Effective Date: January 1, 2020
COLLECTION OF INFORMATION
Information You Provide
As part of your use of our Service, we may ask you to provide information directly to us. For example, we collect information when you register an account, communicate or transact with us, or submit feedback on certain products, by way of surveys, testimonials, ratings and reviews or other format through the Service.
The information we collect may include information that identifies you personally (whether alone or in combination), such as your name, address, phone number, email address, age, and gender ("Personal Information"). In addition, in order to match you with promotional samples of certain third party products or services ("Third Party Product Samples") that are provided by our third party brand partners ("Brand Partners"), we may ask you to provide additional information. Some examples of possible requested information include your relationship status, household information, pet information, product preferences, and shopping habits. You may choose to voluntarily submit certain other information to us through the Service, including Personal Information.
In some cases, we may collect information that you provide about others, including Personal Information, such as when you refer a friend. We will use the information you provide to fulfill your requests, such as sending information about our Service to your friend’s email address. By using this functionality, you acknowledge and agree that both you and your friend are based in the United States and that you have your friend’s consent for us to use his or her contact information to fulfill your request.
Information Collected Automatically
When you access our Service, we and our third-party service providers may use a variety of technologies, now and hereafter devised, that automatically record certain usage information about you ("Usage Information"). Usage Information may include your Internet Protocol address (and other unique identifiers for the particular device you use to access the Internet), browser type, your web or application request, your interaction with our Service, the webpage or other feature you were using before you came to our Service, pages of our websites that you visit, information you search for via our Service, access times and dates, and other similar information. We use this information for a variety of purposes, including analyzing and enhancing our products and services, and to help personalize our Service for you. Your Internet Protocol Address and other items automatically collected may be considered Personal Information.
The methods that may be used on the Service to collect Usage Information include:
Log Information: Log information is data about your use of the Service, such as IP address, browser type, internet service provider, referring/exit pages, operating system, date/time stamps, and related data, which is stored in log files.
Information Collected by Tracking Technologies: We and our third-party service providers may automatically collect information about your interactions with the Service or emails using various tracking technologies, including cookies, web beacons (also known as "tracking pixels"), embedded scripts, location-identifying technologies, device fingerprinting, in-app tracking methods, and other tracking technologies now and hereafter developed ( "Tracking Technologies" ).
Cookies: A cookie is a small data file transferred to your computer (or other device) when it is used to access our Service. Cookies may be used for many purposes, including to enable certain features of our Service, to better understand how you interact with our Service and to monitor aggregate usage by visitors and online traffic routing. Cookies may remain on your device for extended periods of time.
Web Beacons (“Tracking Pixels”): Web beacons are small graphic images, also known as "internet tags" or "clear gifs," embedded in web pages and email messages. Web beacons may be used to count the number of visitors to the Service, to monitor how users navigate the Service, and to count content views.
Embedded Scripts: An embedded script is programming code designed to collect information about your interactions with the Service. It is temporarily downloaded onto your device from our web server or a third party with whom we work, is active only while you are connected to the Service, and deleted or deactivated thereafter.
In-App Tracking Methods: There are a variety of tracking technologies that may be included in mobile apps, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifier, or other identifiers such as “Ad IDs” to associate app user activity to a particular app and to track user activity across apps.
Some information about your use of the Service and certain Third Party Services (defined below) may be collected using Tracking Technologies across time and services and used by us and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Service and certain Third Party Services.
For further information on Tracking Technologies and your choices regarding them, please see “Third Party Services, Features, and Devices” and “Your Choices” below.
Information from Other Sources
USE OF INFORMATION
The following is a non-exhaustive list of ways that we may use your information:
to manage our Service, identify you as a user of the Service, and help authenticate any account you create with us; to communicate with you regarding campaigns, the Service, updates, offers, promotions or events and to deliver Third Party Product Samples to you (for information about how to manage these communications and marketing efforts, please see “Your Choices” below); to help us develop, customize, deliver, support and improve our Service, products, Third Party Product Sample offerings, and advertising and to provide you with the best user experience possible; to administer promotions, contests, sweepstakes or other offerings; to protect the rights or property or security of PINCHme or our users, and prevent fraud and other prohibited or illegal activities; to respond to your comments, questions, and requests, and provide customer service; to send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages; for our internal purposes (such as auditing, data analysis, and research to improve our services, and communications); and for any other purpose as may be disclosed to you at the point of collection or otherwise with your consent.
SHARING OF INFORMATION
With Our Service Providers
We may engage third parties to perform services on our behalf, such as hosting and storage services, software maintenance services, email notifications, database management, analytics, fulfilment services, and other services. These third parties may have access to your Personal Information to perform certain tasks on our behalf but they are not authorized by us to otherwise use or disclose your Personal Information.
With Our Brand Partners
If you choose to submit any information or materials to us including, without limitation, testimonials, ratings and reviews, product feedback, data files, written text, computer software, music, audio files or other sounds, photographs, videos, and other images) (collectively, “Content”), we may share the Personal Information you include in that Content, if any, with our Brand Partners.
To Comply with Laws, Legal Process and Authorities and Protect Rights
We may disclose Personal Information or other information about you to government or law enforcement officials, in connection with subpoenas or judicial process, or to any other third party to protect the property and rights of us or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable.
For Business Transfers
We reserve the right to transfer or otherwise disclose your information, including Personal Information, in connection with a merger, acquisition, or other change in control, joint venture, reorganization or sale of assets or in the event of bankruptcy or liquidation proceeding.
With Our Affiliates for Internal Business Purposes
We may disclose information about you, including Personal Information, with our affiliates for internal business purposes.
For Direct Marketing Purposes
We may disclose information about you, including Personal Information, with our affiliates, business partners, and other third parties including, Brand Partners, for their own business purposes, including direct marketing purposes (California residents have certain rights set forth in “Your California Privacy Rights” below).
With Sponsors and Other Third Parties for Sweepstakes, Contests, Promotions
In addition, if you voluntarily participate in a sweepstakes, contest, rewards program or other promotion through our Site or Service, we may share your information, including Personal Information, with the participating sponsors or with third parties who assist us in using the content or other information you have posted or shared with us. By participating, you agree to the official rules that govern that promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials.
With your Consent
We may disclose information about you, including Personal Information, with your consent or at your direction, or for purposes disclosed at the time you provide the information.
Without limiting the foregoing, in our sole discretion, we may share aggregated information (including information collected for purposes of selecting relevant Third Party Product Samples) which does not identify you or de-identified information about you with third parties or affiliates for any purpose.
THIRD PARTY SERVICES, FEATURES, AND DEVICES
Our Service also contains Tracking Technologies operated by third parties. For example, analytics services, such as Google Analytics, may use Tracking Technologies on our Service to help us analyze your use of the Service, compile statistic reports on the Service’s activity, and provide other services relating to Service activity and internet usage. Similarly, ad serving services, advertisers, and other third parties may use Tracking Technologies on our Service and Third Party Services to track your activities across time and services, and tailor ads to you based on your activities, which may include sending you an ad on a Third Party Service or third party device after you have left the Service (“Interest-based Advertising”).
Changing or Deleting Your Information
To view and change Personal Information that you have directly provided to PINCHme via the Service, you can contact PINCHme by sending an email to privacy@PINCH.me or by or sending us a letter to PINCHme.com, Inc., 611 Broadway, Suite 308 New York NY 10012 (Attention: Legal). Requests must include your name, street address, city, state, and ZIP code. Please note that we are not required to respond to requests made by means other than through the provided email address or mail address. Information may also be accessible via the “Member Profile” section of our website. We may require additional information from you to allow us to confirm your identity. Please note we may retain server/backup copies of all such data, and that we may decline to process change or deletion requests that we deem to be unreasonable, require disproportionate technical effort, jeopardize the privacy of others, or are not required by law. Tracking Technologies Generally
You may be able to instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the online services you visit. Browsers offer different functionalities and options so you may need to set them separately. With respect to our mobile apps, you can stop all collection of information via an app by uninstalling the app. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain location-based services, by adjusting the permissions in your mobile device. If you do not accept cookies or disable these technologies, however, you may not be able to use all portions of our Site or Service, or all functionality of our Site or Service.
You may choose whether to receive Interest-based Advertising by submitting opt outs. Some of the advertisers and Service Providers that perform advertising-related services for us and our partners may participate in the Digital Advertising Alliance ("DAA") Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, visit http://www.aboutads.info/choices and http://www.aboutads.info/appchoices for information on the DAA’s opt out program for mobile apps. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). PINCHme is not responsible for effectiveness of, or compliance with, any third-parties’ opt out options or programs or the accuracy of their statements regarding their programs.
By providing your mobile phone number and using the Service, you hereby affirmatively consent to us sending you ongoing text messages (including by automatic telephone dialing systems) for marketing purposes, including to notify you of newly available Third Party Product Samples and update you about the status of your Third Party Product Sample orders. PINCHme will not assess any charges for text messages, but standard message charges or other charges from your wireless carrier may apply. You can opt-out of receiving certain promotional communications (emails, text messages, and push notifications) from us at any time by: (i) for emails, following the instructions as provided in emails to click on the unsubscribe link, or contacting us at privacy@PINCH.me with the word UNSUBSCRIBE in the subject field of the email; (ii) for text messages, texting “STOP” in response to any text message you receive or contacting us at privacy@PINCH.me and specifying you want to opt-out of text messages; and (iii) for push notifications or in-app messages, adjusting the permissions in your mobile device. Please note that your opt-out is limited to the email address, phone number, or device used and will not affect subsequent subscriptions or, for emails, non-promotional communications, such as those about your account, transactions, servicing, or our ongoing business relations. You understand that we may send you a text message confirming any opt-out by you. If you provide to us the number for a mobile phone or other device, you represent, warrant, and guarantee that such device is registered in your name and owned by you.
YOUR CALIFORNIA PRIVACY RIGHTS
If you are a California resident and wish to obtain information about our compliance with California’s laws pertaining to privacy, please (1) email us at privacy@PINCH.me, (2) send us a letter to PINCHme.com, Inc., 611 Broadway, Suite 308 New York NY 10012 (Attention: Legal). Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are not required to respond to requests made by means other than through the provided email address, website, or mail address.
PINCHme will respond to a verifiable consumer request (as defined by the CCPA) in accordance with applicable privacy laws. PINCHme has the right to require authentication of the consumer in light of the nature of the personal information requested. Under the CCPA, Personal Information does not include (i) information that is lawfully made available from federal, state or local government records, (ii) de-identified or aggregated data or (iii) information excluded from the scope of the CCPA. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request (and will not be made more than twice in a 12-month period). If we cannot comply with all or part of a request, the response we provide will also explain the reason(s) we cannot comply.
We employ reasonable security measures and practices appropriate to the nature of the information you provide to us and designed to protect your information, including Personal Information, from unauthorized access and disclosure. Please be advised that we cannot guarantee or warrant the security of any information you disclose or transmit to us online and are not responsible for the theft, destruction, unauthorized access by third parties or inadvertent disclosure of your Personal Information.
OTHER GENERAL INFORMATION
Public Posts on the Service
PINCHme processes information on our servers in the United States of America. Your information, including Personal Information, may be transferred to, and used by, entities located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. Such export is a requirement of providing your information to PINCHme, and you consent to such transfer and use in all respects.
Our Policy Toward Children
To be a PINCHme Member, you must be over the age of 16. We do not knowingly collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) from children under 13 in a manner that is not permitted by COPPA, and do not target our online services to children under 13. If we discover that someone under the age of 13 has provided personal information, we will delete such information from our Site and Service to the extent required by COPPA. We encourage parents and guardians to prevent children from submitting information or data on our Service, and to contact us at privacy@PINCH.me if they believe we have collected personal information from children under 13.