Privacy FAQ — 2013

Privacy FAQ

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 email or mobile phone. You may also be asked for additional information, such as your friends’ email addresses or mobile numbers, 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 by providing personally identifiable information in order to receive a promotion 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.


Our 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. We also use general geographic location information 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 or required to run a promotion (as in the case of social, mobile or email promotions), to certain third party 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 our cookies using standard methods for your browser. Please be aware that disabling these functions may impact your use and enjoyment of the Public Site, including but not limited to preventing you from viewing and/or printing a promotion.

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 promotion which requires you to enter a mobile phone number or email address, or (c) you opt to participate in a social sharing promotion or survey. 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, to (i) send the promotion to the third parties you enter in the promotion, and/or (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, (3) phone number and (4) 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. We will never ask you for your social security number or credit card information.

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, clients 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, mobile number, 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 us and our 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, including but not limited 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 our and our 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, our 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 vendors to 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. California Online Privacy Protection Act (“CalOPPA”)

The RevTrax Sites do not currently actively respond to “Do Not Track” browser signals or mechanisms.

5. 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.

6. 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.

7. 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. We reserve the right to modify this privacy statement at any time, so please review it periodically. 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: 03/03/14


Terms and Conditions

Welcome to the RevTrax® terms and conditions. If you continue to use this website or any coupon, discount or promotion (each a “Promotion”) displayed or provided theron, you are agreeing to comply with and be bound by the following terms and conditions of use (the website’s “Terms and Conditions”), which together with our privacy policy govern our relationship with you (the “Governing Agreements”). If you disagree with any part of these terms and conditions, please do not use our website or the Promotions.

The term ‘RevTrax’ or ‘us’ or ‘we’ refers to the owner of the website whose registered office is 276 Fifth Avenue, Suite 608, NY, NY 10001. The term ‘you’ and ‘your’ refers to the user or viewer of our website and/or promotions.

The use of this website and/or promotions is subject to the following Terms and Conditions of use:

  • You are permitted to use this website solely to (i) view and print certain Promotions of our customers (collectively, the “Customers”); (ii) send the Promotions to your own or a third party’s email account or mobile phone; or (iii) share a Promotion using Facebook, Twitter or other social media options available via RevTrax’s OpenShare® feature.
  • You agree that you are over age thirteen (13) and are legally permitted to use the website and/or Promotions.
  • You agree that all information entered by you into the website shall be accurate and valid.
  • You agree to utilize the website and Promotions in accordance with all laws, regulations and privacy policies, including but not limited to CAN-SPAM.
  • You agree not to copy, reverse engineer or otherwise misuse the website and/or any Promotion, including but not limited to reposting, copying or otherwise redistributing any Promotion in a manner not authorized by RevTrax or the Customer.
  • You agree not to alter, modify or otherwise change in any manner or medium the Promotion as it appears on the website.
  • You acknowledge and agree that RevTrax owns and shall retain all right, title and interest in its (a) trade names, logos, trademarks, service marks, trade dress, copyrights, patents, patent applications, trade secrets and other proprietary rights (the “RevTrax Intellectual Property”) on the website, and (b) all information, text, graphics, audio, images, photographs, illustrations, bar codes, designs, ideas, processes, methodologies, forms and formats, materials, software, Internet domain names, arrangement of content, distinctive and original layout and presentation of website, aggregated data and reports, and any derivative works or enhancements to any of the foregoing (together with the RevTrax Intellectual Property, the “RevTrax Property”). All discoveries, improvements, and inventions that are related to the RevTrax Property or Services shall be the sole and exclusive property of RevTrax. Any rights not expressly granted herein are deemed withheld.
  • You acknowledge and agree that REVTRAX SPECIFICALLY DISCLAIMS ANY REPRESENTATIONS OR WARRANTIES, EXPRESS OR IMPLIED, INCLUDING WITHOUT LIMITATION, WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT AND ANY IMPLIED WARRANTY ARISING FROM COURSE OF PERFORMANCE, COURSE OF DEALING OR USAGE OF TRADE. REVTRAX ASSUMES NO RESPONSIBILITY FOR YOUR OR ANY OTHER PERSON’S USE OF THE WEBSITE, THE PROMOTIONS OR ITS CUSTOMERS’ PRODUCTS OR SERVICES. REVTRAX DOES NOT WARRANT THAT THE WEBSITE OR PROMOTIONS WILL BE UNINTERRUPTED OR ERROR FREE.
  • You agree to indemnify, defend and hold harmless RevTrax from all claims, damages, costs and expenses arising from your misuse of the website and Promotions.
  • The content of all pages of this website is subject to change without notice.
  • This website uses cookies to monitor your activities on this website. Please see our privacy policy for further information.
  • Unauthorized use of this website my give rise to a claim for damages and/or be a criminal offense.
  • From time to time, this website may also include links to other websites. These links are provided for your convenience to provide further information. They do not signify that we endorse the website(s). We have no responsibility for the content of the linked website(s).
  • RevTrax or its Customers use its third party email and SMS vendors to distribute the Promotions. You are responsible for reviewing and understanding the privacy and other policies of the Customer and such third party vendors.
  • You understand that SMS Promotions may be subject to standard data and other fees from your SMS provider.
  • These Terms and Conditions and your use of the website are governed by and subject to the laws of the State of New York, without regard to its conflict of laws provisions. Furthermore, you agree to the exclusive jurisdiction of the courts located in New York, New York for all matters arising out of your use of this website and/or the Promotions.
  • Questions regarding these terms and conditions can be addressed to privacy@revtrax.com.

Contact Us

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

Last Modified: 3/6/13