Effective Date: September 1, 2020
Information We Collect
When you interact with us through the Service, we may collect personal information from and about you. You may interact with us directly, such as when you sign up for a GPP Mobile account through the Site or App, as well as indirectly, such as when you sign up for a GPP Mobile account through our Platform operated by one of our Rewards Providers. When you make a purchase or otherwise interact with one of our Rewards Providers, we may also collect transactional information from you.
Information You Provide
We collect personal information from you when you voluntarily provide it, such as when you register for access to the Service and create an account, use certain aspects of the Service, contact us with inquiries or respond to one of our surveys. For example, we may collect your name, phone number, email address, photograph, birthdate, location information, Third-Party Service (defined below) login credentials, other information (such as your online activity) based on your registration and privacy settings on those Third-Party Services, and the messages you send or receive through the Service.
Information We Automatically Collect & How it is Used
· MEMBER PROFILE INFORMATION: We track member enrollment information, including name, address, phone and email address, throughout our software, site and Member Web portals. We also track incoming IP addresses and workstation names which access our data center and site.
· TRANSACTION INFORMATION: We track sales transactions, including sales amounts, points earned, gift card deductions and balances and gift card account numbers. We do not track or store any credit card information.
· EMAILS, SMS TEXT AND DIRECT MAIL: Personal information that you provide may be used to communicate to you, via EMAIL, SMS Text and or Direct Mail. Receipt of this information is controlled via an opt-in/opt-out preference stored against your loyalty account. If you are not receiving communications and would like to, you may choose to change your preferences by accessing your loyalty account via the online Web Portal or by contacting the specific merchant with whom you want to receive communications from. If you are receiving Email communications and no longer wish to, you can opt-out by clicking the one-click unsubscribe link found in every email that leaves our system. The unsubscribe link is an automated way for you to immediately cease receiving email from our system. If you are not receiving SMS Text communications and would like to, simply text "join" to the participating merchant's text code, supplying the merchants SMS keyword. If you are receiving SMS Text messages from our system and no longer wish to, you may opt-out immediately by replying STOP to any message you receive. Opt-out is immediate in all cases. If you would like to change your direct mail preferences, simply contact the merchant of interest or access your loyalty account via the merchant's online loyalty web portal.
· WEB BEACONS: All emails distributed through our system contain electronic images known as web beacons, also known as single-pixel GIFs, which are invisible graphical images. These web beacons allow us to count users who have opened email delivered from our system and who have visited associated web pages or ads provided as links in those emails. Web beacons collect only limited information, such as the date/time the email was opened and who opened it. Web Beacons can be refused. If you do not wish to receive Web Beacons via email, you will need to disable HTML images or refuse HTML (select Text only) emails via your email viewer software.
· CHOICE/OPT-OUT: GPP Mobile adheres to an industry standard Anti-Spam Policy and, as such, we tolerate only permission-based email, SMS Text messaging and Direct Mail delivery. Recipients always have the opportunity to opt-out via a one-click unsubscribe link in the footer of all email messages or by replying STOP to any SMS Text message. Additionally, these options are made available when you sign-up for enrollment in our loyalty programs. If you believe that you have received an unsolicited email, SMS text or Direct Mail communication from GPP Mobil, you may report it to us at firstname.lastname@example.org.
Tracking Options and California Do Not Track Disclosures
Our cookies and other tracking technologies help provide additional functionality to the Service and help us analyze Service usage more accurately. For instance, our Service may set a cookie on your browser that saves your login credentials. You can set your browser or operating system settings to limit certain tracking or to decline cookies, but by doing so, you may not be able to use certain Service features. Please refer to your web browser’s or operating system’s website or “Help” section for more information on how to delete and/or disable your browser or operating system from receiving cookies or controlling your tracking preferences. Our system may not respond to Do Not Track requests or headers from some or all browsers.
Combination of Information & Collected from Third-Party Services
We may combine the personal information we receive from or about you, including information you provide to us and information we automatically collect through the Service, as well as information across other computers or devices that you use, with information we collect or receive about you from other online and offline sources, or from other third party sources.
In addition, one of the special features of the Service is that it allows you to integrate various online third-party services, such as social media and social networking services (“Third-Party Services”), directly into your GPP Mobile experience. To take advantage of this feature, we will ask you to provide us your username and password for the relevant Third-Party Services. By enabling such Third-Party Services, you are allowing us to pass your Third-Party Service log-in information to these Third-Party Services for this purpose. When you add a Third-Party Service account to the Service, we will collect your Third-Party Service login information and other relevant information necessary to enable the Service to access that Third-Party Service and your data contained within that Third-Party Service. However, please remember that the Third-Party Services may use, store and disclose your personal information differently, as described in their policies, and GPP Mobile shall have no liability or responsibility for the privacy practices or other actions of any Third-Party Service.
GPP Mobile uses transactional data to facilitate your transactions with Rewards Providers. If you are a GPP Mobile accountholder, transactional data will be used by Rewards Providers to automatically award you rewards points and/or to provide you with other offers that may be of interest to you. We may also remove your personal information from transactional data and aggregate it with other anonymous data, pool and/or combine aggregated data with other information, and share aggregated data with Rewards Providers, affiliates, service providers, agents and business partners. GPP Mobile may also disclose de-identified, aggregated data to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
GPP Mobile and its subsidiaries and affiliates (the “Related Companies”) may use data collected automatically through your use of the Service to analyze, improve, support and operate the Service, to help us improve the content and functionality of the Service, to better understand our users, for distribution in general benchmarking data and industry and/or other usage and demographic reports, and other business purposes.
GPP Mobile may also use the personal information collected from and about you through the Service to improve the GPP Mobile Service. GPP Mobile and its Related Companies may use this information to contact you in the future to tell you about services we believe will be of interest to you. GPP Mobile may also use your information in other ways, with your consent or as disclosed to you at the time of collection.
GPP Mobile is not in the business of selling your personal information. We consider personal information to be a vital part of our relationship with you.
There are, however, certain circumstances in which we may share your information for a business or commercial purpose with certain service providers or partners, or where you may share your information with third parties, as set forth below:
· Rewards Providers: To the extent you have obtained or redeemed a reward offered by a Rewards Provider, added a Rewards Provider as a membership to your account, made a purchase at or through a Rewards Provider, or otherwise participated in any other activity sponsored or offered on behalf of the Rewards Provider, we may provide your personal and transactional information to such Rewards Providers (a) for the Rewards Provider to redeem and validate your reward, send you customized offers, troubleshoot redemption, combat fraud and otherwise communicate with you; (b) as part of legal proceedings affecting GPP Mobile or the Rewards Provider; or (c) to send you marketing information or otherwise facilitate a direct relationship between the Rewards Provider and you.
· Agents, Consultants and Service Providers: GPP Mobile, like many businesses, sometimes hires agents or service providers to perform certain business-related functions. Examples of such functions include maintaining databases, sending emails and SMS messages, offering and developing certain features of the Service, and performing maintenance and security. When we employ an agent or service provider to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
· Your Public Profile: If you make any information available through your public profile, it will be made available to members of the GPP Mobile community. Please exercise caution when disclosing personal information in these public areas of the Service.
· Legal Requirements: GPP Mobile may disclose your information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation or assist government enforcement agencies, (ii) protect and defend the rights or property of GPP Mobile, Rewards Providers, or our users, (iii) act in urgent circumstances to protect the personal safety of users of the Service or the public, (iv) protect against legal liability; (v) protect Rewards Providers from fraudulent, abusive, or unlawful uses; or (vi) protect the security or integrity of the Service.
· Aggregate or Anonymous Non-Personal Information: We may also share aggregate, anonymous, or de-identified non-personal information with third parties for their or our marketing or analytics uses, and as described in the “Information Use” section above.
Your Choices and Opt-Outs
The Service will automatically send you SMS messages with updates and other information. You may stop receiving SMS messages by replying STOP in response to any received SMS message. You may also opt-out of receiving SMS messages on the GPP Mobile website. If you opt-out of receiving SMS messages, you may not be able to use certain Service. If you do not want to receive marketing emails from us, click the unsubscribe link in the footer of such emails.
Your California Privacy Rights
If you are a California resident, you have the right to ask to make an access and deletion request. GPP Mobile will not discriminate against you for exercising these rights, but we may offer financial incentives to those who opt in to our collection of personal information.
· Access Request. You may make up to two requests per year for information as to:
· The categories of personal information that we’ve collected about you, or shared with a service provider or partner for a business or commercial purpose;
· The sources from which we collected such information;
· The business or commercial purpose for collecting that personal information.
· The specific pieces of personal information we’ve collected about you.
· Deletion Request. You may request that we delete the Personal Information that we’ve collected from or about you. If we cannot delete all of your information, we will let you know the reason why, such as if we need to continue to provide you with rewards, or for an internal business or legal reason.
· Further to the “Information Disclosure” section, over the last 12 months, GPP Mobile has collected and shared for a business or commercial purpose the following categories of personal information:
o Identifiers/Contact Information: These include your name, postal and email address, phone number, and unique identifiers that may identify your device or browser but not you by name.
o Commercial/Transactional Information: Your transaction and usage history, payment card information, and which Rewards Providers you visit.
o Internet/Electronic Activity: Your geolocation information, IP address, web/app browsing and search history related to our Services, and information regarding your interaction(s) with the Services or our advertising.
· Children: GPP Mobile does not direct the Service to, nor does it not knowingly collect personal information from children under the age of 13 If we learn that a child under the age of 13 has provided personally identifiable information to GPP Mobile through the Service, we will endeavor to delete that information from our databases.
GPP Mobile takes reasonable steps to protect the personal information provided via the Service from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet, email, mobile or other electronic transmission is ever fully secure or error free, so you should take special care in deciding what information you provide.
Access to Information; Contacting Us
You may request, by contacting us as specified below, that we disclose, update, correct, or delete certain personal information that we have collected through the Service. We will take reasonable steps to honor your request in accordance with applicable law. You may also update, correct, or delete certain information associated with your account, and you are responsible for maintaining the accuracy of this information. To make such a request, please send an email to email@example.com. GPP Mobile may take steps to verify your identity before responding to your request.