Effective from Jan 23, 2018.
1.Introduction
This Privacy Policy explains how SMTPCOUPONS, formerly known as Coupons.com Incorporated (together with our subsidiaries, “SMTPCOUPONS,” “we” or “our”), collects, uses, and shares your Personal Information (as defined below). This Privacy Policy applies to the websites, services, and mobile and software applications we own or control (the “Services”), including emails and designated portions of third party websites and applications that link to or reference this Privacy Policy.
By using any of the Services, you are agreeing to the terms of this Privacy Policy and the Terms of Use into which it is incorporated. If you do not agree to this Privacy Policy, you should not use any of the Services or provide to us any of your personal information. If you have questions regarding this Privacy Policy, please contact us via email at privacy@SMTPCOUPONS.com, or in writing at the following address:
SMTPCOUPONS.
Attn: Privacy
Email: info@smtpcoupons.com
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) here.
Our Services may include links to third-party websites, applications and services, and embedded third-party tools and widgets. Any third-party collection and use of your information is governed by the privacy policies of the respective third parties. We encourage you to learn about the privacy practices of those third parties.
2. Updates
We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes, including changes to how we share personal information, we will notify you by email or by providing notice on or through the Services prior to the change becoming effective.
3. What Information Do We Collect And Use?
(a) Information You Provide
“Personal Information” means information that can be used on its own or with other information to identify, locate, or contact a specific individual, together with associated information. If you create any type of account, download software, or participate in certain activities on the Services (such as surveys, sweepstakes, contests, or other promotions), we may ask you to provide us with Personal Information that can be used to specifically identify, locate, or contact you, such as: your name, email address, postal mailing address, or telephone number. You may also have the option of providing us with other information about yourself or your household that may be associated with information that identifies you, such as payment card number, retailer loyalty card number, age or date of birth, gender, interests, product purchase information or receipts, zip code, and product or content preferences (including saved offers and content favorites). It will always be your decision whether to directly provide to us your Personal Information. In some cases, if you decline to share Personal Information with us, then we may not be able to provide you with certain Services, and you may not be eligible for certain sweepstakes, contests, or other promotions. For example, in order to use our Card Linked Offers, you must provide your email address and payment card number, in addition to other requirements. For information about how we handle user-submitted content, see Section 8.
(b) Information Automatically Collected As You Access and Use the Services
When you use or interact with the Services in any way, we may use cookies, web beacons, pixel tags, log files, local storage, and other similar mechanisms to automatically collect information, including:
Your activity on the Services (such as pages viewed, searches performed and features accessed);
Operating system, web browser information, and device attributes;
Inbound-referral and outbound websites;
Your internet protocol (“IP”) address;
How you interact with coupons, advertisements and other content available on or through the Services, such as whether you print a coupon or load a Card Linked Offer to a payment card;
The dates and times that you visited or used the Services, or requested certain services or transactions;
Location information (see Location Services in Section 3.e below); and
Advertising identifier associated with your mobile device.
An anonymous identifier or Personal Information may be associated with the information collected using cookies and similar technologies. If you are accessing the Services from a mobile device, see Section 3.e for additional automatically collected information.
Device Information and Identifier. When you use our Services or install on your computer or other device our coupon printing software, mobile applications, or one of our toolbars, we may collect and store information about that device that helps us manage our products and services, deliver a more customized experience for you, and detect and prevent fraud. If you download the coupon printing software, a device identifier remains associated with that device even after uninstalling the software. This identifier is used primarily to prevent fraud. If you print a coupon using our download-free print technology, we will create an identifier for your print activity, and a persistent identifier will be associated with any device you authenticate using your phone number.
Cookies and Web Beacons. A cookie is a small text file or identifier. When you visit a Site, we may store one or more cookies or other similar information on your device. We use cookies for the purposes described in Section 4, including for advertising. Our Cookie Policy provides additional resources on cookies, and information about how to opt-out from certain interest-based advertisements. We use both session cookies and persistent cookies. A persistent cookie remains after you close your browser and may be used by your browser on subsequent website visits. These persistent cookies can be removed, but each web browser is different. Please review your browser’s settings to learn how to manage your cookies. Our Services may also use web beacons (also known as clear gifs or pixel tags), which are tiny graphics with unique identifiers that are placed in the code of a webpage.
Third-Party Cookies and Similar Technologies. We allow third-party companies to use cookies, pixels or other similar technologies on our Services to collect and use non-personally identifiable information (e.g., hashed data, click stream information, browser type, time and date, subject of advertisements clicked or scrolled over, content viewed, search terms, location of the device, a cookie identifier, communication type (broadband or dial-up), and browser-related properties). These third parties include advertisers, service providers, affiliate-marketing networks and other companies with whom we partner to provide certain offers, promotions or features available on or through our Services or third party properties, or to display advertising on the Services or third party properties. Such third parties may use cookies to provide advertisements about goods and services likely to be of greater interest to you, to track off-Site transactions and to assist us in providing, evaluating, and improving the Services and our other products and services. Further, such third parties may use information they directly collect from you in combination with information we provide (as described in Section 5) or information they collect from another source. In some cases, we may not have access to or control of the third-party tracking technology. To learn more about interest-based advertising and your choices regarding third-party cookies.
Log Files and Local Storage (HTML5/Flash Cookies). As is true of most websites, we gather certain information automatically and store it in log files. This information may include IP addresses, browser type, internet service provider (“ISP”), referring/exit pages, operating system, date and time stamp, and clickstream data. We use this information to manage and operate our products and services, to offer you more personalized content and advertising, and for the other purposes described in Section 4 below.
Certain Services may use local shared objects, such as Flash cookies, and local storage, such as HTML5, to store content information and preferences. Third parties may also use Flash cookies or HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5.
Analytics. We may use our own and third party tracking and analytics tools to better understand who is using our Services and how they are using them. These tools may use cookies and page tags to collect information such as time of visit, pages visited, time spent on each page of the website, IP address, and type of operating system used. One of the analytics tools we may use is Google Analytics. You can learn how to opt-out of the Google Analytics tracking software here.
(c) Information From Third Parties
We may receive information from third parties about you, including Personal Information, cookies and other identifiers that do not personally identify you, and information about in-store and online transactions. We may use this information to administer the applicable program or service, to offer you more personalized content and advertising, and for the other purposes described in Section 4 below.
(d) Information You Provide About a Third Party
If you choose to use any of our referral services to tell someone else about our Services, or to email a promotion, we will ask you for that person’s name and email address. We will use the information you provide to automatically send to that person the referral, such as an email inviting him or her to the Services you recommended. We do not share this email with any third party, other than those third party service providers used to transmit the referral.
(e) Information From Use Of Our Mobile Websites and Applications
In addition to other information described above, when you download or use one of our mobile applications, or access the Services through a mobile device, we may automatically collect information about your location and your mobile device, including your operating system, device type, and device identifier. We may also request access to the device storage and camera, and permission to send you push notifications. You may decline to provide location information, storage and camera access, and push notification permission at any time using your mobile device’s system settings. Please consult your mobile device’s instruction manual for additional information about controlling system and application settings.
4. How We Use Your Information
We may use information that we collect for the following purposes:
Operate, maintain, and improve the Services and our other products and services;
Communicate with you about the coupons, advertisements, promotional offerings, and other content found on and off our Services;
Process and facilitate coupon printing, loading, and redemption activity;
Manage and store shopping lists;
Monitor and improve marketing and promotional campaigns and efforts;
Provide you with a personalized experience on and off the Services, including targeted advertisements and promotions;
Anonymize and aggregate information for different purposes, such as website traffic flow analysis, usage analysis, product development, market analysis, case studies, reports, insights, and marketing;
For administrative purposes, such as customer service and sweepstakes administration or responding to your inquiries;
Comply with our legal obligations, resolve disputes, and enforce our agreements; and
Share information as described in this Privacy Policy.
We may combine information about you collected across different Services and devices, and we may combine information we obtain with information obtained from third parties. We may make inferences based on this combined information, such as product preferences and interests. We retain all information we collect about you for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.
5. When We Share Information
(a) We may share Personal Information and other information collected or obtained about you with our affiliates (subsidiaries or other companies owned or controlled by SMTPCOUPONS). In all cases, the affiliates will only be able to use the information as set forth in Section 4 above.
(b) We may work with other companies to operate, maintain and deliver the Services and the content, services and features available on and off the Services, including to provide personalized coupons and advertisements, for contests and sweepstakes, and to communicate with you by email, SMS text message, or push notification. In such circumstances, those companies will have access to the information needed, including Personal Information, to provide the applicable service, content or feature on our behalf, but they will not be permitted to use the information for any other purpose, except for the aggregation and other purposes set forth in Section 5.e. For instance, if you provide to us a retailer loyalty number in order to load a coupon we distribute to your loyalty card, we will provide the retailer with the loyalty card number and other information necessary to fulfill your load request. The retailer may then match this information with other information in its possession.
(c) We may share Personal Information with other companies with your consent or as part of a specific program or feature provided in partnership with a third party. If you choose to participate in such program or feature, we authorize those third parties to use your Personal Information. For example, we offer coupons on or through our Services that require you to fill out an advertiser survey in order to receive the coupon. If you choose to participate in the survey, then we will share the information you provide with the advertiser who provided the survey. You may also be given the option to sign up for promotional emails from a third party. In order to fulfill your request, we will provide your email address to the applicable third party. In addition, we may share your Personal Information with third parties to obtain associated information, including cookies and other identifiers that do not personally identify you, and for marketing on our behalf. In such cases, the third party would be restricted from using your Personal Information for other purposes not associated with our Services.
(d) We may share information that does not specifically identify an individual, and cannot be used to contact or locate a specific individual (such as a cryptographic hash of an email address, certain cookies, age, gender, household income, interests, zip code, state, coupon activation and redemption data, purchase data, and other automatically collected information) with third parties for advertising and promotional use. A third party may match such information with information you have previously provided to that party, or other information that party has obtained. We also may share information that does not specifically identify you with third parties that use cookies or other similar technologies on our Sites so that they can tailor advertisements to your apparent interests and deliver those advertisements to you while you are either using our Services or on third-party websites. For example, if you print pet food coupons, then we may conclude that you have a pet and show you a pet care supply advertisement instead of a random advertisement. For additional information about interest-based advertising and how to opt out of certain types of advertising.
(e) We may aggregate Personal Information (excluding Personal Information that specifically identifies an individual, or that can be used to contact or locate a specific individual) or de-identify Personal Information, and share such aggregated or de-identified information with third parties; we may also share such aggregated or de-identified information publicly to provide information about general use of our Services. In addition, we may permit our third-party service providers and vendors that collect Personal Information in connection with performing functions or providing Services on our behalf to aggregate that Personal Information (excluding Personal Information that specifically identifies an individual, or that can be used to contact or locate a specific individual) or de-identify that Personal Information, to improve their own products and services or for their internal business and research purposes and we may permit such third parties to share such aggregated or de-identified information publicly to provide information about their services.
(f) In the event that we are acquired by or merged with a third-party entity, we reserve the right, to transfer or assign the information we have collected from you as part of such merger, acquisition, sale, or other change of control. You will be notified by email or a prominent notice on our Services of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.
(g) We may share information about you 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 governmental subpoena or warrant, or in the event of bankruptcy proceedings. For example, where required by law, we will publicly disclose information about the winners of sweepstakes and contests. We also reserve the right to share information when we believe, in good faith, it is appropriate or necessary to protect us or the third parties we work with from fraudulent, abusive, or unlawful uses, investigate and defend ourselves against any third-party claims or allegations, assist government enforcement agencies, protect the security or integrity of the Services, and to protect our rights, property, or safety and those of the third parties we work with.
6. Your Choices
Please contact us using this form to determine whether we control any Personal Information that is associated with your email address. If SMTPCOUPONS receives information about you from a third party, you will need to contact that third party directly to manage your information.
Site Accounts. If you registered a password-protected account with us, you may modify or correct your Personal Information and preferences at any time by logging into this account or by contacting us using this form. We will respond to you within 30 days from the date you contact us. If there is Personal Information that we cannot fully modify or delete upon your request, we will provide you with any available options.
Emails. You can opt-out of marketing coupon email alerts and other emails such as newsletters by following the instructions included in our emails to you, or by contacting us using this form. In addition, you can change your preferences for certain Coupons.com emails by logging into your Coupons.com account and going to “Email Settings” or “Alerts.” For Definitive Deals promotional emails, you can update your email preferences using the “Unsubscribe” or “Update Your Profile” links contained in the footer. Please note that if you opt out from all promotional emails, we may still send you transactional or administrative messages.
Interest-Based Advertising. Our advertising partners, vendors and other third parties may track your online activities and collect information for use in providing content and advertising tailored to your interests. For information about how to opt out of receiving certain behavioral advertisements.
7. Registration via Third Party Accounts and Social Media Sharing
You may be given the opportunity to register with us via third party accounts such as Facebook. These services will authenticate your identity and may provide you the option to share certain information (such as your name and email address) with us. We may store the information you provide us through such accounts and combine it with other information, including Personal Information. Disabling your Facebook or other such account may not terminate your account with us.
Our Services may also include social media features, such as sharing widgets provided by Facebook, Twitter, Google and Pinterest. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy policy of the company providing them.
8. Community Forums/Blogs; User-Generated Content
We may offer features that allow users to post comments, recipes, photos, video and other user-generated content to public areas within the Services (“Community Forums”). By default, when you post content to a Community Forum, it is public. In addition, your account name and photo may be associated with the content, and if so, may be displayed publicly. Your user profile may also link to your public profile from a third party account if you registered with us through Facebook or other such service. Please take special note that your user profile and any user-generated content that you post, including any Personal Information, are intended for public consumption, will be publicly accessible and will not be considered confidential. We may display user-generated content on our Services, including comments and recipes, and we or our users may share such content with third party sites and services. To request removal of your Personal Information from any Community Forum, please contact us. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.
9. Our Commitment to Data Security
The Services may use various physical, electronic, and administrative procedures to safeguard the confidentiality of your Personal Information. Additional security measures, such as Secure Sockets Layer (“SSL”) or other technology, will be used if you engage in financial transactions on our Services. However, as no security measures are perfect or impenetrable, we cannot guarantee the security of any information you transmit to us or that unauthorized access or theft of data might not occur.
For features on our Services that require a login or password, it is important for you to protect against unauthorized access to your password and your computer or mobile device. Use strong logins and passwords that are difficult to guess and change your logins and password periodically. Be sure to sign off when finished using a shared computer. Please notify us immediately if you think your account or login or password has been compromised.
10. Our Commitment To Children’s Privacy
The Site is not designed for use by anyone under the age of 13, and any use or access of the Site by anyone under the age of 13 is strictly prohibited. If we learn that personally identifiable information of a user under the age of 13 has been collected through the Services, then we will take the appropriate steps to delete this information.
11. Special Notice to Users Outside The United States of America Regarding International Transfers
The Internet is a global environment and SMTPCOUPONS is an international business with headquarters in the United States of America (“U.S.”) and so the personal information it collects about you may be processed in any of the countries where SMTPCOUPONS, its service providers or business partners operate, including the U.S. The data protection laws of these countries may be different to the laws of the country where you are resident, but SMTPCOUPONS will protect your personal information strictly in accordance with this Privacy Policy at all times, wherever it is processed. Therefore, by using our Services and communicating electronically with us, you acknowledge and agree to our processing of your information in this way.