(Last Updated June 26, 2020)
- Information We Collect
- How We Use Information
- Disclosure of Personal Information
- Updating Your Personal Information and Information Retention
- Security of your Personal Information
- Links to Third-Party Websites and Applications
- Do-Not-Track Settings
- Children Under 13
- Consent to Processing and Transfer of Information
- Changes to this Policy
Information We Collect
- Information You Provide
In general, you may visit the Website or download the Application without telling us who you are or sharing any Personal Information with us. When you register for an account for the Services (an “Account”), use other aspects of the Services, or communicate with us for customer service or technical support for the Services, we may ask you to provide certain Personal Information, such as your name, email address, postal address, mobile number, Payment Card information, birth date, and gender. Additionally, if we are required by law to send to you and file certain forms with tax authorities, we may ask you to provide us or our service provider certain personal information.
In certain circumstances, we are required to collect Social Security Numbers or Taxpayer Identification Numbers in connection with an individual’s participation in the Services. This information is required by law for governmental and tax purposes. It is our policy to protect the confidentiality of Social Security and Taxpayer Identification Numbers. We use these types of data to carry out our business needs and to comply with local, state and national governmental requirements including tax reporting, among other things. We do not use this information for identification purposes.
Any Personal Information that you provide is available to us and may be available to third-party service providers involved in the operation of the Services. Although we contractually require our third-party service providers to protect your Personal Information, please note that we do not own or control such providers and cannot guarantee their compliance.
- Information We Collect Automatically
- Usage Information. myGini may use a variety of technologies that passively or automatically collect information about how the Services are accessed and used, including your browser type, device type and manufacturer, operating system, application version, the pages served to you, the time you browse, preceding page views, and your use of particular features of the Services. This statistical data helps us understand what is interesting and relevant to users of the Site so that we can best tailor our content to you.
- Device Identifiers. myGini also automatically collects an IP address or other unique identifier, mobile carrier, and mobile phone number, for the computer, mobile device, technology or other device (collectively “Device”) you use to access the Services. A “Device Identifier” is a number that is automatically assigned to your Device when you access a web site or its servers, and our systems identify your Device by its Device Identifier. We may use a Device Identifier to, among other things, administer the Services, help diagnose problems with our servers, analyze trends, track users’ web page movements, and gather broad demographic information for aggregate use.
- Location Information. In addition, if you download the Application to your mobile Device, we may collect information from your mobile Device about your location while you are accessing or using the Application and while you are not accessing or using the Application. We may use this information to provide targeted offers to you and notify you of nearby third-party locations where you may use the Services. You may opt out of the collection of location data at any time by changing your settings on your mobile Device. However, if you do so, certain features of the Services may not be available to you or the performance of certain features of the Services may be limited or not work at all. We may also collect anonymized information, including anonymized Device Identifiers, from third-party devices present at certain third-party locations, such as retail stores, restaurants, and other points of interest. Such devices may use wifi, near field communication (NFC), or Bluetooth low-energy (BLE) beacon technology to transmit signals about the location of your Device to us so that we may notify you via push message that you are near a location where you may use the Services.
- Information We Collect Automatically
If you would prefer not to accept Session Trackers when using the Site, follow the instructions provided by your website or mobile browser (usually located within the “Help”, “Tools,” or “Edit” facility) to modify your Session Tracker settings. Please note that if you disable Session Trackers, you may not be able to access certain parts of our Site and other parts of our Services may not work properly.
- Web Beacons. In addition to Session Trackers, we may use web beacons, which are transparent graphic images placed on a web page or in an email and indicate that a page or email has been viewed or tell your browser to get content from another server. We use web beacons to measure traffic to or from, or use of, our online forms, tools, or content items and related browsing behavior and to improve your experience when using the Services. We may also use customized links or other similar technologies to track hyperlinks that you click and associate that information with your Personal Information in order to provide you with more focused communications
- Click-Through URLs. In some of our Communications to you, we may use “click-through URLs” linked to content on the Application. We track click-through data to help us understand and analyze interest in topics and use of the Services.
- Non-Personal Information
Additionally, we may modify and combine Personal Information in a manner that does not personally identify you or any other individual and thus, no longer constitutes Personal Information. We may use this non-Personal Information, such as aggregate user statistics, demographic information, and usage information, for any lawful purpose.
- Information from Third Parties
- Information Collected from Payment Card Networks and Transaction Monitoring. When you link an eligible credit or debit card (a “Payment Card”) to your Account, we may collect Personal Information, including transaction information, from your Payment Card Network (e.g., Visa, Mastercard, American Express, Discover). By registering a Payment Card to your Account in connection with transaction monitoring, you authorize: (i) myGini to share your Payment Card information with the third parties that enable us to provide the Services, such as Empyr, or Plaid (“Third-Party Service Providers”) and your payment card network so it knows you enrolled for the Services; and (ii) the payment card network to (A) monitor transactions on your Payment Card(s) to identify Qualified Purchases in order to determine whether you qualify for or earn an Offer linked to your Payment Card(s) in connection with the Services; and (B) share such transaction details with myGini to provide the Services to you. You authorize the relevant payment card network(s) to monitor transactions on your registered card(s) to identify qualifying purchases in order to determine whether you have qualified for or earned an offer linked to your Payment Card, and for your payment card network to share such transaction details with myGini to enable your card-linked offer(s) and target offers that may be of interest to you. . You may opt-out of such transaction monitoring on the Payment Card(s) you have registered by de-linking them through the Services or by terminating your Account. To terminate your Account and your right to use the Services at any time and for any reason and for no reason, de-link all your linked cards and delete the myGini App from your mobile Device and immediately discontinue all use of the Services. Please note that if you opt-out of transaction monitoring, certain features of the Services may not be available to you or the performance of certain features of the Services may be limited or not work at all.
- Information from Third Parties
- to confirm a Qualified Purchase or return to match transactions to confirm whether you qualify for an Offer or statement credit;
- to create a record of the transaction information and thereafter maintain and use data in connection with the Services;
- to provide targeted offers that may be of interest to you;
- to conduct analysis for the improvement and optimization of the Services;
- to inform participating merchants where a transaction occurred as needed for the merchant to confirm a specific transaction occurred or points should be awarded; for example, we may share the date and amount of your purchase and the last 4 digits of your card number so the merchant can verify your purchase with its records or confirm if there is a missing or disputed transaction;
- to provide participating merchants aggregated and anonymized information relating specifically to registered Payment Card activity solely to allow participating merchants to assess the results of their campaign;
- to provide information in order to respond to a request from government authority or a payment organization involved in a transaction with you or a merchant; and
- to enable the sharing, exchange and use of transaction information described above and herein by and among us, the payment card networks, applicable Third-Party Service Providers, including Empyr, Inc., and applicable merchants.
Information from Merchants. We may receive information about transactions you make at select merchants including the merchant’s name, location, the date and time of the purchase, the transaction amount, the purchased items, and other Personal Information about you.
How We Use Information
- provide the Services and Communications related thereto;
- analyze, improve, and customize the Services;
- provide customer and technical support for the Services;
- evaluate the types of Offers, products, or services that may be of interest to you and provide you with Offers from participating merchants that are more relevant to you, including Offers based on variables such as placements or searches, past Offer redemptions, or user location;
- send you announcements, newsletters, promotional materials, and other information about the Services and third-party products and services that we think may be of interest to you;
- detect, prevent and investigate actual or suspected fraud, hacking, infringement, or
other misconduct involving the Services;
- collect fees and other amounts owed in connection with the Services; and
- comply with tax and other applicable laws; and
- for internal research purposes.
- Email Communications. We may use your Personal Information to provide you with marketing or other promotional communications via mail or email. If, at any time, you would like to stop receiving these promotional e-mails, you may follow the opt-out instructions contained in any such e-mail.Please note that by opting out, you may prohibit myGini from informing you of offerings that may be of interest to you. It may take up to ten (10) business days for us to process opt-out requests. You will continue to receive non-promotional emails about your relationship with us.
Disclosure of Personal Information
Except as provided herein, myGini will not sell, rent, or otherwise disclose Personal Information about you to third parties.
- At your request or to complete a transaction. We may share your Personal Information with specified third parties if you request or direct such disclosure. We may also share such information to complete a transaction or to provide a service requested by you
- Third party providers. We may share your Personal Information with unaffiliated third parties that provide certain services to us, including, but not limited to payment processing, data analysis, email delivery, hosting, order fulfillment, infrastructure, network storage, customer service, technical support, and promotional services. We may also disclose transaction information as described in Section 1.4 above with Empyr, Inc. and its third party service providers. These third parties may have access to Personal Information or non-Personal Information in order to perform their functions on our behalf. However, these third parties are only permitted to use your Personal Information for the purpose for which it has been provided or to administer, service or process transactions that you have authorized, and may not disclose it to any other third party except at our express direction and in accordance with this Policy.
- Business transfers. As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or our assets, Personal Information collected through the Services may be disclosed to such entity as one of the transferred assets. Also if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.
Updating Your Personal Information and Information Retention
If you wish to modify, verify, correct, or update any of your Personal Information collected through the Services, you may do so by logging into your Account and updating your Account profile or by emailing us at firstname.lastname@example.org. Please note that myGini may continue to use your de-identified data after you delete any of your Personal Information.
In accordance with our routine record-keeping, we may delete certain records that contain Personal Information you have submitted through the Services. We are under no obligation to store such Personal Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Personal Information. In addition, you should be aware that it is not always possible to completely remove or delete all of your information from our databases without some residual data remaining because of backups and other reasons.
We will retain your Personal Information as long as needed to provide you services, comply with our legal obligations, resolve disputes, or enforce our agreements.
Security of your Personal Information
myGini has, and requires our Third-Party Service Providers to have, commercially reasonable administrative, technical, and physical safeguards in place in our respective physical facilities and in our respective computer systems, databases, and communications networks that are reasonably designed to protect information contained within such systems from loss, misuse, and alteration. The measures we use may include storing Personal Information on secured servers, transmitting Personal Information using encryption technologies, and auditing and reviewing our data collection and storage practices.
No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your Personal Information. You also play a role in protecting your Personal Information. Please safeguard your password for your Account and do not share them with others. If we receive instructions using your Account log-in information, we will consider such instructions to have been authorized by you. You agree to notify us immediately of any unauthorized use of your Account or any other breach of security related to the Services. We reserve the right, in our sole discretion, to refuse to provide the Services, terminate your Account, and to remove or edit content.
Links to Third-Party Websites and Applications
Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not use technology that recognizes DNT signals from your web browser.
Children Under 13
The Site is not directed to children under 13 years of age and we do not knowingly collect Personal Information from children under 13. If we become aware that a child under 13 has provided us with Personal Information, we will make reasonable efforts to delete such information from our files.
Consent to Processing and Transfer of Information
The Services are governed by and operated in, and in accordance with the laws of, the United States, and are intended for the enjoyment of residents of the United States. If you use the Services, or otherwise provide us with data, from outside the United States, you acknowledge and agree that your Personal Information may be transmitted outside your resident jurisdiction. In particular, please note that your Personal Information may be stored and processed in the United States. The laws pertaining to the collection, use, disclosure and protection of Personal Information in the United States may be more or less stringent than the laws of other countries. By using the Services, you (a) acknowledge that the Services is subject to the laws of the United States; (b) consent to your Personal Information being stored and processed in the United States and handled as described in this Policy; and (c) waive any claims that may arise under the laws of the country where you reside, are a citizen, and/or from where you access the Services.
Changes to this Policy
If you have any questions or concerns about this Policy, please contact us at:
402 Jackson Street
San Francisco, CA 94111
Telephone: (415) 234-4464