Privacy Policy

Introduction

This privacy policy (“Privacy Policy”) applies to information collected by ClientLoyalty, LLC (“Company”, “we”, or “us”) in connection with the ClientLoyalty cloud-based platform and the ClientLoyalty mobile application available for the Apple and Android platforms, and any other ClientLoyalty web site, widget, mobile application or other online property that links to or includes this Privacy Policy (collectively, the “Platform”) (however accessed and/or used, whether via personal computers, mobile devices or otherwise). This Privacy Policy also applies to interactive features or downloads that are owned or operated by Company and available through the Platform. This Privacy Policy explains Company’s information collection practices at the Platform, such as the types of information Company collects regarding users of the Platform and how we may use that information. Please review this Privacy Policy carefully.

(1) What Information Does The Platform Collect?

(a) Information You Provide To Us

We may ask you to provide us with certain categories of information such as: (1) personal information, which is information that specifically identifies you, such as your name and physical address (“Personal Information”); and (2) demographic information, such as gender, zip code, or similar information (“Demographic Information”). We may collect this information through various forms and in various places on the Platform, including account registration forms, “contact us” forms, or when you otherwise interact with us. If we combine Demographic Information with the Personal Information we collect, we will treat it as Personal Information under this Privacy Policy.

(b) Information We Collect As You Access and Use The Platform

In addition to any Personal Information or other information that you choose to submit to us, we and our third-party service providers may use a variety of technologies that collect certain information whenever you visit or interact with the Platform (“Usage Information”). This Usage Information may include the browser version that you are using, the URL that referred you to our Platform, all of the areas within our Platform that you visit, the time of day, your geographic location, among other information. We may use Usage Information for a variety of purposes, including to enhance or otherwise improve the Platform. In addition, Usage Information that we may collect include your IP address or other unique identifier assigned to your computer or other device used to access the Platform (each, a “Device”). Whenever we combine Usage Information with your Personal Information, we will treat the combination as Personal Information.

A few of the methods that may be used to collect Usage Information, include, but are not limited to:

Cookies

A cookie is a data file placed on a Device when it is used to visit the Platform. A Flash cookie is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. Cookies and Flash Cookies may be used for many purposes, including to remember you and your preferences and track your visits to our web pages. If you choose to disable cookies or Flash cookies on your Device, some features of the Platform may not function properly.

Embedded Scripts

An embedded script is programming code that is designed to collect information about your interactions with the Platform, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Platform, and is deactivated or deleted thereafter.

(c) Information Third Parties Provide About You

We may, from time to time, supplement the information we collect about you online with outside records from third parties in order to enhance our ability to serve you, to tailor our content to you and to offer you opportunities to participate in research surveys that we believe may be of interest to you. We may combine the information we receive from those sources with information we collect through the Platform. In those cases, we will apply this Privacy Policy to any Personal Information received, unless we have disclosed otherwise.

(d) Information You Provide About A Third Party

If you send someone else a communication from the Platform, such as sending an invitation to a friend, the information you provide (names, e-mail addresses, etc.) is used to facilitate the communication and is not used for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you use any send-to-a-friend functionality on our Platform, your e-mail address may be included in the communication sent to your friend.

(2) How Do We Use The Information Collected?

We may use your Personal Information, Demographic Information or Usage Information that we collect about you: (a) to provide you with information or services or process transactions that you have requested or agreed to receive including to facilitate your participation in completing survey questions or entering operational data, or to provide you with information on behalf of us or third parties; (b) to enable you to participate in a variety of the Platform’s features such as surveys or entering operational data and similar programs; (c) to process your registration with the Platform, including verifying your information is active and valid; (d) to improve the Platform or our services, to customize your experience on the Platform, or to serve you specific content that is most relevant to you; (e) to contact you with regard to your use of the Platform and, in our discretion, changes to the Platform and/or Platform’s policies; (f) for other internal business purposes; and (g) for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.

Please note that information submitted to the Platform via a “contact us” or other similar function may not receive a response. We will not use the information provided to contact you for marketing purposes unrelated to your request unless you agree otherwise.

(3) How and When Do We Disclose Information to Third Parties?

We may share non-personally identifiable information, such as aggregated user statistics and Usage Information, with third parties. We do not share your Personal Information with third parties for those third parties’ marketing purposes unless you consent to such sharing at the time you provide your Personal Information. We may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described in this Privacy Policy.

(a) When You Agree To Receive Information From Third Parties

You may be presented with an opportunity to receive information and/or marketing offers directly from third parties. If you do agree to have your Personal Information shared, your Personal Information will be disclosed to such third parties and all information you disclose will be subject to the privacy policy and practices of such third parties. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review the privacy policies and practices of such third parties prior to agreeing to receive such information from them. If you later decide that you no longer want to receive communication from a third party, you will need to contact that third party directly.

(b) Third Parties Providing Services on Our Behalf

We may use third party vendors to perform certain services on behalf of the Platform, such as hosting the Platform, designing and/or operating the Platform’s features, tracking the Platform analytics, and enabling Company to send you information about participating in surveys or performing other administrative services. We may provide these vendors with access to user information, including Personal Information and Usage Information, to carry out the services they are performing for you or for us. While we may use third party analytics service providers to evaluate and provide us with information about the use of the Platform and viewing of our content, we do not share Personal Information with these analytics service providers, but they may set and access their own cookies, web beacons and embedded scripts on your Device and they may otherwise collect or have access to information about you, including aggregated user statistics and Usage Information.

(c) Administrative and Legal Reasons

We may access, use, preserve, transfer and disclose your information (including Personal Information), including disclosure to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the Platform’s policies applicable to the Platform, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Platform or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Further, we may use IP address or other Usage Information, to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion. Such disclosures may be carried out without notice to you.

(d) Business Transfer

We may share your information, including your Personal Information, Demographic Information and Usage Information with our parent, subsidiaries and affiliates for internal reasons. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Platform or applicable database; or (ii) in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our membership interests and/or assets or other corporate change, including, during the course of any due diligence process.

(4) What about Information I Disclose Publicly?

The Platform may permit you to submit feedback, opinions, ideas, videos, and operational data or other content, including Personal Information (collectively, “User Generated Content”). User Generated Content may be published online or offline in any media or format (currently existing or hereafter developed). Others may have access to this User Generated Content and may have the ability to share it with third parties across the Internet. Please think carefully before deciding what information you share, including Personal Information, in connection with your User Generated Content. Please note that Company does not control who will have access to the information that you choose to make public, and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure. This Privacy Policy does not apply to any information that you disclose publicly, share with others or otherwise upload onto the Platform. We are not responsible for the accuracy, use or misuse of any content or information that you disclose or receive through the Platform.

(5) How Do I Change My Information And Communications Preferences?

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration. If you have any questions about: (a) access to Personal Information; (b) the collection, use, management or disclosure of your Personal Information; or (c) this Privacy Policy, you should contact us in the following ways:

Postal Mail: Privacy Coordinator, ClientLoyalty, Inc., 220 N Green St, Suite 6015, Chicago, Illinois 60607; By e-mail: info@clientloyalty.com

(6) What About Consent To Transfer Information To The United States?

The Platform is operated in the United States and intended for users internationally provided the countries where the users reside are not on a sanctioned or prohibited country list provided by the United States government. If you are located anywhere outside of the United States, please be aware that information we collect, including, Personal Information, will be transferred to, processed and stored in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Platform or providing us with any information, you consent to this transfer, processing and storage of your information in the United States.

(7) What Should Parents Know About Children?

The Platform is intended for general audiences and we do not knowingly collect any Personal Information from children younger than the age of 13. We will use reasonable efforts to delete from our networks any Personal Information collected that we later determine to be from a user younger than the age of 13. If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed Personal Information to us, please contact us at:

Postal Mail: Privacy Coordinator, ClientLoyalty, Inc., 220 N Green St, Suite 6015, Chicago, Illinois 60607; By e-mail: info@clientloyalty.com

(8) What About Security?

We incorporate technical and administrative safeguards to help protect and secure our networks, including your Personal Information. However, no data transmission over the Internet, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Platform and provide us with your information at your own risk.

(9) What About Credit Card Info?

Certain ClientLoyalty users will submit credit card information to subscribe to the service. This credit card information is stored by a trusted third party supplier who has represented to us that it will only handle Personal Information in accordance with security practices prevalent in the payment industry. Our payment supplier will have to share your payment information with credit card companies to process your payments to us.

(10) What About Changes To The Privacy Policy?

We reserve the right to change this Privacy Policy at any time. If we do, we will use reasonable efforts to provide you with notice of our revised Privacy Policy.

Last Updated April 14, 2016