This Policy does not apply to websites, applications or other services that do not display or link to this statement or that display or link to different privacy statements.
Collection of Information
We collect certain personally identifiable information from you in various ways when you use our Services (“Personal Information”), including:
Information you provide to Us. We may collect your name, email address, GSC name, phone number and other information when you use the Services. In addition, when your principal, employer or GSC (“Principal”) registers you to be able to use the Website to access Mission Information (see below), we will receive additional information including your GSC email address. We may also obtain information that you upload to the App as part of any campaign, campaign objectives or mission (“Mission Information”) and associated location information and time stamped information and combine that with other information that we have collected.
Information from Social Networking Sites. Our Services include interfaces that allow you to connect with social networking sites (each an “SNS”). If you connect to a SNS through our Services, you authorize us to access, use and store the information that you agreed the SNS could provide to us based on your settings on that SNS. We will access, use and store that information in accordance with this Policy. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable SNS.
Information We Get from Others. We may also get information about you from other sources, for example, from your Principal.
Information Automatically Collected. When you visit our Website, some information is automatically collected. For example, when you visit our Website your computer’s operating system, Internet Protocol (IP) address, access times, browser type and language, and the website you visited before our site are logged automatically (“Usage Information”). We also collect information about your usage and activity on our Website.
We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our Services; and (2) third party cookies, which are served by service providers on our Services, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.
We may collect information using Web beacons. Web beacons are electronic images that may be used on our Website or in our emails. We use Web beacons to deliver cookies, count visits, understand usage and to tell if an email has been opened and acted upon.
Local Shared Objects
We may use local shared objects, also known as Flash cookies, to store your preferences such as volume control or to display content based upon what you view on our sites to personalize your visit. Third party partners provide certain features on our sites and display advertising based upon your Web browsing activity using Flash cookies to collect and store information. Flash cookies are different from browser cookies because of the amount of, type of, and way in which data is stored. Cookie management tools provided by your browser usually will not remove Flash cookies. Learn how to manage privacy and storage settings for certain Flash cookies.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk if you are in the UK or European Union (EU).
Use of Information
We use personal data and Mission Information collected through our Services for purposes described in this Policy. For example, we may use your information to:
- operate and improve our Website, App, products, and services;
- understand you and your preferences to enhance your experience and enjoyment using our Website, App, products, and services;
- track, collate, and analyze your use of the Website and/or App, and your progress in completing any campaigns, campaign objectives or missions set by your Principal (“Missions”);
- process and deliver contest entries and rewards;
- respond to your comments and questions and provide customer service;
- provide and deliver products and services you request;
- to send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
- communicate with you about new contests, promotions, rewards, upcoming events, and other news about products and services offered by the GSC and our selected partners; and
- link or combine it with other personal data we get from third parties, to help understand your needs and provide you with better service.
Sharing of Information
Information We Share
We do not share your personal data with third parties other than as follows:
- Third Parties Designated by You. With your consent, for example, when you agree to our sharing your information with other third parties for their own marketing purposes subject to their separate privacy policies; with your Principal in order to provide feedback about the Principal’s business, any Mission and any related information.
- Our Third Party Service Providers. With third party vendors, consultants and other service providers who work for us and need access to your information to do that work, such as hosting providers.
- Corporate Restructuring. in connection with or during negotiation of any merger, financing, acquisition, or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets to another GSC.
We may also share aggregated anonymous or de-identified information. When we use the term “anonymous data”, we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party.
We may create anonymous data from the personal data we receive about you and other individuals whose personal data we collect. Anonymous data might include analytics information and information collected by us using cookies. We make personal data into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyze usage patterns in order to make improvements to our Services.
Opt-Out and Disabling Cookies
You may opt out of receiving promotional emails from us by following the instructions in those emails. If you opt out, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations. You may also send requests about your contact preferences and changes to your information including requests to opt-out of sharing your personal data with third parties by emailing firstname.lastname@example.org.
Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Website.
If you have provided your phone number and consented to receive text messages, you may revoke your consent at any time by texting “STOP” to the applicable short code.
Third Party Sites and Links
Our Services may contain links to third party websites and features. This Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their websites, features or policies. Please read their privacy policies before you submit any data to them.
The Website is not directed to children under the age of 13. If you believe a child has provided us with information, contact us at email@example.com.
We take reasonable organizational, technical and administrative steps to help protect personal data against loss, misuse, unauthorized access or disclosure. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure.
Your California Privacy Rights
If you are a California resident, you have the right to request information from us regarding the manner in which GSC shares certain categories of personal information with third parties for their direct marketing purposes, in addition to the rights set forth above or to be informed that GSC has a policy in place to prevent such sharing. GSC has implemented such a policy and does not share your personal information with any third parties for their direct marketing purpose.
EU-U.S. Privacy Shield
GSC complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from the EU to the United States. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, the Privacy Shield Principles and to view our certification, please visit www.privacyshield.gov.
Our participation in the Privacy Shield applies to all Personal Information that is received from the European Union and European Economic Area.
We remain responsible and liable under the Privacy Shield Principles if third-party agents that we engage to process Personal Information on our behalf do so in a manner inconsistent with the Principles, unless we can prove that we are not responsible for the event giving rise to the damage.
You may request access to any Personal Information maintained on you by GSC at any time by emailing firstname.lastname@example.org.
If you believe that we have not adhered to this Policy, please contact us by e-mail at email@example.com. We will do our best to address your concerns. If you feel that your complaint has been addressed incompletely, we invite you to let us know for further investigation. For any complaints that cannot be resolved with GSC directly, we have chosen to settle the dispute exclusively under the JAMS Streamlined Arbitration Rules or JAMS International Mediation Rules). To file a complaint via JAMS, please visit https://www.jamsadr.com/eu-us-privacy-shield.
For complaints left unresolved by all other available mechanisms, you may invoke binding arbitration with the Privacy Shield Panel, which consists of a pool of 20 arbitrators designated by the Department of Commerce and the European Commission, from which the parties will be able to select either one or three arbitrators.
GSC is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
Changes to This Policy
We may change this Policy from time to time. If we make any changes to this Policy, we will change the “Last Updated” date above. If we make any material change(s) to the Policy, we will post a notice on our Website prior to such changes(s) taking effect.