The purpose of this Policy is to inform you about our privacy practices and to ensure that you understand the purposes for which we collect and process your Personal Data. The following is a brief summary of the manner and purposes for which we process your Personal Data.
This Policy does not apply to any data insofar as it is held, processed, disclosed or published in a form which cannot be linked to a living individual (such as anonymized data, aggregated data, or coded data which, in a given form, cannot effectively be used to extract your Personal Data) ("Anonymized and Aggregated Data"). We reserve the right to generate Anonymized and Aggregated Data extracted out of any databases containing your Personal Data and to make use as we see fit of any such Anonymized and Aggregated Data.
Responsibility for processing Personal Data
Propeller Enterprise is the entity which is responsible for the processing of personal data that we collect from you through registration forms or through the Site. If you have any questions or concerns about Propeller's use of your Personal Data, please contact us at [email protected]
Collection of Personal Data
The Site enables individuals to participate in certain activities, sweepstakes, campaigns, and fundraising programs (each an "Activity") to earn points ("Points") that can be redeemed for a variety of rewards ("Rewards") from the online catalogue ("Catalogue"). In order to earn Points and claim Rewards, you will need to create an account ("Account"). You can set up an Account either by linking to your Facebook, Twitter or Google account ("Social Media Account") or by registering an Account directly with us.
When you create your Account, we may ask you to provide certain personally identifiable information ("Personal Data"), which may include but is not limited to your name, email address, area (or zip) code and credit card information (provided to a secure Payment Processor). You may choose not to provide your Personal Data; however creating an Account is a prerequisite for using the full functions of the Site.
Registration through Facebook and other Social Media Accounts
The Site is designed to work in conjunction with your Social Media Account. If you choose to register for the Site by linking to your Social Media Account, we will provide you with an interface to connect with your Social Media Account host's application protocol interface (better known as its developer API) which will allow you to authorize us to access your Social Media Account on your behalf. You do not need to provide us with your Social Media Account's user name or password to provide this authorization, but you will need to log-in to your Social Media Account directly through the Site. Once authorized by you, your Social Media Account host will provide us with a token that allows it to recognize us and us to recognize your Social Media Account. You can revoke our access to your Social Media Account at any time by amending the appropriate settings from within your Social Media Account settings, though such revocation may limit your ability to access or use certain functionality of the Site.
If you register for the Site using your Social Media Account, Propeller will treat this as your consent to access your Social Media Account information, including (where relevant) your name, email address, profile picture, gender, 'networks', user ID (but not your password), list of friends, and any other information that you have 'shared with everyone'. If you allow Propeller access to such data, Propeller may access that data at any time, including when you are not using the application.
If you prefer not to use your Social Media Account to register for the Site, you can register for an Account directly by providing your name, telephone number, physical address and email address. If you choose to register in this way, you may not be able to participate in all Activities as many are intended to use functionality such as Facebook's 'share' function.
We may use certain standard web measurement and tracking technologies such as cookies, web server logs, or other statistics programs to collect usage information and track and record how you use the Site ("Usage Information"). This data is anonymous and does not personally identify you. Usage Information helps us measure the success of the Site and its features or pages and to improve your online experience. Your browser may have an option that allows you to accept cookies, reject cookies, or receive notification when a cookie is sent, but you should note that the use of such restrictive browser settings may limit your use of the Site. These web beacons enable our advertising server to recognize you when you visit the Site and to determine which banner ads bring users to the Site. We do not use spyware, adware or any other similarly intrusive software. Third-party advertisers (or their partners) may place or recognize a unique cookie on your browser. These cookies enable more customized ads, content or services to be provided to you. To trigger these cookies, we may pass an encrypted or 'hashed' (non-human readable) identifier corresponding to your email address to a web advertising partner, who may place a cookie on your computer. No personally identifiable information is on, or is connected to, these cookies. To opt-out of these cookies, please go to http://www.privacychoice.com/companies or http://www.aboutads.info/choices.
The purposes for which we collect your Personal Data
We collect your Personal Data for the following purposes:
1. To enable you to participate in Activities, earn Points and redeem Rewards through the Site;
2. To connect you with various non-profit organizations ("Causes") and to enable them to contact you directly (when you opt-in to join activities and agree for your details to be forwarded to such organizations);
3. Insofar as permitted under applicable law, to communicate with you in relation to other services that we or our affiliates offer;
4. To personalize, test, monitor, improve and upgrade the services offered to you through the Site;
5. To tailor the content that is made available to you on to Site and our communications to you by monitoring your Activities on the Site and the Causes that you choose to support;
6. To meet our legal obligations and the regulatory requirements to which we are subject, for loss prevention purposes and to protect and enforce our rights and meet our obligations to third parties; and
7. For our internal business purposes, such as compiling and analyzing Usage Information.
Disclosure of Personal Data
We may disclose your Personal Data to Causes or other third parties in the following circumstances:
1. Where you have granted express consent for us to do so, such as by completing an 'opt-in' form on the Site – in that case, the recipient would become the controller of the information and will handle it in accordance with its own privacy policies;
2. Where necessary in order for us to fulfill our obligations to you, such as disclosures to third party vendors who provide or fulfill Rewards;
3. As required or permitted by law, including to comply with legal process (for example, we may disclose your Personal Data as necessary to comply with an authorized civil, criminal or regulatory investigation);
4. To protect the security or integrity of our databases or the Site, to protect our business or reputation, to take precautions against legal liability, in the event of a business transition (see below), to protect and defend our rights or property, for required institutional risk control, or for resolving disputes, inquiries or complaints with respect to your use of the Site; or
5. As might otherwise be necessary in pursuit of our legitimate interests.
Legal basis for processing Personal Data
The processing of your Personal Data is lawful on the basis of the following:
1. your express consent, where you consent for us to use your Personal Data (including the sharing of your contact details with third party when you request to join their newsletters or other activities);
2. the fulfillment of our contractual obligations to you or at your request prior to entering into a contract with us, where we process your Personal Data at your request as part of the services provided through our Site (such as when we disclose your Personal Data to third party vendors who provide or fulfill Rewards you have earned);
3. compliance with legal obligations to which we are subject, including to comply with legal process (for example, we may disclose your Personal Data as necessary to comply with an authorized civil, criminal or regulatory investigation);
4. our legitimate interests in (among other things) operating and administering the Site, conducting commercial research, improving and maintaining our Site, personalizing and tailoring content made available to you through the Site, protecting the security or integrity of our databases or the Site, protecting our business or reputation, to taking precautions against legal liability, in the event of a business transition (see below), protecting and defending our rights or property, required institutional risk control, or for resolving disputes, investigating and attending to inquiries or complaints with respect to your use of the Site.
You may receive communications from Propeller, including promotional email messages sent to you by Propeller on behalf of Causes or other third parties. In the event that you choose not to receive any future communications about special offers, Activities or programs, you may opt-out by clicking on the link provided at the bottom of each email communication.
Where you agreed to receiving promotional materials and information from a third party organization, and that we should forward your details to a third party organization, it is the responsibility of that third party organization to use your Personal Data lawfully and to respond to requests to unsubscribe from such communications.
Links to other websites
While visiting the Site, you may be directed, through links, to other websites that are beyond Propeller's control. Propeller is not responsible for the privacy practices and policies of such websites.
Your choices regarding your Personal Data
If you have any reason to believe that Personal Data about you that is stored and maintained by us is incorrect, please contact us by email at [email protected] You may change any of your Personal Data in your Account by editing your profile within your Account or by sending an e-mail to us at [email protected] You may also request deletion of your Personal Data, but please note that we may be required to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may retain your information for fraud prevention or similar purposes.
Propeller's policies on SMS
In addition to any entry, submission or other fee of which you are notified, your carrier's standard messaging rates apply to your entry or submission message, our confirmation and all subsequent SMS correspondence and/or transmissions. All charges are billed by and payable to your mobile service provider.
We will not be liable for any delays in the receipt of any SMS messages as delivery is subject to effective transmission from your mobile service operator. SMS MESSAGE SERVICES ARE PROVIDED ON AN "AS IS" BASIS, AND WE MAKE NO WARRANTY, EXPRESS OR IMPLIED, AND ALL WARRANTIES, INCLUDING IMPLIED WARRANTIES OF MERCHANTABILITY AND FITNESS FOR PARTICULAR PURPOSE, ARE HEREBY EXPRESSLY DISCLAIMED.
Data obtained from you in connection with this SMS service may include your cell phone number, your carrier's name, and the date, time and content of your messages, as well as other information that you provide. We may use this information to contact you and to provide the services you request from us.
By using this service you may have access to various content. You should assume that everything to which you have access through this service is subject to copyright and trademark protection, unless noted otherwise. By subscribing or otherwise using the service, you acknowledge and agree that all right, title and interest, including the trademark and copyright rights, in and to such works are our property, and that you will not gain any ownership or other right, title or interest therein or thereto. You may not copy, download or make any other unauthorized uses of such items.
By subscribing, you consent to receiving, from time to time, further text messages from us.
By subscribing or otherwise using the service, you acknowledge and agree that we will have the right to change and/or terminate the service at any time, with or without cause and/or advance notice.
Protection of Personal Data
Propeller takes commercially reasonable steps to help protect your Personal Data against loss, misuse and unauthorized access, disclosure, alteration and destruction. Propeller expressly disclaims any representation or warranty, whether express or implied, with respect to ensuring, guaranteeing or otherwise offering any definitive promise of security in connection with your Personal Data. If you have any questions or concerns regarding the security of your information, please email us at [email protected]
In the event Propeller goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your Personal Data might be among the assets transferred. You will be notified via this Site of any such change in ownership or control of your Personal Data.
Credit card information
When you use a credit card to make a donation to a Cause via the Site, you are actually being redirected to a secure third party provider ("Payment Processor"). We do not collect, access, store or process any credit card information.
If we decide to change this Policy, we will post the changes on this Site and at other places as we deem appropriate. We reserve the right to modify this Policy at any time, so please review it frequently.
If any part of the Policy is determined to be invalid or unenforceable pursuant to applicable law, then the invalid or unenforceable provision will be deemed superseded by a valid, enforceable provision that most closely matches the intent of the original provision and the remainder of the Policy shall continue in force and effect.
Location of processing activities
We operate in the United States of America and operate the Site from that country. When you provide Personal Data to us through the Site or where we monitor your Activities on the site the data is collected and received in the USA. In the event we need to transfer data from the European Union to the USA (or to other countries outside the European Union) we do so under a data export agreement in accordance with the model clauses adopted by the European Commission. The agreement ensures that the recipient of the data will handle it in accordance with safeguards stipulated in the agreement. If you are a user in the European Union you are a beneficiary of any such agreement and you can enforce its provisions against the parties.
EU data subject rights
Users based in the European Union have the following legal rights in respect of their Personal Data:
1. The right to require Propeller to confirm whether or not their Personal Data is being processed, the purpose of any such processing, the recipients of any Personal Data that has been disclosed, the period for which their Personal Data is to be stored and whether any automated decision-making processes are used in relation to their Personal Data;
2. The right to require Propeller to rectify inaccurate Personal Data without undue delay;
3. The right to request the erasure of their Personal Data. Propeller will be required to erase the Personal Data in response to such request where:
a) the Personal Data is no longer necessary in relation to the purpose for which it was collected, such as where a user chooses to delete his or her Account;
b) where the processing of the data is based on the user's consent (and the other circumstances described in the 'Disclosure of Personal Data' and 'Legal basis for processing' sections above no longer apply), if the user withdraws his or her consent; or
c) the user objects to the processing of his or her Personal Data and there are no overriding legitimate grounds for the processing.
Where Propeller has disclosed the Personal Data of a European Union user to a third party and the user requests the erasure or rectification of the data, Propeller will take all reasonable steps to inform the third party of such request.
4. The right to restrict Propeller from processing their Personal Data in certain circumstances, such as where the accuracy of that Personal Data is disputed or an objection has been raised (see below). In such circumstances, Propeller will only process that Personal Data with the express consent of the user, or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest;
5. The right to receive their Personal Data from Propeller in a structured, commonly used and machine-readable format;
6. The right to object to the processing of their Personal Data by Propeller where:
a) Propeller has relied on the 'legitimate interest' basis for processing that Personal Data (see item 4 in the section headed 'Legal basis for processing Personal Data' above), in which case we will immediately stop processing the user's Personal Data unless we have compelling legitimate grounds which override the interests, rights and freedoms of the user; or
b) the Personal Data is used for direct marketing purposes, in which case we will immediately stop processing the user's Personal Data for such purposes.
If you feel that Propeller has mishandled your Personal Data in violation of EU law, please contact us with a written description of your complaint. After receiving such written description, a representative from Propeller will contact you to set up a time and manner to discuss your complaint. Propeller is dedicated to addressing all legitimate complaints about its adherence to this Policy and all applicable legal requirements and will make a good faith effort to engage in communications to address such complaints. For unresolved complaints under the Safe Harbor Privacy Principles, Propeller has agreed to participate in the BBB EU Safe Harbor Dispute Resolution Program operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Propeller, please visit the BBB EU Safe Harbor Dispute Resolution Program website at www.bbb.com/us/safe-harbor-complaints for more information.
This Policy is effective as of March 29, 2018.
If you have any questions or suggestions regarding this Policy, please contact Propeller at [email protected]