Effective February , 2014
- Users in the general public ("Website Users") who visit and use the publicly-accessible website located at www.offerpop.com ("Offerpop Site"). Website Users include, by way of example, but not limitation, users who:
- Submit feedback, questions, comments or other user-generated content on the publicly-accessible Offerpop support portal located at http://getsatisfaction.com/offerpop
- Sign up to receive marketing and other communications regarding Offerpop including offers we send on behalf of business partners through the "Contact Us" or "Join our email list" or similar features available on the Offerpop Site
- Publicly state their preferences, experiences or interests regarding Offerpop or Offerpop's product or service offerings, in each case as expressed in the course of such user's use of the Offerpop Site by selecting a "Like," "Follow," "+1," or similar public designation of interest
- Users who are customers or prospective customers of Offerpop ("Campaign Operators") who access and use the Offerpop-branded social marketing applications (the "Offerpop Applications"), whether on a trial, freemium, or paid subscription basis, to operate online social media marketing campaigns or promotions (“Campaign”) Facebook, Twitter, or any other website operated by a third party on which the Campaign is run (“Third Party Sites”).
Offerpop complies with the U.S. - E.U. and U.S. - Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from European Union member countries and Switzerland. Offerpop has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Offerpop's certification, please visit http://www.export.gov/safeharbor.
INFORMATION OFFERPOP MAY RECEIVE FROM USERS
- Website Users. If you are a Website User, in the course of using the Offerpop Site, you may provide Offerpop with (i) personally identifiable information ("Personal Information") such as your name, phone number, or email address; and (ii) feedback, suggestions, complaints, or other descriptions of your experiences, preferences, or interests in Offerpop or the Offerpop Applications ("Feedback").
- Campaign Operators. If you are a Campaign Operator, in the course of using the Offerpop Site or the Offerpop Applications, you may provide Offerpop with (i) Personal Information in your user or account profile with Offerpop, such as your name, phone number, credit card or other billing information, email address, and home and/or business postal addresses; and (ii) Personal Information in your user or account profile with the Third Party Site that interact with the Offerpop Applications, that may include, but are not limited to, your log in credentials and profile information you have elected to make public; (iii) Personal Information of your Social Users that you elect to collect, process, and/or store in connection with such Social Users' participation in a Campaign using the Offerpop Applications; and (iv) Feedback.
- Social Users. If you are a Social User (e.g. Facebook) in the course of using the Offerpop Applications, Offerpop may receive, directly or through Campaign Operators, Personal Information of yours that may include, but is not limited to, (i) your social media profile (e.g. your Facebook profile name or handle, and its associated email address, but never your password); (ii) information posted on your social media profile such as wall posts, likes, dislikes, or items you follow, but only to the extent that you make this information publicly available, that you authorize the use of private information through a permission grant or other means provided by that Social Service, or that you provide this information to the Campaign Operators in response to a promotion or other marketing campaign operated by the Campaign Operators by use of the Offerpop Applications.
- If you are a Social User we may provide you the opportunity to refer friends to a Campaign Operator promotion. If you choose to do so we may ask you for your friend's name and email address. We will automatically send your friend a one-time email inviting him or her to view the Campaign Operator’s promotion. Offerpop stores this information for the sole purpose of sending this one-time email and tracking the success of the referral. Your friend may contact us at email@example.com to request that we remove this information from our database.
- Offerpop collects information under the direction of its Campaign Operators, and has no direct relationship with the Social Users whose personal data it processes.
INFORMATION OFFERPOP COLLECTS
In addition to the information identified above, and regardless of the type of user you are, when you visit the Offerpop Site or interact with the Offerpop Applications, Offerpop's servers and our third party tracking-utility partners gather certain information automatically that your browser sends whenever you visit a website through log files. This information may include, but is not limited to, your computer's Internet Protocol address, browser type, the web page you were visiting before you came to the Offerpop Site or interacted with the Offerpop Applications, and information you search for on the Offerpop Site or the Campaign Operator’s website or the Third Party Site.
HOW OFFERPOP USES INFORMATION
We will share your Personal Information with third parties only in the ways that are described in this privacy statement. Offerpop uses Personal Information obtained by technical means or directly or indirectly for the following purposes: (i) to provide and improve the Offerpop Site, the Offerpop Applications, and related Offerpop services, features and content, (ii) to administer Campaign Operators' membership and users' use of the Offerpop Site, (iii) to enable users to enjoy and easily navigate the Offerpop Site and Offerpop Applications, (iv) to better understand users' needs and interests, (v) to fulfill requests users may submit to Offerpop, (vi) to personalize users' experience on the Offerpop Site or Offerpop Applications, (vii) to provide or offer software updates and product announcements, and (viii) to provide users with further information and offers from Offerpop or third parties that Offerpop believes users may find useful or interesting, including newsletters, marketing or promotional materials and other information on services and products offered by Offerpop or third parties.
SERVICE PROVIDERS AND BUSINESS PARTNERS
Offerpop may employ third party companies and individuals to operate the Offerpop Site or the Offerpop Applications to perform site-related services (such as to maintenance services, database management, customer support, sending emails on our behalf and web analytics and site improvement) or to assist us in analyzing how the Offerpop Site and the Offerpop Applications are used. These third parties have access to your Personal Information only for purposes of performing these tasks on Offerpop's behalf.
Offerpop may also provide Personal Information to its business partners or other entities with whom Offerpop has cooperative relationships so that they can send you promotional and other information you have requested from Offerpop or such business partners. If you provide us with your Personal Information for these purposes and would no longer prefer it be used you may contact us at firstname.lastname@example.org.
CREDIT CARD PROCESSING
Offerpop uses an outside, PCI-compliant card processing company to bill Campaign Operators who are purchasing subscriptions to the Offerpop Applications from Offerpop. This information is collected and transmitted in a secure manner, using SSL encryption. The credit card processing company does not retain, share, store or use Personal Information for any secondary purposes beyond filling your order. In addition, Offerpop will not collect credit card data from Social Users who participate in Campaigns.
USER PROFILE INFORMATION
If you are a Campaign Operator, Offerpop will display your Personal Information in your profile page and elsewhere on the Offerpop Site accessed by you according to the preferences you set in your account. You can review and revise your profile information at any time by logging on to your account and making the applicable changes.
If you are either a Website User or a Campaign Operator and decide at any time that you no longer wish to receive email or marketing communications from Offerpop, please follow the unsubscribe instructions provided in any of our communications.
We collect information for our Campaign Operators, if you are a Social User and would no longer like to be contacted by a Campaign Operators that use the Offerpop Applications, please contact the Campaign Operator directly.
PUBLICLY-AVAILABLE PERSONALLY-IDENTIFIABLE INFORMATION
Offerpop hereby notifies you that, while Offerpop discourages the collection and use of any sensitive personally-identifiable information on the part of its Campaign Operators, Offerpop does not and cannot review or monitor the type of information which Campaign Operators choose to collect from Social Users as a condition to, or in the course of, operating a Campaign by use of the Offerpop Applications.
To request removal of your personal information from our blog or community forum, contact us at email@example.com. 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.
SOCIAL MEDIA FEATURES
You can log in to our site using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities on this Web site to your profile page to share with others within your network.
OUR POLICY TOWARD CHILDREN
Neither the Offerpop Site nor the Offerpop Applications are directed to children under 13. Offerpop does not knowingly collect Personal Information from children under 13. If a parent or guardian becomes aware that his or her child has provided Offerpop with Personal Information without their consent, he or she should contact us at firstname.lastname@example.org. If Offerpop becomes aware that a child under 13 has provided Offerpop with Personal Information, Offerpop will delete such information from its files, and perform any other acts necessary to comply with applicable law or regulations.
Offerpop reserves the right to use and disclose any information that is aggregate in format or does not contain Personal Information (such as statistics and survey results that do not identify you individually by name).
ACCESS TO, CHANGING OR DELETING YOUR INFORMATION
All Campaign Operators may review, update, correct or delete the Personal Information provided in their registration or account profile by making changes on the settings page of the Offerpop Site or by contacting us at email@example.com. If you completely delete all such information, then your account may become deactivated and you will not be able to use the Offerpop Applications.
Please note that the above will not apply to communications about the Offerpop Applications that are considered part of Offerpop's service, in which case you will continue to receive such communications and may not opt out of receiving them unless you cancel your subscription to the Offerpop Applications.
If you are a Social User, your Personal Information may not be stored in a way that enables Offerpop to individually excise your data. However, your Personal Information will be expunged, overwritten and/or permanently deleted from Offerpop's servers in accordance with Offerpop's industry-standard data retention policies and procedures.
Offerpop has no direct relationship with the individuals whose personal data it processes. A Social User who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to the Campaign Operator (the data controller). If the Campaign Operator requests Offerpop to remove the data, we will respond to their request within 30 business days.
We will retain your information as well as information we process on behalf of our Campaign Operator for as long as the Campaign Operator’s account is active or as needed to provide the Campaign Operator with services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Offerpop will respond to requests for access within 30 days.
We post customer testimonials on the Offerpop Site which may contain Personal Information. We do obtain your consent via email prior to posting the testimonial to post your name along with the testimonial. If you want your testimonial removed please contact us at firstname.lastname@example.org.
By providing Offerpop with Feedback, you hereby grant to Offerpop a royalty-free, worldwide, transferable, sublicenseable, irrevocable, perpetual license to use any Feedback and/or to incorporate such Feedback into the Offerpop Site, or Offerpop Applications or any service or product developed by Offerpop. You acknowledge and agree that any Offerpop Application, the Offerpop Site, or other product or service incorporating such suggestions, enhancement requests, recommendations or other feedback shall be the sole and exclusive property of Offerpop and all such recommendations shall be free from any confidentiality restrictions that might otherwise be imposed upon Offerpop pursuant to your written or electronic agreement with Offerpop.
LINKS; MARKETING CAMPAIGNS
The Offerpop Site and the Offerpop Applications may contain links to other sites. Please be aware that Offerpop is not responsible for the content or privacy practices of such other sites. Offerpop encourages all users to read the privacy statements of any other site that collects personally-identifiable information.
Offerpop takes industry-standard precautions to protect Personal Information. For example, whenever Offerpop collects credit card data or other payment information, that information is protected using industry standard encryption and transmitted to Offerpop in a secure way. You can verify this by looking for "https" at the beginning of the address of the particular web page.
While the safeguards implemented by Offerpop may help prevent or slow unauthorized access, maintain data accuracy, and facilitate the appropriate use of data, NO GUARANTY IS OR CAN BE MADE THAT YOUR INFORMATION IS SECURE FROM INTRUSIONS AND OR UNAUTHORIZED ACCESS BY THIRD PARTIES. If you have any questions about security of the Offerpop Site or the Offerpop Applications, you can contact us at email@example.com.
COMPLIANCE WITH LAWS AND LAW ENFORCEMENT
Offerpop cooperates with government and law enforcement officials and private parties to enforce and comply with law. Offerpop will disclose any information about you to government or law enforcement officials or private parties as Offerpop, in its sole discretion, believes necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Offerpop or a third party, to protect the safety of the public or any person, or to prevent or stop any activity Offerpop may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable.
Offerpop may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy. You will be notified via email and/or a prominent notice on the Offerpop Site of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.
LOCATION OF OFFERPOP SERVERS
Offerpop's computer systems are currently based in the United States, so your Personal Information will be processed by us in the United States. In accordance with applicable law, Personal Information collected on the Offerpop Site or by Campaign Operators through the Offerpop Applications may be transferred, stored and processed in the United States. By submitting your Personal Information to Offerpop or the Offerpop Applications, directly or indirectly through a Campaign Operator, you consent to such processing of your Personal Information.
CHANGES TO THIS POLICY
Offerpop Corporation 36 East 31st Street, 8th floor New York, NY 10016