Privacy Policy

Effective August 09, 2012

Offerpop Corporation ("Offerpop") provides this Information and Privacy Policy to inform you ("User") of Offerpop's policies and procedures regarding the collection, use and disclosure of information that Offerpop receives from the following:

This Information and Privacy Policy further explains how Offerpop can and will use information received by it from Users in the normal course of Offerpop's business.

Offerpop has been awarded TRUSTe's Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe's Program Requirements and the TRUSTed Cloud Program Requirements including transparency, accountability and choice regarding the collection and use of your personal information. TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us at privacy@offerpop.com. If you are not satisfied with our response you can contact TRUSTe here.

Offerpop complies with the U.S. - E.U. and U.S. - Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from European Union member countries and Switzerland. Offerpop has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Offerpop's certification, please visit http://www.export.gov/safeharbor.

INFORMATION OFFERPOP MAY RECEIVE FROM USERS

  1. Website Users. If you are a Website User, in the course of using the Offerpop Site, you may provide Offerpop with (i) personally identifiable information ("Personal Information") such as your name, phone number, email address, ; and (ii) feedback, suggestions, complaints, or other descriptions of your experiences, preferences, or interests in Offerpop or the Offerpop Applications ("Feedback").
  2. Services Users. If you are a Services User, in the course of using the Offerpop Site or the Offerpop Applications, you may provide Offerpop with (i) Personal Information in your user or account profile with Offerpop, such as your name, phone number, credit card or other billing information, email address, and home and/or business postal addresses; and (ii) Personal Information in your user or account profile with the third party social media platform providers that interact with the Offerpop Applications (such as Facebook or Twitter), that may include, but are not limited to, your log in credentials and profile information you have elected to make public; (iii) Personal Information of your Social Users that you elect to collect, process, and/or store in connection with such Social Users' participation in a campaign or promotion you run on your company's Facebook, Twitter, or other social media website using the Offerpop Applications; and (iv) Feedback.
  3. Social Users. If you are a Social User, in the course of using the Offerpop Applications, Offerpop may receive, directly or through Services Users, Personal Information of yours that may include, but is not limited to, (i) your social media profile (e.g. your Facebook profile name or handle, and its associated email address, but never your password); (ii) information posted on your social media profile such as wall posts, likes, dislikes, or items you follow, but only to the extent that you make this information publicly available or that you provide this information to the Services Users in response to a promotion or other marketing campaign operated by the Services Users by use of the Offerpop Applications.
  4. If you are a Social User we may provide you the opportunity to refer friends to a Services User promotion. If you choose to do so we will may ask you for your friend's name and email address. We will automatically send your friend a one-time email inviting him or her to view the Services User promotion. Offerpop stores this information for the sole purpose of sending this one-time email and tracking the success of the referral. Your friend may contact us at privacy@offerpop.com to request that we remove this information from our database.
  5. Offerpop collects information under the direction of its Services Users, and has no direct relationship with the individuals whose personal data it processes. Offerpop works with its Services.

INFORMATION OFFERPOP COLLECTS

In addition to the information identified above, and regardless of the type of User you are, when you visit the Site, Offerpop's servers and our third party tracking-utility partners gather certain information automatically record information that your browser sends whenever you visit a website through log files. This information may include, but is not limited to, your computer's Internet Protocol address, browser type, the web page you were visiting before you came to our Site and information you search for on our Site.

Cookies. Like many websites, Offerpop also uses "cookies" to collect information. We do link the information we store in cookies to any personally identifiable information you submit while on our site. A cookie is a small data file that we transfer to your computer's hard disk for record-keeping purposes. Offerpop uses "persistent cookies" to save your registration ID and login password for future logins to the Site; and we use "session ID cookies" to enable certain features of the Site, to better understand how you interact with the Site and to monitor aggregate usage and web traffic routing on the Site. Most browsers automatically accept cookies. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Site or all functionality of our services.

The use of cookies by our service providers and Services Users is not covered by our privacy statement. We do not have access or control over these cookies. Our service providers and Services Users use session ID and other cookies to track performance of website and campaigns.

We employ or our third party service providers employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user's computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We tie the information gathered by clear gifs to our customers' personally identifiable information.

We use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.

Flash cookies. Offerpop also uses Local Shared Objects or "Flash Cookies" to collect data pertaining to use of the Offerpop website. These Flash Cookies affect only Website Users and Service Users, and do not affect Social Users. Flash Cookies are pieces of data that websites which use Adobe Flash may store on a user's computer. Flash Cookies contain data stored by individual websites, and by default, Flash Player does not seek the user's permission to store Flash Cookies on your hard disk. You should be aware that some web browsers, and many older versions of the most popular browsers, may not permit you to block the use of Flash Cookies; in addition, browser settings that block conventional cookies may not affect Flash Cookies. On the latest versions of some popular browsers (Google Chrome, Mozilla Firefox, and Microsoft Internet Explorer), you may adjust browser settings to block the use of Flash Cookies and, for some browsers, add on programs are available to assist in this process. Another method of preventing Flash cookies from being placed, in addition to adjusting the settings on your updated browser, is to adjust your preferences in the Macromedia Website Privacy Settings Panel at www.macromedia.com/support/documentation/en/flashplayer/help.

HOW OFFERPOP USES INFORMATION

We will share your personal information with third parties only in the ways that are described in this privacy statement. Offerpop uses Personal Information obtained by technical means or directly or indirectly from Users for the following purposes: (i) to provide and improve the Site, the Offerpop Applications, the services, features and content, (ii) to administer Services Users' membership and Users' use of our Site, (iii) to enable Users to enjoy and easily navigate the Site and Offerpop Applications, (iv) to better understand Users' needs and interests, (v) to fulfill requests Users may submit to Offerpop, (vi) to personalize Users' experience on the Site or Offerpop Applications, (vii) to provide or offer software updates and product announcements, and (viii) to provide Users with further information and offers from Offerpop or third parties that Offerpop believes Users may find useful or interesting, including newsletters, marketing or promotional materials and other information on services and products offered by Offerpop or third parties.

If you are a Social User, by participating in any campaign or promotion operated by the Offerpop Applications, you hereby acknowledge and agree that Offerpop will receive, use, store, process, and share your Personal Information with the relevant Services User who is operating a marketing campaign or promotion in which you elect to participate, but solely as necessary for Offerpop to (a) facilitate Services Users' use of the Offerpop Applications during such campaign or promotion; and (b) create aggregate reports or other marketing analyses that do not identify Social Users personally for the relevant Services Users operating the campaign or promotion, or for Offerpop's internal business and marketing analysis. You are hereby informed that it is your responsibility to review and consent to each Services Users' privacy policies and those of the applicable social media platform prior to participating in any marketing campaign or event. Any Personal Information you submit to a Services User or the social media site from which you initiate your participation in a marketing campaign or promotion using the Offerpop Applications will be governed by the Services User's privacy policy or that of the social media site (and not this Information and Privacy Policy). You understand and agree that Offerpop does not direct any Services User to collect any Personal Information from Social Users, and therefore Offerpop assumes no liability in connection with any misuse by a Services User or social media site of your Personal Information, or the failure of the Services User or social media site to obtain your consent to use your Personal Information if such is legally required.

SERVICE PROVIDERS AND BUSINESS PARTNERS

Offerpop may employ third party companies and individuals to operate the Site or the Offerpop Applications to perform Site-related services (such as to maintenance services, database management, customer support, sending emails on our behalf and web analytics and improvement of the Site's features) or to assist us in analyzing how the Site and the Offerpop Applications are used. These third parties have access to your Personal Information only for purposes of performing these tasks on Offerpop's behalf.

Offerpop may also provide Personal Information to its business partners or other entities with whom Offerpop has cooperative relationships so that they can send you promotional and other information you have requested from Offerpop or such business partners. If you provide us with your Personal Information for these purposes and would no longer prefer it be used you may contact us at privacy@offerpop.com.

CREDIT CARD PROCESSING

Offerpop uses an outside, PCI-compliant card processing company to bill Services Users who are purchasing services from Offerpop. This information is collected and transmitted in a secure manner, using SSL encryption. The credit card processing company does not retain, share, store or use Personal Information for any secondary purposes beyond filling your order. In addition, Offerpop will not collect credit card data from Social Users who participate in marketing campaigns or promotions.

USER PROFILE INFORMATION

If you are a Services User, Offerpop will display your Personal Information in your profile page and elsewhere on the Site according to the preferences you set in your account. You can review and revise your profile information at any time by logging on to your account and making the applicable changes.

If you are either a Website User or a Services User and decide at any time that you no longer wish to receive email or marketing communications from Offerpop, please follow the unsubscribe instructions provided in any of the communications.

If you are a Social User, you may have the ability to create, review, revise, and delete personal profile pages by using certain features in the Offerpop Applications run by Services Users on their social media webpages. If you elect to create a personal profile page on a Services User's social media webpage, then you understand and agree that Offerpop may receive, store, process, and use, any such profile information as necessary to make the relevant features of the Offerpop Applications available to the applicable Services Users, and as otherwise set forth in this Information and Privacy Policy. For example, you may upload or link photographs, video, or other content, likes, comments, or other items you have posted from your social media site onto your profile page on the Services User's social media website. You can review and revise your profile information, or change your sharing preferences at any time by logging on to your social media account and making the applicable changes. To the extent that any of this information is Personal Information, you understand and agree that Offerpop may use that Personal Information for the purposes outlined in this Information and Privacy Policy.

We collect information for our Services Users, if you are a Social User of one of our Services Users and would no longer like to be contacted by one of our Services Users that use our service, please contact the Services Users that you interact with directly.

PUBLICLY-AVAILABLE PERSONALLY-IDENTIFIABLE INFORMATION

Regardless of the type of User you are, you should be aware that Personal Information covered under this Information and Privacy Policy does not and shall not include any information, whether it personally identifies you or not, that you have already made publicly accessible, including through a social media site, or have consented to make public through your participation in a marketing campaign on a social media site.

Offerpop hereby notifies you that, while Offerpop discourages the collection and use of any sensitive personally-identifiable information on the part of its Services Users, Offerpop does not and cannot review or monitor the type of information which Services Users choose to collect from Social Users as a condition to, or in the course of, operating a promotion or other marketing campaign by use of the Offerpop Applications.

SOCIAL MEDIA FEATURES

Our Web site includes Social Media Features, such as the Facebook Like button. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

OUR POLICY TOWARD CHILDREN

Neither the Site nor the Offerpop Applications are directed to children under 18. Offerpop does not knowingly collect Personal Information from children under 13. If a parent or guardian becomes aware that his or her child has provided Offerpop with Personal Information without their consent, he or she should contact us at privacy@offerpop.com. If Offerpop becomes aware that a child under 13 has provided Offerpop with Personal Information, Offerpop will delete such information from its files, and perform any other acts necessary to comply with applicable law or regulations.

AGGREGATE INFORMATION

Offerpop reserves the right to use and disclose any information that is aggregate in format or does not contain Personal Information (such as statistics and survey results that do not identify you individually by name).

ACCESS TO, CHANGING OR DELETING YOUR INFORMATION

All Service Users may review, update, correct or delete the Personal Information provided in their registration or account profile by making changes on the settings page of the Offerpop Site or by contacting us at privacy@offerpop.com . If you completely delete all such information, then your account may become deactivated and you will not be able to use the Offerpop Applications.

Any User may communicate with Offerpop to inquire about Offerpop's practices set forth in this Information and Privacy Policy. Users who opt-in to receive mailing or other communications may opt-out from receiving such marketing communications from Offerpop at any time by calling Offerpop, following the specific instructions in the email you receive, or by notifying Offerpop via the following contact email address: privacy@offerpop.com.

Please note that the above will not apply to communications about the Offerpop Applications that are considered part of Offerpop's service, in which case you will continue to receive such communications and may not opt out of receiving them unless you cancel your subscription to the Offerpop Applications.

If you are a Social User, your Personal Information may not be stored in a way that enables Offerpop to individually excise your data. However, your Personal Information will be expunged, overwritten and/or permanently deleted from Offerpop's servers in accordance with Offerpop's industry-standard data retention policies and procedures.

Offerpop has no direct relationship with the individuals whose personal data it processes. A Social User who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to Offerpop's Services User (the data controller). If the Services User requests Offerpop to remove the data, we will respond to their request within 30 business days.

We will retain your information as well as information we process on behalf of our Services User for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Offerpop will respond to requests for access within 30 days.

TESTIMONIALS

We post customer testimonials on our web site which may contain personally identifiable information. We do obtain the customer's consent via email prior to posting the testimonial to post their name along with their testimonial. If you want your testimonial removed please contact us at marketing@offerpop.com.

FEEDBACK

By providing Offerpop with Feedback, you hereby grant to Offerpop a royalty-free, worldwide, transferable, sublicenseable, irrevocable, perpetual license to use any Feedback and/or to incorporate such Feedback into the Site, or Offerpop Applications or any service or product developed by Offerpop. You acknowledge and agree that any Offerpop Application, the Site, or other product or service incorporating such suggestions, enhancement requests, recommendations or other feedback shall be the sole and exclusive property of Offerpop and all such recommendations shall be free from any confidentiality restrictions that might otherwise be imposed upon Offerpop pursuant to your written or electronic agreement with Offerpop.

LINKS; MARKETING CAMPAIGNS

The Offerpop Site and the Offerpop Applications may contain links to other sites. Please be aware that Offerpop is not responsible for the content or privacy practices of such other sites. Offerpop encourages all Users to read the privacy statements of any other site that collects personally-identifiable information.

INFORMATION SECURITY

Offerpop takes industry-standard precautions to protect Personal Information. For example, whenever Offerpop collects credit card data or other payment information, that information is protected using industry standard encryption and transmitted to Offerpop in a secure way. You can verify this by looking for "https" at the beginning of the address of the particular web page.

While the safeguards implemented by Offerpop may help prevent or slow unauthorized access, maintain data accuracy, and facilitate the appropriate use of data, NO GUARANTY IS OR CAN BE MADE THAT YOUR INFORMATION IS SECURE FROM INTRUSIONS AND OR UNAUTHORIZED ACCESS BY THIRD PARTIES. If you have any questions about security on our Web site, you can contact us at support@offerpop.com.

COMPLIANCE WITH LAWS AND LAW ENFORCEMENT

Offerpop cooperates with government and law enforcement officials and private parties to enforce and comply with law. Offerpop will disclose any information about you to government or law enforcement officials or private parties as Offerpop, in its sole discretion, believes necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Offerpop or a third party, to protect the safety of the public or any person, or to prevent or stop any activity Offerpop may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable.

BUSINESS TRANSFERS

Offerpop may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy. You will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

LOCATION OF OFFERPOP SERVERS

Offerpop's computer systems are currently based in the United States, so your Personal Information will be processed by us in the United States. In accordance with applicable law, Personal Information collected on the site may be transferred, stored and processed in the United States. By submitting your Personal Information to Offerpop or the Offerpop Applications, directly or indirectly through a Services User, you consent to such processing of your personal information.

CHANGES TO THIS POLICY

Offerpop may revise this Information and Privacy Policy from time to time. The most current version of the policy will govern Offerpop's use of Personal Information and will always be at http://offerpop.com/privacy-facebook-twitter-marketing. If Offerpop makes a change to this policy, Offerpop may notify you via an e-mail to the email associated with your account or the change will be effective by posting the change to the Site. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. By continuing to access or use the Site or the Offerpop Applications after those changes become effective, you agree to be bound by the revised Information and Privacy Policy.

CONTACTING US

If you have any questions about this Information and Privacy Policy, please contact us at privacy@offerpop.com, or by mail to:

Offerpop Corporation
36 East 31st Street, 8th floor
New York, NY 10016