Effective August 09, 2012
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
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.
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.
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 email@example.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.
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
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 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 firstname.lastname@example.org. 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.
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 email@example.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.
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.
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 firstname.lastname@example.org.
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.
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 email@example.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.
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
36 East 31st Street, 8th floor
New York, NY 10016