POINT2GO™ PRIVACY POLICY

REV 1: JULY 2016

Point2Go™ is a program of Creditcard Discount Services Inc., a Washington corporation. The terms “CDS” “Point2Go™” “we,” “us” or similar terms all refer to Creditcard Discount Services Inc. and its Point2Go™ applications. This policy outlines how CDS treats personally identifiable information that is collected while you access or use any Point2Go™ application (the “Point2Go™ Apps”) or the CDS websites relating to the Point2Go™ Apps, including, but not limited to, www.cdsus.com/point2go/ (the “Site”). For purposes of this Privacy Policy, “Merchant” means any merchant that has registered with us for the Point2Go™ Merchant App or has signed a Point2Go™ Merchant Subscription Agreement and “Consumer” refers to any person that has installed the Point2Go™ App for consumers and agreed to our Terms of Use. The terms “you,” “your” and similar terms refer to both Merchants and Consumers.

Your personally identifiable information will be collected, used, and shared as outlined in this Privacy Policy. This Privacy Policy includes information about the following:

  • What personally identifiable information is collected by CDS or by any third-party through the Point2Go™ Apps or the Site.
  • How CDS uses this information.
  • With whom CDS may share this information.
  • What choices are available to you as a user of the Point2Go™ Apps with respect to collection, use and distribution of the information.
  • What types of security procedures are in place to protect the loss, misuse or alteration of information under our control.
  • How you can correct any inaccuracies in the information.

How We Protect Your Information

CDS security measures are in place to help protect against the loss, misuse, and alteration of the personal information and data under our control. The Site and our services use industry standard measures to protect the security of your information. This is not a guarantee that your information may not be accessed or disclosed by a breach of our systems, as no form of security is ever 100% secure. We take reasonable steps, such as requesting a unique password, to verify your identity before granting you access to your account; however, you are responsible for maintaining the secrecy of your unique password and account information at all times. This helps to ensure that others cannot access your personal information and correspondence when accessing your computer or other mobile devices.

 

Your Choices About Your Information

You may choose not to submit personal information through the Applications, in which case CDS may not be able to provide certain services to you. You can review and correct the information about you that CDS keeps on file by contacting us directly at point2go@cdsus.com.

 

Information Practices: Fair Processing Notice

CDS collects, holds and processes personal information relating to Consumers who use Point2Go™ App, as well as data related to the Merchants that subscribe to the Point2Go™ POINT2GO™ Merchant App. It is essential for CDS to do so in order to manage its operations effectively and in order to provide such interactive marketing services for the benefit of both the Merchant and the Consumers.

During registration or account creation, you give your consent for CDS to process your personal information. CDS provides this fair processing notice, which informs you of how your personal data will be processed and provides the purposes for which the data has been collected. It also explains how you can opt out of some aspects of the processing, where applicable.

 

Information That We Collect and How We Use It

The information held by CDS is primarily taken from the details provided during the registration or account-creation process; however, it also includes information that accumulates during an individual's ongoing use of the Point2Go™ Apps. This information may include personal data such as your name, birthday and email address, transaction history, and could include a photograph and mobile phone number (if Consumer provides either). Geographic location details are used to assist in participating in an individual Merchant program, as well as to provide relevant and appropriate offers.

We collect information about Consumers in order to:

  • Maintain status and preferences with each selected Merchant program.
  • Provide desirable and relevant messages or offers from selected Merchants.
  • Verify and account for any rewards or offers Consumers may have earned or received.
  • Make Consumers known to Merchants.
  • Administer and support the account for the user’s benefit.

We collect information about Merchants in order to:

  • Make the CDS services available to their customers.
  • Moderate how employees have access to product features.
  • Provide marketing services on behalf of the Merchant.
  • To identify Merchants within the consumer interface of the Point2Go™ App.

We may also use information we hold about you to:

  • Compare it to other information to help combat fraud.
  • Assist in the authentication of your identity for customer service.
  • Deliver relevant messages and account service notices.
  • Perform analytics and other product and service development functions.

Your personal information will be used to provide you with Point2Go™ services, such as participation in selected Merchant programs; and a limited amount of information will be shared with Merchants that you select, including your name, photo, visit history and a truncated email address. Any personal information shared in these ways will not be excessive. For example, a Merchant will see your name, a portion (but not all) of your email address, recent transaction history only from their business, in order to provide you with customer service and to make updates to your account.

 

Mobile Geolocation Data

The Applications and Site may use geolocation data to provide our services. When Consumers use the Point2Go™ App, we may use GPS, Wi-Fi, Bluetooth, or other similar technologies to determine your current location in order to identify which Merchant you are visiting other Merchants near you, to check you in to that location, and/or to provide you with relevant advertisements or other messages. We will not share Consumers’ current location with other users or partners. If you do not want us to use your location for the purposes identified above, you should turn off the "location services" for CDS located in your mobile phone settings. You may revoke your consent for access to geolocation data at any time, but elements of the Point2Go™ Apps may not then work. We will use Merchant street addresses and d/b/a name to identify Merchants within the consumer interface of the Point2Go™ App.

 

Third Party Advertisers

We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Point2Go™ Apps, the Site and other websites, based on information relating to your access to and use of the Site and other websites. To do so, these companies may place or recognize a unique cookie on your browser (including through the use of pixel tags). For more information about this practice, or simply to learn more about what choices may be available to you, please visit http://www.aboutads.info/ or http://www.networkadvertising.org/choices

 

Registration

When you select to register an account within a Point2Go™ App or on our Site, we request that you provide information, such as your name, email address, user name and password (and optionally photo and mobile number) to register your account. CDS uses this information to provide services to you and to provide push notifications regarding our services. If you do not wish to receive push notification you will need to opt out of such notification in your mobile phone settings or send an email to point2go@cdsus.com. Except for making your name and profile photo available to Merchants that you have authorized and third parties as needed to provide services to you, it is not shared with any third parties for their promotional purposes.

In addition, if you choose to opt-in to Merchant loyalty programs, Point2Go™ may deliver push notifications on behalf of such Merchants to your mobile device. Point2Go™ and CDS are not responsible for the content of such push notifications.

 

From Your Web Browser or Mobile Device

When you use a Point2Go™ App or the Site, we record and maintain a log of requests sent by your mobile device or browser to our web servers. The information we collect is used to improve the quality of our services - for example, by diagnosing service or technology problems, or assessing and maintaining security. We may also conduct research on information we collect to determine user demographics, interests, and behavior.

CDS reserves the right to utilize your Point2Go™ App or Site usage and location data to identify, generate and show you content-targeted promotions. This will be done through a secure, automated process. Examples of such content-targeted promotions could include using your general location data to determine which Merchant you are visiting so that the Merchant’s special offers can be made available to you during that visit and using your specific location data to determine where in the Merchant’s store you are so the Merchant can provide you offers specific to what you’re browsing. This use of location data is a necessary part of your use of the Point2Go™ App. If you are uncomfortable with such collection or use of location data at any point then, as described above in Mobile Geolocation Data, you may turn off the location services or otherwise discontinue your use of the Point2Go™ App or Site. None of your content or personal information will be shared with any party beyond the terms specified in this Privacy Policy.

 

Information Sharing

CDS will not rent or sell your personal information to third parties for their promotional purposes. CDS may share your personal information with entities outside of CDS as described in this Privacy Policy, such as in the following limited circumstances:

  • If we need to share your information to provide the products or services you have requested.
  • If we have your consent. We would require opt-in consent for the sharing of any sensitive personal information.
  • With a Merchant with whom you have established a history of transactions, we will share that transaction history with that Merchant only, which may include time and date of purchases, quantity, visit history, response to promotions, and personal preferences related to the services of that specific Merchant.
  • To our subsidiaries, affiliated companies or other trusted businesses or persons acting as a service provider, authorized reseller or distributor on behalf of CDS in order to provide the products or services you have requested.
  • If we have a good faith belief that disclosure of the information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request such as in complying with a formal request in a civil action, court order, subpoena or judicial proceeding, (b) enforce our Terms of Use or other agreements with you, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against imminent harm to the rights, property or safety of CDS, its users or the public as required or permitted by law.

We may share non-personal information with interested third parties in order to help them understand usage of the CDS or Point2Go™ services. We may also provide your non-personal information to contractors so that they can perform services for us such as assisting us in improving our offerings. Such information does not identify you individually.

 

Transfers to the United States and Other Global Locations

Because CDS and Point2Go™ are headquartered in the United States, we may transfer information collected from you within the United States. We may also transfer such information between and among such location outside the U.S. as needed to provide the Point2Go™ services. By using the Site or Point2Go™ App you agree to these transfers and allow us to use and disclose your information in accordance with this Privacy Policy. To obtain further information about our policies and practices with respect to service providers outside of the country you are currently located in, please contact us directly at point2go@cdsus.com.

 

This Website May Be Linked to Other Websites

As you use Point2Go™ Apps, you may click to websites of affiliated companies or other third parties. Those websites may have their own privacy policies. This Privacy Policy will not apply when you move to one of these other websites because their privacy practices and policies are tailored to the products and services offered by them rather than by us. If you visit their websites please be sure to review the privacy policies applicable to those websites.

We may create links to third-party websites. CDS is not responsible for the privacy practices employed by any such third-party websites. The CDS privacy policies and practices do not apply to these websites. CDS does not guarantee, approve, or endorse any information, material, services, or products contained on or available through any linked websites. CDS is not responsible for any content on websites linked from or to the Site. CDS is providing links to those websites as a convenience and your connection to and use of any linked website are at your own risk.

This Privacy Policy applies to the information we collect via a Point2Go™ App, the Site, or both. It does not apply to information we collect through other methods or sources, including websites owned or operated by our affiliates or other third parties. As described above, this policy applies and is limited to CDS’ collection, use, and disclosure of your information. It does not apply to the collection, use, or disclosure of your information by any other person or entity. For example, if you visit (by link or otherwise) a third-party website, this policy would not apply to that website. As a further example, if a Merchant uses your information outside of a Point2Go™ App or Site then this Privacy Policy would not apply to the Merchant’s use of your information (though the Merchant might have a privacy policy that would apply). We encourage you to learn about the applicable privacy practices before providing your information to any such person or entity.

 

Online Tracking

Some browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a single website. For these purposes tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time.

How browsers communicate the Do Not Track signal is not yet uniform. As a result neither the Application nor the Site are set up to interpret or respond to Do Not Track signals communicated by your browser. Even so, as described more fully throughout this Privacy Policy, we limit our use and collection of your personal information.

For a description of Do Not Track protocols for browsers and mobile devices, or simply to learn more about the choices available to you, you can visit the “All About Do Not Track” website: http://allaboutdnt.com

 

Children's Privacy

CDS complies with the requirements of the Children’s Online Privacy Protection Act (COPPA) and the FTC’s Rule interpreting COPPA (16 CFR § 512) and does not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to register. If you are under 13, please do not send any information about yourself to us. No one under age 13 is allowed to provide any personal information to or on CDS. In the event that we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us as described in the Questions section below.

 

Changes to Our Privacy Policy

If we change our policies and procedures, we will post those changes on the Site to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it. You are bound by changes to the Privacy Policy when you use any Point2Go™ App or the Site after those changes have been posted. In the event of a material change to our information practices, we shall notify you via email, via a prominent notice on the Site, or via in-app messaging.

 

Opt-Out Policy

CDS reserves the right to send you certain communications related to servicing your account, such as service announcements and administrative messages that are considered part of your account. You can opt-out of news and announcements when you sign up for Point2Go™ or you can use the unsubscribe link at the bottom of applicable emails we send you. If you change your mind about receiving promotional information from us after registering to receive it, please send us a request specifying your new choice at point2go@cdsus.com and we will honor your request or you can select the "Unsubscribe" link in an applicable email we send.

 

Data Storage

CDS uses third-party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run CDS. CDS owns or has rights to the code, databases and Point2Go™ App and this Privacy Policy governs all information on the Site. You retain all rights to your information data. Third-party vendors and hosting partners are not allowed to use your personal information for any promotional purposes.

 

Testimonials

We sometimes post customer testimonials on our Site, which may contain personal information such as the customer's name. We always obtain the customer's consent prior to posting the testimonial to post their name and likeness along with their testimonial. We are not responsible for any personal information a user elects to submit on the Site within their testimonial.

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