Privacy Policy

NeoClick Media, LLC Rewards Program - Privacy and Cookies Policy

Effective Date/Last Updated: February 1, 2026

NeoClick Media, LLC (“Fortune Games,” “we,” “our,” or “us”) provides the following Privacy Policy (“Privacy Policy” or “Policy"), which describes how we collect, use, disclose, and share or sell information that is personally identifiable to a user (“Information”; Information includes Sensitive Personal Information (as defined below)). This Privacy Policy also discusses consumers’ data privacy rights under the California Consumer Privacy Act, as amended (“CCPA”) and other state data privacy and health data privacy laws   that have adopted or may adopt data privacy laws (”State Data Privacy Laws”) and how to exercise those rights. California Consumers: Click here to read the California Notice at Collection within this Privacy Policy. Capitalized terms used but not defined herein shall have the same meaning as in the Website’s Terms and Conditions, which are fully incorporated herein by reference.

We operate this website and other similar websites (each a “Website” and together “Websites”) which enable users to earn gift cards and/or merchandise (“Rewards”) by completing a specified number of “Deals” made available on a Website from our advertising display partners (“Advertisers”) and then completing the Rewards claims process (“Claims Process”) and obtaining a Reward (the foregoing is referred to as the “Program”).

ACCEPTANCE OF PRIVACY POLICY

By accessing and using one of our Websites and/or participating in the Program, you signify your acceptance of this Privacy Policy and your agreement to the collection, use, disclosure, sharing and selling (unless you opt-out from the sale of your Information) of your Information as described herein. If you do not intend to agree to the terms of this Privacy Policy, DO NOT use a Website or participate in the Program. 

PRIVACY POLICY UPDATES

This Privacy Policy is subject to change from time to time. Your continued use of a Website following the posting of changes to these terms will confirm your acceptance of all changes made; provided, that if we expand or alter the Information we collect or how we use it, we will notify users by: (a) sending the modified Policy to our users via email; or (b) any other reasonable means acceptable under applicable state and federal law.

FOR U.S. RESIDENTS ONLY

Please note if you are not a U.S. resident, you are not permitted to use the Websites or participate in the Program.

CATEGORIES OF INFORMATION WE COLLECT

We may collect the following categories of Information:

Identifiers (such as real name, alias, postal, email and/or IP addresses, telephone numbers, birth date, and government-issued identification cards);
Personal information (such as the Identifiers listed above, gender, education, employment, employment history, financial information, home or automobile ownership, medical and health information, and insurance-related, including Medicare, information);
Biometric Data, in the form of users uploading a government-issued identification card along with a selfie or live video for the purpose of verifying their identity prior to claiming Rewards as part of the Claims Process (Biometric Data is considered Sensitive Personal Information under most State Data Privacy Laws);
Protected classification characteristics under state or federal law (which, depending on the state in which the user resides, can include race, religious creed, color, national origin, ancestry, age, marital status, medical condition, physical or mental disability, sex, gender, gender identity, gender expression, sexual orientation and military and veteran status and is considered Sensitive Personal Information under most State Data Privacy Laws);  
Commercial information (including preferences, products or services purchased, obtained, or considered, or other purchasing data); 
Internet or similar network activity (such as browsing and search history and information about a user’s interaction with a website, application, or advertisement) and information made available via Internet activity (such as device types, user agent data, referring URLs, and IP addresses);
Information related to a user’s consent to receive telemarketing calls, SMS messaging, push notifications, commercial email, and other forms of communication (which may include the creation of a report and session recordation of a user interacting with page(s) that seek to obtain a user’s prior express written consent (as defined in the Telephone Consumer Protection Act (“TCPA”)) to receive telemarketing and text messages;
Inferences drawn from other categories of Information (for example, a profile reflecting a person’s preferences, characteristics, psychological trends and attitudes); and
Sensitive Personal Information (some of the Information in the categories above may constitute Sensitive Personal Information, as defined under certain state data privacy and health data privacy laws (“Sensitive Personal Information.”) See,  Health and Wellness Information and U.S. State Law Rights and Disclosures sections in this Privacy Policy for more information concerning Sensitive Personal Information.

HOW WE COLLECT INFORMATION

We may collect Information from the following sources:

Directly from users via registration forms, surveys, communications (including, with consent, business and commercial emails, telephone calls, USPS mail, and other contacts received from users), and, in the case of Biometric Data, when you consent and upload your Information as part of the Claims Process for identity verification;
From publicly availably sources, such as Internet search engines;
Via our hosting servers, which collect Information from users through various technological means when users access and interact with a Website;
From our service providers and contractors who assist us in hosting the Website, providing customer support, and fulfilling Rewards (“Vendors”);
From parties under our common control (which includes our parent, subsidiaries, and other entities under common control with us (collectively “Related Parties");
From our third-party publishers, who may drive users to our Website;
From our Advertisers, who may advertise goods and services on the Website;
From cookies (small text files placed on a user’s browser by a website such as the Website that track online behavior), web beacons (single-pixel GIF image files), and other technological means (collectively, “Cookies”); and
By combining Information, collected from various sources listed above, including Related Parties, to augment and verify Information and to improve the overall quality of our services.

HOW WE MAY USE INFORMATION

We may use Information in the following ways:

To provide you with information about our Rewards, Deals, and other content and products and/or services that we believe may be of interest to you, including sending email, direct mail, text/SMS message alerts, telemarketing messages and other communications that users have requested or consented to receive (the parties sending these communications are referred to as “Marketing Partners”) or that we are required to send concerning users’ registrations or as part of the Claims Process; 
For Website operations, content improvements, testing, research, analysis, and product development;
To verify whether users are entitled to participate in the Program and, if so, to fulfill Rewards;
To provide users with customer service and respond to customer inquiries;
To carry out our obligations and enforce our rights arising from any contracts entered into between users and us, including for purposes of our Arbitration Agreement, and any inquiry specific to prior express written consent under the Telemarketing Sales Rule (“TSR”) and/or the TCPA (“TCPA Consent”);
To detect, investigate, and respond to any fraudulent or malicious activity or any other activity we determine is or may be a violation of our Terms and Conditions, this Policy, or existing laws, rules, and regulations;
As necessary or appropriate to protect the rights, property, and/or safety of us and our Advertisers, Marketing Partners, Related Parties, Vendors, and any other third-party with whom we have a contractual relationship for commercial or business purposes;
To maintain suppression or opt-out lists so that we won't contact users who have asked not to be contacted;
To augment Information by enhancing it with other data sources provided by our Advertisers, Marketing Partners, Related Parties, and Vendors to enable us, for example, to gain deeper insights into our users; and
To respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims, or when we determine it is necessary to comply with applicable laws and/or regulations.

HOW WE SHARE AND/OR SELL INFORMATION

We may share and/or sell Information in the following ways:

With our Vendors and/or Marketing Partners in connection with the delivery of email messaging, telemarketing calls, text/SMS messaging, and push notifications, provided that we have obtained TCPA Consent from such users to be contacted by telephone or text/SMS messaging and push notifications;
With our interest-based Marketing Partners to create anonymized sets of Information which are made available for use by third-party Marketing Partners for programmatic advertising purposes;
With our Related Parties to augment and verify the Information we collect and to develop and enhance their products and services;
With one or more Vendors who provide independent verification of consent, including verification of TCPA Consent for purposes of the TSR and TCPA;
To enable third parties, including our Marketing Partners and data and list management partners, to market products and services to you;
To enable our Vendors to perform their respective tasks, including for fulfillment of Rewards (including our Identity Verification process);
To enable our Information verification and fraud detection Vendors to perform contracted-for services; and
To submit users’ contact information to comment and petition campaigns run by governmental agencies, elected officials, or other parties where users have provided their express consent to endorse and be a part of the campaign including, in some instances, appending the user contact information with specific comment language.

When we share and/or sell Information with our Vendors and Marketing Partners, 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.

We may also share Information with our Vendors as necessary if we become the subject of bankruptcy proceedings, or in connection with the sale, assignment, merger, or other transfer of all or a portion of our business. If we are involved in these types of transactions, we will notify users via email and via a Privacy Policy update on the Website regarding any material details pertaining to Information. 

MINORS

The Websites are designed to comply with the Children’s Online Privacy Protection Act (“COPPA”) and State Data Laws and other laws protecting children’s privacy. In compliance with COPPA, we do not knowingly collect or retain Information from children under the age of 13 and any minor under the age of 13 is not permitted to participate in our Rewards program or claim Rewards.  If you are a parent or guardian of a child under 13 years of age and you think your child has given us Information, you can email us at [email protected].) In compliance with the CCPA, we do not knowingly sell Information of users under the age of 16 for any commercial purpose.  We will only permit children over the age of 13 and under the age of 18 to participate in Deals that involve a purchase if they use a valid credit or debit card or any other payment method that can be relied on as parental consent under COPPA.

COOKIES, INTEREST-BASED ADVERTISING, AND THIRD-PARTY ANALYTICS

Our Websites may use Cookies to determine whether users have previously visited a Website and to streamline the registration process so, for example, users don’t have to re-enter their basic registration information when they return to the Website. We may also use Cookies to enhance a user’s experience while on a Website. Some of our Marketing Partners may place Cookies on a Website to track users’ online behavior while on the Website and after they leave the Website. These third-party Cookies may enable the delivery of interest-based advertisements (to find out more about Cookies, visit here) based on a user’s visit to the Website and/or other websites. In addition, our Marketing Partners use Information gathered in this manner to recognize users across different channels and platforms, including computers, mobile devices, and Smart TVs. Our Marketing Partners may use this information over time for advertising, analytics, attribution, and reporting purposes.

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 a Website and do not involve the collection of any additional Information.

Most browsers 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 or to refuse online tracking. To disable and reject certain Cookies, follow the instructions associated with your Internet browser. In general, when a “do-not-track” setting is active, the user’s browser notifies other websites that the user does not want their Information and online behavior to be tracked and used, for example, for interest-based advertising. As required under some state laws, we are required to inform users that, as is the case with most websites, we generally do not honor or alter our behavior when a user to one of the Websites has activated the "do-not-track" setting on their browser. The exception to this is in the case of California consumers, where, in compliance with the CCPA, we will honor any opt-out preference signals they set on applicable browsers.

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 the 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 means 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 via the following ways:

Email Opt-Out. To opt-out from email marketing and to remove your anonymized data from programmatic advertising enabled by contacting customer service, click the “Unsubscribe” link on the bottom of every page or click here;
TCPA Consent Opt-Out. Providing TCPA Consent is not required to qualify for a Reward. You may continue to use all other aspects of the Website, regardless of whether you elect to provide TCPA Consent. Users who elected to provide TCPA Consent but later wish to revoke it can opt out from future telemarketing calls by following prompts to stop individual telemarketing calls on recorded calls, by informing calling parties that they wish to be placed on their do not call list, or by contacting, as appropriate, the Marketing Partner(s) or our customer service team here. The Terms & Conditions also contain guidance for opting out from telemarketing;
SMS/Text Messaging Opt-Out. To revoke consent for, or opt-out from, SMS/text messaging, reply STOP to text/SMS messages received or contact customer service here;
Push Notification Opt-Out. To opt-out of browser-based push notifications, disable the notifications at the time you receive the notification or disable notifications through your browser’s settings; and
Targeting Advertising Opt-Out. To-opt out of Cookies, interest-based advertising and/or third-party analytics, see the section above. California consumers may also set an opt-out preference signal on applicable browsers.

OPTING OUT OF SHARING/SALE OF INFORMATION

To opt-out of the sharing/sale of your Information click on the “Do Not Sell My Personal Info” link on the bottom of the Website page(s) that you have visited and/or provided Information to and complete the form. You can also send an email to [email protected], stating that you want to opt-out of the sale and sharing of your Information. We do not require a verification process to opt-out, but we reserve the right to confirm this request by sending you an email containing a final “Do Not Sell My Personal Info” link and requesting that you respond to the email. Please note that it may take us several days to process an opt-out request. In compliance with the CCPA, we will honor any opt-out preference signals California consumers set on their applicable browsers.  

To opt-out from the sale of sharing of your Sensitive Personal Information, click on the “Limit the Use of My Sensitive Personal Information” link or contact us at  [email protected].

ACCESSING, CORRECTING, AND DELETING YOUR INFORMATION

Users who provide Information to us may contact us here to correct their Information, request their Information be deleted, and/or access what Information we have collected, processed, sold and/or shared with Advertisers, Marketing Partners and Vendors. We will respond to user requests within forty-five (45) days. If you request deletion of your Information, please note that your Information will be suppressed from further use as described in this Policy. However, please remember that if we have already shared your Information with our third-party Marketing Partners, you will need to contact those Marketing Partners individually to have them suppress or delete your Information. Note that we may retain and use your Information as necessary to comply with our policies including legal obligations, dispute resolution, and enforcement of our agreements.

When you make a request regarding accessing, correcting, or deleting your Information, we will ask individual users to identify themselves and the Information requested to be accessed, corrected, or deleted before processing such requests. 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).

Please refer to the U.S. State Law Rights and Disclosures section of this Privacy Policy for additional information on privacy rights for consumers in certain states.

HEALTH AND WELLNESS INFORMATION

Our surveys may ask health and wellness-related questions which are considered “Sensitive Personal Information” under most State Data Privacy Laws.  We may share your responses with our third-party Marketing Partners who advertise health and wellness-related products and services on the Website, or who otherwise promote health and wellness-related products or services. We may also use this Sensitive Personal Information to display offers for health and wellness-related products and services to you. You may limit the use of your Sensitive Personal Information by clicking on the “Limit the Use of My Sensitive Personal Information” link or by contacting us [email protected] We will also not sell or share your Sensitive Personal Information in states that require a separate opt-in or notice which currently includes the states of Washington, Connecticut and Nevada.  If other states adopt a separate opt-in or notice for the use of Sensitive Personal Information, you may refuse to consent if you are a resident of that state.

MEDICARE SUPPLEMENT PLANS DISCLOSURE

Some of our Marketing Partners offer Medicare Supplement plans. Medicare Supplement plans are not connected with or endorsed by the U.S. Government or the Federal Medicare program. Our Marketing Partners have confirmed to us that all related optional marketing Deals on the Website comply with applicable Federal civil rights laws and do not discriminate on the basis of race, color, national origin, age, disability, or sex. With your consent, we may provide Information to Medicare Supplement providers so they can contact you. If you do not wish us to share your Information, do not provide consent to telemarketing from Medicare Supplement plans.

FINANCIAL INFORMATION

Our surveys may ask questions related to your financial status. We may share your responses with our third-party Marketing Partners who advertise finance-related products and services on the Website, or who otherwise promote finance-related products or services. We may also use this Information to display offers for finance-related products and services to you. With your consent, we may provide this Information to providers so they can contact you. If you do not wish to share this Information, do not answer the finance-related survey questions and do not provide TCPA Consent.

THIRD-PARTY SITES

Our Websites contain links to Advertisers and other sites or services. When you link from a Website to a third-party site (such as when you link from a survey question, optional marketing offer, or Deal advertisement to another site), you are leaving the Website and are subject to the privacy policies and terms and conditions of those sites – NOT this Privacy Policy. We are not responsible for the privacy practices, content, or security of such third-party sites. 

SECURITY OF YOUR INFORMATION

We use commercially reasonable efforts to prevent unauthorized access, 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 users’ Information to only those persons who need access to perform or provide their job or service, both internally and with our Vendors. Information is encrypted with advanced TLS (Transport Layer Security) when collected, stored, and/or transmitted.

While we have taken reasonable measures to create a secure and reliable Websites for users, we are not able to fully eliminate security risks associated with Information. 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 a reportable information security breach of your Information. You will be notified via email 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.

BIOMETRIC DATA

Biometric Data is any information based on a biometric identifier used to identify an individual, including scans of facial geometry. As part of the Claims Process, we ask your consent to use Biometric Data to verify your identity by uploading an image of your government-issued identification document and a photographic image or brief live video (often called a “selfie”) from your mobile phone or other device. We use these images to create facial geometry recognition or a “faceprint,” which we use to verify your identity (“Identity Verification” or “Face Verification”). We collect and process your Biometric Data only for the following purposes:

To verify your identity when you submit a claim for a Reward; and
To prevent fraudulent uses of our Website or the creation of multiple accounts.

We will never sell, rent, or trade your Biometric Data. Biometric Data is decentralized and hosted securely. We implement security measures such as encryption, firewalls, and intrusion detection and prevention systems. We permanently delete and destroy your Biometric Data six (6) months after submission. You may also request that your Biometric Data be deleted any time after it has been submitted for Identity Verification.

You may refuse to consent to the collection and processing of your Biometric Data if you live in a state that requires your opt-in consent for the use of Biometric Data.  These states currently include Illinois, Texas and the State of Washington.  If you live in one of these states, you will be afforded an opt-out election as part of the Claims Process.  If other states adopt opt-in consent for the use of Biometric Data, you may refuse to consent if you are a resident of that state. We may ask that you prove your residence in a  state that requires opt-in consent.  If you choose not to consent we will provide you with alternate options for verifying your identity. 

U.S. STATE LAW RIGHTS AND DISCLOSURES

California was the first U.S. state to adopt a comprehensive data privacy law.  Since the CCPA was adopted  and as of the date this Policy was last updated, about twenty states have enacted data and health data privacy laws (which we refer to in this Policy as “State Data Privacy Laws”), and more are currently considering adopting data privacy laws.  All of the State Data Privacy Laws provide statutory rights to consumers in their respective states.

In general, the CCPA affords among the broadest range of rights to California consumers of the data privacy laws adopted to date but there are variations among the State Data Privacy Laws.  We currently offer all of our U.S. users the same rights afforded to California consumers.  We also briefly describe any additional rights beyond those afforded under the CCPA in other states that have adopted data privacy laws.  

NOTICE AT COLLECTION

This Policy provides timely notice to users, including those who are California residents and fall within the definition of “consumers” as provided for in the CCPA, that we collect Information at or before collection.

In the chart below, we set forth the categories of Information we collect from users and which categories of Information we share or sell. We collect these categories of Information for the following purposes: to provide you with information about Rewards, Deals, and other content and products and/or services that we believe may be of interest to you, including sending you communications that you have consented to receive; for website operations, content improvements, testing, research, analysis, and product development; to verify whether users are entitled to participate in the Program and, if so, to fulfill Rewards; to provide users with customer service and respond to customer inquiries; to carry out our obligations and enforce our rights arising from any contracts entered into between users and us, and any inquiry into whether the user has provided express written consent where required under applicable law; to detect, investigate, and respond to any fraudulent or malicious activity or any other activity we determine is or may be a violation of our Terms and Conditions, this Policy, or existing laws, rules, and regulations; as necessary or appropriate to protect the rights, property, and/or safety of us and our Advertisers, Vendors, Marketing Partners, Related Parties and any other third-party with whom we have a contractual relationship for commercial or business purposes; to maintain suppression or opt-out lists so that we won't contact users who have asked not to be contacted; to augment Information by enhancing it with other data sources provided by our Advertisers, Marketing Partners, Related Parties, and Vendors to enable us, for example, to gain deeper insights into our users; and to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims, or when we determine it is necessary to comply with applicable laws and/or regulations.

Category	Sold/Shared?
Identifiers (such as real name, alias, postal, email and/or IP addresses, telephone numbers, birth date, and government-issued identification cards)	Yes, business and commercial purposes, with the exception of government-issued identification cards, which are shared only for the business purpose of Identity Verification
Personal information (such as the Identifiers listed above, gender, education, employment, employment history, financial information, home or automobile ownership, medical and health information, and insurance-related, including Medicare, information) and which may include Information that is a protected classification characteristic under state and/or federal law) and/or sensitive personal information under state law, including the CCPA (for example, government-issued identification cards, race and/or ethnic origin, physical or mental disability, or sexual orientation)	Yes, for business and commercial purposes
Commercial information (including preferences, products or services purchased, obtained, or considered, or other purchasing data)
Internet or similar network activity (such as browsing and search history and information about a consumer's interaction with a website, application, or advertisement) information available from Internet activity (such as device types, user agent data, referring URLs, and IP addresses)
Inferences drawn from other categories of Information (for example, a profile reflecting a person’s preferences, characteristics, psychological trends and attitudes.
Information related to a user’s consent to receive telemarketing calls, SMS messaging, push notifications, commercial email, and other forms of communication (which may include the creation of a report and visual playback of a user responding to one or more survey questions and interacting with the page that seeks to obtain a user's “prior express written consent” (i.e., TCPA Consent), as defined in the TCPA.	Yes, for business and commercial purposes
Biometric data, in the form of uploading a government-issued identification card and a selfie or a live video	Yes, solely for the business purpose of Identity Verification

We will retain your Information unless you exercise your data privacy rights for so long as we need to protect us from claims related to your interactions with us. For example, if you complete Deals towards a Reward, we will retain the Information relating to your sign up for so long as you could challenge that transaction. For Identity Verification, the Information is retained no longer than six (6) months after submission.

We do not knowingly sell Information of users under the age of sixteen (16) years for any commercial purpose.

Please see the Rights of California Consumers section of this Privacy Policy immediately below to learn about California consumer privacy rights and how to exercise those rights. This includes the right to know the Information we have collected and sold, the right to opt-out from the sale or sharing of Information, and the right to correct or delete your Information.

RIGHTS OF CALIFORNIA CONSUMERS

California consumers have the following rights under the CCPA regarding their Information.

Right to Know. The right to know what Information we have collected, including the categories of Information, the source of collection, our purpose for collecting the Information, the categories of third parties with whom we disclose, share or sell that Information and for what reason, and the specific pieces of Information we have collected about you.
Right to Delete. The right to request that we delete the Information about you that we have collected. Note that there are certain exceptions to this right, including when the Information is necessary to provide you with goods or services you requested, to prevent fraud, and to comply with our legal obligations.  
Right to Correct. The right to request that we correct inaccurate Information that we maintain about you.
Right to Opt-Out of Sale/Sharing. The right to limit or opt-out from the sale or sharing of Information.
Right to Limit the Processing, Use or Disclosure of Sensitive Personal Information. The right to limit the use of Sensitive Personal Information, as defined under the CCPA. Note that there are certain exceptions to this right, including when the Sensitive Personal Information is necessary to provide you with goods or services you requested, to prevent fraud, and ensure safety and security.  We collect Sensitive Personal Information which we may sell or share for commercial purposes unless you elect to limit the use of your Sensitive Personal Information.
Right to Non-Discrimination. The right not to receive discriminatory treatment for exercising your privacy rights.

How to Exercise Your Rights.  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 send an email to [email protected]. To exercise your CCPA rights with regard to Sensitive Personal Information, click on the “Limit the Use of My Sensitive Personal Info” link on the bottom of the Website page where we collect Sensitive Personal Information Information, or send an email to [email protected].

Verification Process.  We require a verification process for requests to access, correct, or delete Information in order to prevent an unauthorized third-party from accessing or making decisions regarding a user’s Information. Generally, 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, such as a government-issued identification card, which we will not retain or use for any other purpose. Use of an Authorized Agent. California consumers may also designate an authorized agent to make these requests on their behalf. You must provide written authorization to the authorized agent that they are authorized to act on your behalf. When contacting us, the agent must submit proof of that authorization. If you use an authorized agent to submit a request, we may need to collect additional information, such as a government issued identification card, to verify your identity before processing your request to protect your Information.

Timing. We will confirm receipt of your request within ten (10) business days. 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 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. 

How We Handle Deletion Requests After Verification. Once we receive and confirm your request to delete, we will delete or de-identify (and direct our 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. If we do not comply with a deletion request, we will provide you with grounds for the denial in writing. Note that after a deletion request, we may retain and use your Information for the limited purpose of complying with our policies, including this Policy, and to comply with applicable laws. 

Disclosure of Information Collected and Sold or Shared. Once we receive and confirm your verifiable consumer request to access your Information, we will disclose to you the following:

The categories and sources of Information collected;
Our business and commercial purposes for collecting and sharing/selling that Information;
The categories of third parties with whom we shared that Information;
The specific pieces of Information collected;
If we sold or disclosed your Information for a business purpose, we will disclose:
For sales - the Information categories for each category sold and the categories of third parties to whom the Information was sold; and
For disclosures - the Information categories for each category disclosed and the categories of third parties to whom the Information was disclosed.

Notice of Right to Opt-Out of the Sale or Sharing of Your Information. 

California consumers have the right to opt-out from the sale or sharing of their Information, including the sale of sharing of any sensitive 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 send an email to [email protected] and elect to opt-out from the sale of your Information. We do not require a verification process to opt-out, but we reserve the right to confirm your request by sending you an email and requesting that you respond to the email. 

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 we have sold or shared a California consumer’s Information after an opt-out request is submitted but before we have complied with the opt-out, we will, where possible, notify all third parties to whom we have sold or shared a California consumer’s Information to comply with the opt-out request. 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.

Notice of Right to Limit Sensitive Personal Information. Under the CCPA, “Sensitive Personal Information” includes non-public information that reveals a consumer’s social security, driver’s license, state identification card, or passport number, a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership, Information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation, and Biometric Data. As noted in the Categories of Information We Collect section above, we may collect, use, share, and sell Sensitive Personal Information under the CCPA other than Biometric Information which we collect only for Identity Verification Purposes as part of the Claims Process. If you do not wish to share your Sensitive Personal Information, you may limit the use of your Sensitive Personal Information by clicking on the “Limit the Use of My Sensitive Personal Information” link or by contacting us at [email protected].

Identity Verification Information Used Only to Fulfill Rewards. To verify your eligibility for Rewards, we use Biometric Data to verify your identity as part of the Claims Process by uploading a government-issue identification card and selfie or live video. Biometric Data is used only for our Identity Verification process and fraud prevention. Biometric Data is stored for no longer than six (6) months. You can request that it be deleted at any time after submission. It is not sold or shared with any third-party for any commercial purpose.

Global Privacy Controls. Certain browsers allow users to enable an opt-out preference signal in their browser settings (a “Global Privacy Control”). When a Global Privacy Control is enabled, it signals websites that the user visits that the user is automatically exercising their right to opt-out of the sale or sharing of their Information without the need, for example, of clicking on a “Do Not Sell My Information” link. Via our service provider, we have enabled acceptance of users of  Global Privacy Control for California consumers and other states that require we honor Global Privacy Controls.

Commitment to Nondiscrimination. We are committed to not discriminating against California consumers 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 the Website may be unavailable if consumers exercise their right to have their Information deleted.

CCPA Metrics. We are required to compile certain annual metrics regarding the CCPA, 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. The metrics for the last calendar year are displayed here. Please note that the information outlined is compiled from various entities, which include our parent, subsidiaries, and other entities under common control with us.

De-identified Data Disclosure.  We may use de-identified data in some instances (data that cannot be linked to any identifiable natural person or any device linked to any such person). We maintain de-identified data without attempting to re-identify it, and any de-identified data that is sold or shared is not able to be re-identified. 

Commitment to Nondiscrimination.  We are committed to not discriminating against consumers who exercise their privacy rights. As such, unless otherwise permitted by applicable law, 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 discriminate against users who exercise their rights, please note that some of the functionality of the Website may be unavailable if consumers exercise their right to have their Information deleted. 

RIGHTS OF USERS OF OTHER STATES THAT HAVE ADOPTED DATA PRIVACY LAWS 

As of the date of this Privacy Policy, about twenty other states beyond California have enacted data privacy laws and more are expected to do so.  We will update our privacy practices to comply with those laws when they’re effective.  Each of the states that has adopted data privacy laws including states that have adopted health data privacy laws afford their residents data privacy rights with respect to the collection, use, sale and/or sharing of Information.  As noted above, the CCPA affords California consumers a broad range of rights with respect to their Information and we have elected to afford all of our U.S. users with these rights.  Some state data privacy and health data privacy laws afford consumers with other rights including the right to opt-out of targeted advertising, the right to opt-out of automated processing performed on Information that evaluates, analyzes, or predicts personal aspects of the user and the right to opt-out of the collection and use oof Biometric Data. 

We will also not sell or share your Sensitive Personal Information in states that require a separate opt-in or notice which currently includes Washington, Connecticut and Nevada.  If other states adopt a separate opt-in or notice for the use of Sensitive Personal Information, you may refuse to consent if you are a resident of that state.

States currently and may in the future offer additional data privacy rights to their residents.  If a user resident in a state that offers these additional rights requests that we afford users these state-specific rights, we will honor such requests. 

QUESTIONS, SUGGESTIONS, OR TO CONTACT US

If you have any questions, comments, complaints, or suggestions regarding this Policy or the Website, please contact us here.