As used in this policy, the terms “using” and “processing” information include using cookies on a computer or mobile device, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization.
Information Collection and Use
Our primary goals in collecting information are to provide and improve the Services, to administer your use of the Services (including your account, if you are an account holder), and to enable you to enjoy and easily navigate the Services.
Personally Identifiable Information.
- Your use of our Services is voluntary. However, if you wish to use certain features of the Services, we may ask you to provide us with, or grant us access to, or permission to obtain, certain personally identifiable information that can be used to contact or identify you (“Personal Information”). Personal Information includes, but is not limited to, your name, phone number, credit card/debit card number or other billing information, email address and postal address. For example, we collect Personal Information in connection with your registration to join the Froogal Service. We also collect Personal Information on behalf of the Branded Offering Merchant when you register to use its Merchant Branded Offering. When you complete your registration in either instance you become a “Member”. If you create an account using your login credentials from one of your Social Networking Service (“SNS”) accounts, we will be able to access and collect your name and email address and other Personal Information that your privacy settings on the SNS account permit us to access (such as your “real” name, profile picture, email address and other information you make publicly available via the applicable SNS).
- We also collect other information that you provide as part of registration and the administration and personalization of your profile webpage, as applicable (e.g., without limitation, age, date of birth, extended profile or survey responses, zip code, geo-location information and mobile device identification information (e.g., UDID) (“Non-Identifying Information”).
- We use your Personal Information (in some cases, in conjunction with your Non-Identifying Information) mainly to provide the Services and administer your inquiries. Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your viewing preferences). We may combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other Users (defined below) to attempt to provide you with a better or more personalized experience, to improve the quality and value of the Services and to analyze and understand how the Services are used. We may also use the combined information without aggregating it to serve you specifically, for instance to deliver a product to you according to your preferences or restrictions.
Information Related to Use of the Services. When you visit the Services, whether as a Member or a non-registered user just browsing (any of these, a “User”), our servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type or the webpage you were visiting before you came to the Services, pages of the Services that you visit, the time spent on those pages, information you search for on the Services, access times and dates and other statistics. From users of the mobile applications part of the Services, we also collect Log Data such as agent version, platform, SDK version, API key for the application, application version, mobile device model, manufacturer and version, access times and dates, time zones and network status.
We use several third party services to collect, monitor and analyze this information in order to increase the Services’ functionality and user-friendliness, and to better tailor the Services to visitors’ needs. We also use this information to verify that visitors to the Services meet the criteria required to process their requests. Accordingly, Log Data is shared with these third party service providers (such as Google Analytics and Mixpanel) but does not include Personal Information.
Information Collected Using Cookies and other Web Technologies
“Web Beacons” (also known as Web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the user’s device, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).
Location Information. When you use the Froo app (By “Froogal Service”) or the apps part of a Branded Merchant Offering, we may collect and store information about your location by converting your IP address into a rough geo-location or by accessing your mobile device’s GPS coordinates or coarse location if you enable location services on your device. We may use location information to improve and personalize our Services for you. If you do not want us to collect location information, you may disable that feature on your mobile device.
Information Sharing and Disclosure
We will not share any Personal Information that we have collected from or regarding you except as described below:
Information Shared with Social Networking Services. The Services give you the option to share information contained in your account with certain SNSs. We will not share your account information, which may contain your Personal Information, with such SNSs unless you expressly authorize such disclosure.
Information Shared with Froogal Network Merchants. When you join the Froogal Service you may transact at participating merchants part of the Froogal network (each a “Froogal Network Merchant”) and earn reward progress or rewards at those merchants. When you do so, Froogal may provide your anonymous and/or aggregate transaction data to the Froogal Network Merchant in order to enable the merchant to track the efficacy of their participation in the Froogal network. For the first Froogal Network Merchant you at which you select an introductory offer (including intro rewards that grant progress toward a reward) and/or through which you sign up for the Froogal Service (“Initial Froogal Merchant”) we automatically share the Personal Information and Non-Identifying Information we collect from you with the Initial Froogal Merchant.
This information is shared with the Initial Froogal Merchant so they can administer your participation in their rewards program, update you on special offers, products or services that may be of interest to you. Initial Froogal Merchants are contractually obligated to comply with applicable law in their use of the information they may receive from us about you. For Froogal Network Services you purchase directly through the Froo app (By “Froogal”), such as Exclusive Offers, we will share your mobile number / e-mail address to enable the Froogal Network Merchant whose product or service you purchased for purposes of support and tracking your purchase.
For all other Froogal Network Merchants, you may have the option to provide your mobile number / email address or other Personal Information and Non-Identifying Information to a Froogal Network Merchant and we will only share that Personal Information with a Froogal Network Merchant when you expressly authorize us to do so. Thanx Network Merchants may use this information to message you inside and outside of the Froogal Network Service (e.g., via email / mobile number) with advertisements about products or services that may be of interest to you or to respond to your requests. Froogal Network Merchants are contractually obligated to comply with applicable law in their use of the information they may receive from us about you.
Information Shared with Branded Offering Merchants. When you join a Merchant Branded Offering we automatically share the Personal Information, Transaction Data and any other information we collect from you with the Branded Offering Merchant. This information is shared with the Branded Offering Merchant so they can administer your participation in their rewards program and learn about your interests and the products and services you enjoy. Branded Offering Merchants may also use this information to message you inside and outside of the Merchant Branded Offering. For example, a Branded Offering Merchant may use your Personal Information to deliver you rewards and keep track of your rewards progress in its loyalty program. Branded Offering Merchants are contractually obligated to comply with applicable law in their use of the information they may receive from us about you.
Information Shared with Third Parties. We may share aggregated information that does not include Personal Information and we may otherwise disclose Non-Identifying Information and Log Data with third parties for industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.
Information Shared with Our Services Providers. We may employ third party companies and individuals to facilitate the Services, to provide the Services on our behalf, to perform website and application-related services (e.g., without limitation, maintenance services, database management, communications, card processing, web analytics and improvement of the Services’ features) or to assist us in analyzing how our Services are used. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Information Disclosed for Our Protection and the Protection of Others.
Froogal cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Froogal or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.
Information Disclosed in Connection with Business Transactions. Froogal may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.
We offer you choices regarding the collection, use and sharing of your Personal Information and we will respect the choices you make. Please note that if you decide not to provide us with the Personal Information that we request, you may not be able to access all of the features of the Services.
- Changing or Deleting Your Information: All Members may review, update, correct or delete the Personal Information provided to us in course of the use of the Services via their accounts or by contacting us. If you completely delete all such information, then your account may become deactivated. If you would like us to delete your account in our system, please contact us at [email protected] with a request that we delete your Personal Information from our database. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.
Froogal is very concerned with safeguarding your information. The security of your Personal Information is important to us. But remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. When you enter sensitive information on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). In some cases, we also encrypt sensitive information where it is stored on our systems.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on the Site or via the Application in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Identity theft and the practice currently known as “phishing” are of great concern to Froogal. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your account login information, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication.
Links to Other Sites
The Services contains links to other websites. If you choose to visit a third party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other sites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.