Privacy FAQ — 2012

Consumer privacy is a top priority. That’s why we designed the RevTrax® platform. RevTrax provides Advertisers with anti-fraud and other security measures and analytics for promotions. The Advertiser, not RevTrax, is responsible for the distribution, content and other terms of the promotions.

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. You may also be asked for your friends’ email addresses if you opt to participate in a social sharing coupon promotion.

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) a merchant 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 concurrently opt in or previously opted in to an email list, loyalty club, or other program run by an advertiser or one of its third party vendors 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 track my browsing history?
No, RevTrax only knows associated method (such as the specific search term, ad, website and URL) that sent traffic to the coupon and if you go to the coupon more than once. 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.

RevTrax.com Privacy Policy

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.

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 or 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 views and prints, the website that referred you to us and any other information passed in the URL, 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, for other anti-fraud purposes and to analyze coupon data by geographic region. We provide information on views, prints, referring domains and other associated data to the applicable Advertiser and, if requested by the Advertiser, to its vendors and agents. We may provide aggregate, non-identifiable statistical information to third parties and use it to publish market studies.

In addition, we may use (a) IP addresses, (b) cookies, flash cookies (aka Flash Local Shared Objects), (c) Java applets, (d) referral headers or (e) pixels, and in each case other similar data and methods (together the “Security Methods”) (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, the type of interaction (e.g. view and/or print) and other promotion statistics and analytics. “Cookies” and “Flash Cookies” are small pieces of information that are stored on your computer’s hard drive. Our Security Methods 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, it helps us to see which pages of the Public Site are popular and which are not. Most web browsers automatically accept our Security Methods, but you can disable these functions. Please be aware that disabling these functions 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, (b) you request a mobile promotion which requires you to enter a mobile phone number, or (c) you opt to participate in a social sharing promotion. This information is used solely to (a) enable you to obtain the promotion you requested; (b) to assist us in providing our services to Advertisers and (c) in the case of social sharing promotions, (i) send the promotion to the third parties you enter in the promotion, and (ii) enable you to receive a higher level promotion. 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.

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

Information may be collected by Advertisers, via the Advertiser’s website, Advertiser’s vendors 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.

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 vendors, to analyze and summarize the information, as well as provide one or more reports to the Advertiser and/or its authorized vendors on the effectiveness of its promotions.

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, membership 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.

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. NOR DOES THIS PRIVACY POLICY APPLY TO INFORMATION ONCE IT HAS BEEN PROVIDED TO AN ADVERTISER OR OTHER THIRD PARTY AT THE DIRECTION OF THE ADVERTISER. REVTRAX IS NOT RESPONSIBLE FOR THE PERSONAL INFORMATION COLLECTED OR USED 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 discloses certain automatically collected data (such as promotion view, 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 or have required us to collect on their behalf 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 of, and protect 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 reasonable physical, managerial and technical safeguards to preserve the integrity and security of your personal information. WE CANNOT AND DO NOT, HOWEVER, ENSURE, WARRANT OR GUARANTEE 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 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 and will notify you 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 NOT A U.S. CITIZEN AND/OR ACCESSING THE SITES FROM THE EUROPEAN UNION, CANADA OR ANY OTHER COUNTRY WITH LAWS OR REGULATIONS GOVERNING PERSONAL DATA COLLECTION, USE AND DISCLOSURE THAT DIFFER FROM U.S. LAWS, PLEASE BE ADVISED THAT THROUGH YOUR 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 AND THE TERMS OF U.S. LAWS AND THIS PRIVACY POLICY.

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 the revised privacy policy here 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. YOUR CONTINUED USE OF THE SITES CONSTITUTES YOUR AGREEMENT TO THIS PRIVACY POLICY AND ANY FUTURE REVISIONS.

7. Contact Us 

RevTrax
276 Fifth Avenue
Suite 608
New York, NY 10001
Attn: Privacy Officer
Email: privacy@revtrax.com

Last Modified: 8/26/12