believe maintain an adequate level of security.
Section 7. Your California Privacy Rights.
As provided under California Civil Code Section 1798.83, also known as the “Shine The Light” law, we provide our customers with the ability to “opt out” of having their personal information shared with affiliated and non-affiliated third parties for their direct marketing purposes. You may opt-out of having your personal information shared with affiliated and non-affiliated third parties for their direct marketing purposes in accordance with the opt-out process described in Section 5.
Section 8. Children's Personal Information.
We are committed to protecting the privacy of children and encourage parents and guardians to take an active role in their children’s online activities and interests. Our website is not directed to children or designed to attract them. You must be at least 18 years of age to use our Website and Reward Services. We do not knowingly collect, use, or disclose personal information about users that are under 18 years of age. If we later learn that a user is under 18 years of age, we will remove that user’s personal information from our databases and prevent the user from further using the Website and Reward Services. If you become aware that a user is under 18 years of age, please notify us immediately at csr@alldigitalrewards.com. If you are a user who is identified in this manner, we may require you to submit suitable proof of age, such as a copy of government-issued identification, in order to continue using the Website.
Section 9. More About Your Privacy.
You should be aware that personal information you voluntarily disclose online in a public area might be collected and used by others. We do not control the actions of visitors, members or users. Your disclosure of personal information in a travel submission, an interactive question and answer, or any other publicly-accessible place on our Website is done so at your own risk. You should understand that your personal information might be collected and used by others to send you advertisements or unsolicited messages or for other purposes. You are solely responsible for maintaining the secrecy of your passwords and should be careful when disclosing your personal information online. While we will take appropriate security measures to protect the privacy of your personal information, no protection is foolproof, and transmissions made over the Internet cannot be made absolutely secure. We do not assume any liability for disclosure of data resulting from errors in transmission or made by unauthorized third parties.
Section 10. Acceptance of Privacy Statement.
By using this Website and services, you signify your acceptance of this Privacy Policy. If you do not agree or are not comfortable with any part of this Privacy Policy, you should no longer use our Website. We reserve the right to modify this Privacy Policy at any time. Your continued use of any portion of our Website following notification or posting of such changes will constitute your acceptance of those changes.
Section 11. Security.
We apply technical, administrative, and organizational security measures to protect the data we collect against accidental or unlawful destruction and loss, alteration, unauthorized disclosure or access, in particular where the processing involves the transmission of data over a network, and against other unlawful forms of processing. While we are always looking to take reasonable steps to improve our security, the Internet can never be completely secure, and we cannot guarantee the security of the information transmitted to the Website. In particular, emails, messages, and other communications may not be encrypted, and you should never use these communication methods to convey personal information that you wish to keep private. Ultimately, you are responsible for protecting the security of your password and login information.
Section 12. Data Breach.
While we employ multiple security measures to maintain data security, data breaches can occasionally happen, even to the most secure of systems. In the event of such a situation, we will, in compliance with any applicable federal and state data breach laws, endeavor to timely notify all users whose personal information we know or has clear reason to believe was accessed by an unauthorized person.
Section 13. Monitoring and Enforcement.
In accordance with applicable laws, you may request access and raise concerns or complaints regarding your personal information processed by us by contacting us using the information provided in Section 14. If you file a complaint, we will investigate the matter or suspected failure to comply with this privacy policy. It is our practice to respond to you within 45 days of receiving the complaint. We will take all appropriate action to remedy any such issues.
Section 14. Contacting Us.
If you have any questions or concerns regarding this Privacy Policy, or if you would like to request us to delete, correct or show you your personal information as provided above, please contact All Digital Rewards at csr@alldigitalrewards.com.