Privacy FAQ — 2010

Consumer privacy is a top priority. That’s why we designed RevTrax®, a digital coupon technology that doesn’t require consumers to register or download any type of software.

We have answered a few of the most frequently asked questions concerning privacy in plain English. You can also read our full Public Site Privacy Policy below.

Do I need to provide any personally identifiable information to RevTrax in order to receive a RevTrax enabled coupon?
We will not ask for your personally identifiable information in order for you to obtain or print any coupon unless required to do so by an Advertiser or if you request a coupon to be sent to your mobile phone.

If I print a RevTrax coupon, does RevTrax know who I am?
No. RevTrax does not know who you are unless (i) you tell us, or (ii) an Advertiser shared your personally identifiable information (such as your name or email address) with RevTrax.

If I print a RevTrax coupon, does the advertiser know who I am?
The Advertiser only knows who you are if you opted in to an email list, loyalty club, or other program run by an advertiser or its third party vendor and provided them with your personally identifiable information.

Does RevTrax sell personally identifiable data?
RevTrax does not sell personally identifiable data. We do publish trend information (e.g. consumers are more likely to print coupons for shoes than for socks) but this is based on aggregated, non-identifiable data.

Does RevTrax profile people by IP address?
No, RevTrax does not profile people by IP address.

Does RevTrax track my browsing history?
No, RevTrax only knows the website and URL that sent traffic to the coupon. For example, if you click on an ad on Google’s website, we would know that Google drove someone to the coupon and any other information contained in that URL.

Does RevTrax use cookies?
Yes. RevTrax uses cookies for fraud control and coupon analytics. When you visit the Public Site, we may send one or more cookies – a small text file containing a string of alphanumeric characters – to your computer. We use persistent cookies. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Public Site. These persistent cookies can be removed, but each web browser is a little different. So, please review your browser’s Help menu to learn the correct way to modify your cookies setup. We do not store in cookies any personally identifiable information you submit while on the Public Site.

RevTrax.com Privacy Policy
Effective Date: 07/14/2010
Last Updated: 06/30/2010

Our Commitment to Privacy

At RevTrax, we respect the privacy of your information and are committed to protecting personally identifiable information that you disclose on our corporate website, www.revtrax.com, and other websites owned by us (the “RevTrax Sites”). This Privacy Policy describes how we collect, use and protect your personally identifiable information on any areas of the RevTrax Sites that host promotions for our Advertisers that are accessible by the general public (collectively, the “Public Site”). If you have an Advertiser account with us, you can view our Privacy Policy covering secure areas of the RevTrax Sites (collectively, the “Secure Site”) by clicking here to login. By using our Public Site, you agree to be bound by the terms of this Privacy Policy. If you do not agree with these terms, do not use our Public Site.

 

Certain Definitions

The terms “we,” “our,” “us,” and “RevTrax” refer to OnCard Marketing, Inc. d/b/a RevTrax, the entity that runs and maintains the Public Site.

The terms “user,” “you,” “your” refer to any individual who uses the Public Site.

The term “Content” refers to any text, graphics, logos, button icons, images, audio or video content, digital or printable downloads, and other materials that may appear on or may be produced by the Public Site.

The term “Advertisers” refers, collectively, to merchants, manufacturers and their agents.

The terms ” promotion” and ” promotions” refer, collectively, to Advertiser product and service offers, including, but not limited to, coupons, virtual gift cards, virtual loyalty cards and other promotions for in-store sales.

The term “personally identifiable information” refers to information that can be used to uniquely identify, contact or locate a single person (such as name, home address, phone number, email address, social security number, credit card number). IP address is not personally identifiable information.

 

1. Collection and Use of Your Information

We use the information that we collect to operate, maintain, and provide to you all of the promotions and offerings found on the Public Site and for administrative purposes (such as for customer service purposes).

 

A. Information We Collect Passively

You can browse certain portions of the Public Site without revealing any personally identifiable information about yourself. We automatically gather general statistical information about the Public Site and its visitors, such as IP addresses, browser type, pages viewed, number of visitors, search terms used in finding the Public Site, but in doing so we do not obtain any personally identifiable information about you. Automatically collected data includes: promotion printing, the website that referred you to us, the web pages you viewed on the Public Site, and the dates and times that you visited the Public Site.  We use the information to statistically analyze Public Site usage, to improve our Content and layout and other similar internal purposes. In addition, IP address may be used to differentiate which promotions are available to you by geographic location and other anti-fraud purposes. We may provide this aggregate, non-identifiable statistical information to third parties.

We may use cookies and IP addresses (i) to prevent fraudulent use of the Public Site, for example, to prevent consumers from taking advantage of a promotion more than once or (ii) to determine how many unique individuals interact with a particular promotion and the type of interaction (e.g. view and/or print). “Cookies” are small pieces of information that are stored by your browser on your computer’s hard drive. Our cookies enable us to facilitate access to different aspects of the Public Site. For example, by showing when and how you and others visit the Public Site, cookies help us to see which pages of the Public Site are popular and which are not. Most web browsers automatically accept cookies, but you can disable this function so that your browser will not accept cookies. Please be aware that disabling this function may impact your use and enjoyment of the Public Site.

 

B. Information You Provide to Us

When you participate in a promotion through the Public Site, we may ask you to provide personally identifiable information or other information that could later be used to identify you. This information is only requested if (a) our Advertisers require us to request such information, or (b) you request a mobile promotion which requires you to enter a mobile phone number. This information is used solely to (a) enable you to obtain the promotion you requested; and (b) to assist us in providing our services to Advertisers. We may collect any information, whether or not personally identifiable, which you choose to provide, including without limitation your (1) e-mail address or (2) name and (3) other personal information required to provide you with the promotion or other information or services that you request, subject to applicable law and the terms of this Privacy Policy.

 

C. Information Provided to Us by Third Parties

This privacy policy addresses only the use and disclosure of information we collect from you through the use of the Public Site. If you disclose your information to a third party or third party website or if a third party website collects your information, different rules may apply to their use and disclosure of such information. We may obtain your personally identifiable information through such third parties if they are an Advertiser, vendor of an Advertiser or vendor of RevTrax. We do not provide personally identifiable information received from a third party to anyone other than the party from whom it was received and their authorized affiliates, vendors or agents.

We provide services to Advertisers to enable, provide anti-fraud and other security measures for, track and analyze the usage of promotions. The Advertiser, not RevTrax, is responsible for the distribution, content and other terms of the promotions. RevTrax provides the Advertiser and its vendor with an analysis of each promotion.

 

D. Information Provided by Advertiser or its vendor to Generate Promotions

Information may be collected by Advertisers, via the Advertiser’s website or otherwise, and provided to us. We store and use this information for the purpose of generating, securing, tracking and analyzing the usage of promotions. The information may include, but is not limited to, the search terms used to find the promotion, IP address, name and/or email address. In some cases the promotion may be displayed on the Public Site, or another website owned by RevTrax and used for this purpose. Any personally identifiable information used to generate a promotion is provided by the Advertiser or its vendor.

 

E. Information Provided by Advertiser or its vendor to Monitor Promotion Redemption 

Advertisers may also provide us with information gathered when a promotion is redeemed as part of a sales transaction. This information may include but is not limited to the location, business name, date, and/or time the promotion was redeemed, in addition to other transaction details. We may combine this information with information previously provided by the Advertiser and/or its vendor, to analyze and summarize the information, as well as provide one or more reports to the Advertiser and/or its vendor on the effectiveness of its promotion programs.

 

F. Information Provided by Other Third Parties

We may also receive information from third-party vendors working with Advertisers to distribute their promotion offers, including online rewards programs or other types of incentive programs. This information may include but not be limited to registration and/or other membership information linking you with a particular program or certain personally identifiable information. We may combine this information with the information provided by Advertisers to link a particular promotion with an individual participating in a particular third-party vendor program. RevTrax does not knowingly provide an Advertiser with personally identifiable information provided to it by the third party vendor unless prompted by the vendor to do so.

 

G. Our Use of Information Provided by Third Parties

REVTRAX COLLECTS PERSONAL INFORMATION FROM INDIVIDUALS (A) DIRECTLY ONLY IF THEY PROVIDE SUCH INFORMATION TO US AND (B) IN CONJUNCTION WITH THEIR USAGE OF THE PUBLIC SITE. REVTRAX’S USE OF ANY PERSONAL INFORMATION PROVIDED BY ADVERTISERS OR OTHER THIRD PARTIES IS SOLELY LIMITED TO PROVIDING THESE PARTIES WITH SERVICES RELATING TO PROMOTION PROGRAMS, INCLUDING GENERATING, TRACKING AND ANALYZING THE USE OF THE PROMOTIONS. REVTRAX DOES NOT SHARE ANY PERSONALLY IDENTIFIABLE INFORMATION PROVIDED BY A PARTICULAR ADVERTISER WITH ANY OTHER ADVERTISER, UNLESS BOTH ADVERTISERS ARE UNDER COMMON CONTROL.

THIS PRIVACY POLICY DOES NOT APPLY TO ANY INFORMATION COLLECTED BY ADVERTISERS OR OTHER THIRD PARTIES AND SUBSEQUENTLY PROVIDED TO REVTRAX. REVTRAX IS NOT RESPONSIBLE FOR THE PERSONAL INFORMATION COLLECTED BY ADVERTISERS OR OTHER THIRD PARTIES. THE COLLECTION AND USE OF YOUR INFORMATION ON AN ADVERTISER OR OTHER THIRD PARTY SITE OR BY AN ADVERTISER OR THIRD PARTY MAY BE GOVERNED BY THE PRIVACY POLICY ON THE RESPECTIVE SITE OR OF THE RESPECTIVE PARTY. REVTRAX IS NOT RESPONSIBLE AND CANNOT CONTROL THE ACTIVITIES OF ANY ADVERTISER OR OTHER THIRD PARTY. YOU SHOULD CONSULT THE PRIVACY POLICY ON EACH ADVERTISER OR OTHER THIRD PARTY WEBSITE FOR SUCH ADVERTISER’S OR OTHER THIRD PARTY’S POLICIES ON DATA COLLECTION AND USE.

 

H. How We Disclose Information

We maintain full rights to any information collected on the Public Site, and may freely collect, use, transfer and disclose such information unless prohibited by this Privacy Policy, applicable law or our obligations under any agreement with an Advertiser. RevTrax does not sell any personally identifiable information. RevTrax does not share any personally identifiable information except in the manner described in this Privacy Policy. We disclose certain automatically collected data (such as promotion print and redemption activity) to our Advertisers and under certain circumstances Advertiser’s vendors. These third parties may match this data with information that they have previously collected about you under their own privacy policies, which you should consult on a regular basis. RevTrax may share non-personally identifiable, aggregated or summarized information with third parties. We may disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with local, state or federal laws or to respond to a court order, judicial or other government subpoena, or warrant. We also reserve the right to disclose information that we believe, in good faith, is appropriate or necessary to take precautions against liability; protect Advertisers from fraudulent, abusive, or unlawful uses; to investigate and defend ourselves against any third-party claims or allegations; to assist government enforcement agencies; to protect the security or integrity of the Public Site; and to protect against fraudulent uses, the rights, property, or safety of the company, you, our Advertisers, or others.

 

2. Our Commitment to Data Security

 

A. Protecting Your Information

We use commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. WE CANNOT, HOWEVER, ENSURE OR WARRANT THE SECURITY OF ANY INFORMATION YOU TRANSMIT TO US, AND YOU DO SO AT YOUR OWN RISK. Once we receive your transmission of information, we make commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
No data transmission over the Internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we try to protect your personal information, we cannot ensure or guarantee the security of any information you transmit to us, and you do so at your own risk.

 

B. In the Event of a Security Breach of Your Personal Information

If we determine that your personal information has been disclosed due to a security breach of our systems, we will work with our Advertisers to notify you within a reasonable time in accordance with applicable state and federal laws, so long as the notification would not interfere with a criminal investigation.

 

3. Children’s Privacy

Protecting the privacy of young children is especially important to us. As such, we do not knowingly collect or maintain information from persons under 13 years of age. If we learn that personally identifiable information of persons under 13 years of age has been collected on the Public Site, we will take the necessary steps to delete the information. If you are under 13 years of age, then please do not use or access the Sites at any time or in any manner.

 

4. Special Note to International Users

The Public Site is hosted in the United States and are intended for and directed to users in the U.S. If you are accessing the Sites from the European Union, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure that differ from U.S. laws, please be advised that through your continued use of the Public Site, which is governed by U.S. law and this Privacy Policy, you are transferring your personal information to the U.S. and you consent to that transfer.

 

5. In the Event of Merger or Sale

In the event that we are acquired by or merged with a third-party entity, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from you as part of such merger, acquisition, sale or other change of control.

 

6. Changes and Updates to this Privacy Policy

This Privacy Policy may be revised periodically, and this will be reflected by the “last modified” notice below. If we decide to change our Privacy Policy, we will post those changes to this privacy statement, the homepage, and/or other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our homepage. In general, we only use your personal information in the manner described in the Privacy Policy in effect when we received that personal information. YOUR CONTINUED USE OF THE SITES CONSTITUTES YOUR AGREEMENT TO THIS PRIVACY POLICY AND ANY FUTURE REVISIONS.

 

7. Contact Us 

RevTrax
404 Park Avenue South, 2nd Fl.
New York, NY 10016
Attn: Privacy

Email: privacy@revtrax.com