Effective Date: May 30, 2013
Attention: Legal Department
301 Congress Avenue, Suite 700
Austin, Texas 78701
- Types of Personal Information We Collect
- How RetailMeNot Collects Personal Information
- How RetailMeNot Uses Personal Information
- When and Why RetailMeNot Discloses Personal Information
- Cookies and Related Technologies
- Your Choices
- Accessing and Correcting Personal Information
- Security of Personal Information
- Notice to Residents of Countries outside the United States of America
- Privacy Practices of Third Parties
- Children's Privacy
- California Privacy Rights
1. Types of Personal Information We Collect
Personal Information is information that can be used to identify, locate, or contact an individual. It also includes other information that may be associated with Personal Information. We collect the following types of Personal Information:
- Contact Information that allows us to communicate with you, such as your name, postal addresses, email addresses, social media website user account names, telephone numbers, or other addresses at which you receive communications from or on behalf of RetailMeNot.
- Relationship Information that helps us to understand who you are and what types of coupons you might like. This includes lifestyle, preference, and interest information; location information related to your state/province, city, or neighborhood; the types of coupons that interest you; information collected from social media interactions (such as via Facebook Connect); and demographic information (e.g., birth date, age, gender).
- Transaction Information about how you interact with the Services, such as the coupons you view and redeem and the stores you prefer; other information about how you use our Services, email, other communications, and applications; and how you interact with RetailMeNot's merchants, business partners, and service providers.
- Location Information to help us offer you coupons for merchants nearby, if you have activated our Services on a mobile device and permitted your mobile device to transmit location data. Please see the Your Choices section under the heading “mobile” for more information on the types of Personal Information that RetailMeNot may collect from the Services operating on a mobile device.
2. How RetailMeNot Collects Personal Information
We may ask you for Personal Information when you register, subscribe, create an account, or otherwise interact with the Services or contact RetailMeNot. For example, you may be required to provide us with Contact Information or Relationship Information in order to register for certain services.
We also collect Transaction Information if you contact us via telephone, email, text, postal mail, social media interaction, or other methods of communication, such as for customer support purposes.
If you use a social media platform, a mobile device or other third-party method of communication to interact with RetailMeNot or the Services, that platform may have a specific privacy statement that governs the use of Personal Information related to that platform. If you have questions about the security and privacy settings of your mobile device, please refer to instructions from your mobile service provider or the manufacturer of your device to learn how to adjust your settings.
If you use the Services on a mobile device and your mobile device's settings allow it, we may collect Personal Information from your mobile device. Our application may be designed to collect information even if you are not logged into one of the Services. Please see the Your Choices section under the heading “mobile” for more information on the types of Personal Information that RetailMeNot may collect from the Services operating on a mobile device.
From time to time, we may obtain additional Personal Information from third parties. For example, we may collect Personal Information from third parties to enhance other information we have about you, to help us better understand you, and to otherwise enhance the Services.
3. How RetailMeNot Uses Personal Information
RetailMeNot uses Personal Information to:
- Operate and improve our Services;
- Provide users with coupons for products and services from participating merchants, including coupons based on variables such as stated and anticipated user interests, personal characteristics, or location;
- Evaluate eligibility of users for certain coupons, products or services;
- Provide card-linked offers;
- Evaluate the types of coupons, products or services that may be of interest to users;
- Track redemption of coupons and perform other analytics;
- Provide user support, including to our merchants or business partners;
- Fulfill requests for RetailMeNot services;
- Communicate and provide additional information that may be of interest to you about RetailMeNot and our merchants and business partners, such as RetailMeNot news, special offers and coupons, announcements, and marketing materials;
- Send you reminders, technical notices, updates, security alerts and support and administrative messages service bulletins, or marketing;
- Provide advertisements to you through the Services, third-party sites, email messages, text messages, applications, or other methods of communication;
- Administer surveys, sweepstakes, contests, or other promotional activities or events sponsored by us or our partners;
- Create user profiles that may contain inferences about users such as age range, income range, gender, and interests;
- Allow you to apply for a job, post a video or sign up for special offers from third parties through the Services; and
- Carry out other purposes that are disclosed to you and to which you consent.
4. When and Why RetailMeNot Discloses Personal Information
We may share your Personal Information as required or permitted by law as described below:
- With affiliated companies (e.g., subsidiaries and other companies owned by or controlled by RetailMeNot) who may only use the Personal Information for the purposes described in Section 3 above;
- With our service providers that provide services for us to assist us in carrying out the purposes described in Section 3 above such as sending emails on our behalf, processing payments, and facilitating card-linked offers. Qualcomm Labs, Inc., for example, is a service provider that enables certain geo-location features of our mobile-device applications. Consequently, Qualcomm Labs, Inc. and its affiliates collect, store, and process, on RetailMeNot’s behalf, certain Location Information and related data on servers in the United States. Our service providers are bound by law or contract to protect Personal Information and are only allowed to use the Personal Information in accordance with the terms of our service agreements with them;
- Merchants, but only to the extent you have redeemed a coupon offered by the merchant, or participated in an offer, contest or other activity sponsored or offered through RetailMeNot on behalf of the merchant;
- RetailMeNot business partners or advertisers, as part of an offer, contest, or other activity that is provided by or in conjunction with RetailMeNot and its business partners and in which you have elected to participate. For example, if you are referred to RetailMeNot from a business partner's website or through an invitation facilitated by or in conjunction with a RetailMeNot business partner, RetailMeNot may provide that business partner with Contact Information and Transactional Information to validate the referral and to support the terms of the relationship between RetailMeNot and the business partner, which may allow such business partner to contact you directly and to advertise to you;
- To effect a merger, acquisition, or otherwise; to support the sale or transfer of business assets; to enforce our rights or protect our property; to protect the rights, property or safety of others, investigate fraud, respond to a government request; or as needed to support auditing, compliance, and corporate governance functions. We may also disclose Personal Information to defend ourselves in litigation or a regulatory action, and when required or advised to do so by law, such as in response to a subpoena, or similar legal process, including to law enforcement agencies, regulators, and courts in the United States and other countries where we operate. If RetailMeNot is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or prominent notice on one or more of our Services of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information; or
Otherwise with your consent.
We may also disclose information about you that is not personally identifiable. For example, we may provide our merchants, business partners, or other third parties with reports that contain aggregated and statistical data about our users.
When you use our Services, we collect certain information by automated or electronic means, using technologies such as cookies, pixel tags and web beacons, browser analysis tools, and web server logs. As you use our Services, your browser and devices communicate with servers operated by us, our business partners and services providers to coordinate and record the interactivity and fill your requests for services and information.
The information from cookies and related technology is stored in web server logs and also in web cookies kept on your computers or mobile devices, which are then transmitted back to our Services by your computers or mobile devices. These servers are operated and the cookies managed by us, our business partners or our service providers.
For example, when you access our Services, RetailMeNot and our service providers may place cookies on your computers or mobile devices. These cookies may include means for tracking your Transaction Information with a Merchant and may include tracking technology from third-party affiliate-network operators like LinkShare and Commission Junction. Cookies allow us to recognize you when you return, and track and target your interests in order to provide a customized experience. They also help us provide a customized experience and help us to detect certain kinds of fraud. A "cookie" is a small amount of information that a web server sends to your browser that stores information about your account, your preferences, and your use of the Services. Some cookies contain serial numbers that allow us to connect your activity with the Services with other information we store about you in your profile or as related to your other interactions with the Services.
Some cookies are temporary, whereas others may be configured to last longer. "Session" cookies are temporary cookies used for various reasons, such as to manage page views. Your browser usually erases Session cookies once you exit your browser. "Persistent" cookies are more permanent cookies that are stored on your computers or mobile devices even beyond when you exit your browser. We use Persistent cookies for a number of purposes, such as retrieving certain information you have previously provided (such as your user id if you asked to be remembered), and storing your preferences.
Pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed specific actions. When you access these pages or open email messages, the pixel tags and web beacons generate a notice of that action to us, or our service providers. These tools allow us to measure response to our communications and improve our web pages and promotions.
We collect many different types of information from cookies and other technologies. For example, we may collect information from the devices you use to access our Services, your operating system type or mobile device model, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone of your device. Browsers routinely send these types of information to web servers. Our server logs also record the Internet Protocol ("IP") addresses of the devices you use to interact with the Services. An IP address is a unique identifier that devices use to identify and communicate with each other on the Internet. We may also collect information about the website you were visiting before you came to our Services and the website you visit after you leave our Services, if this information is supplied to us by your browser.
We also use third party services, such as Google Analytics, to help us understand how visitors interact with our website and to help improve our user experience.
6. Your Choices
We think that you benefit from a more personalized experience when we know more about you and the kinds of coupons you like. However, you can limit the information you provide to RetailMeNot, and you can limit the communications that RetailMeNot sends to you.
You can manage your email preferences by logging into the Community at www.retailmenot.com/community and clicking on the "Email Preferences" link. You can also manage your subscriptions by following subscription management instructions contained in the commercial messages that we send you. You may choose to subscribe to some types of messages, and may choose to unsubscribe from others. You may also update your subscription preferences from time to time. If you wish to opt out of receiving offers directly from RetailMeNot merchants or business partners, you can follow the opt-out instructions in the emails that they send you.
You may manage how your browser handles cookies and related technologies by adjusting its privacy and security settings. Browsers are different, so refer to instructions related to your browser to learn about cookie-related and other privacy and security settings that may be available. Please note that if you disable cookies, you may be unable to access some customized features of our Services. You can opt-out of being targeted by certain third party advertising companies online at www.networkadvertising.org/consumer/opt_out.asp.
You may opt-out of sharing your Location Information by toggling off the “Location” option within the “Settings” menu of our mobile- device applications. (This feature is available in our iOS-based applications, version 2.2 or higher and in our Android-based applications, version 2.0 or higher).
Alternatively, you may adjust the settings on your mobile device to prevent the sharing of Location Information. You may also manage how your mobile device or mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your mobile device and mobile browser settings. Please note that if you disable the sharing of Location Information, you may be unable to access some features of our Services that are designed for mobile devices.
Connecting through Social Networks
RetailMeNot App on Facebook
The RetailMeNot App on Facebook (the “App”) provides two separate privacy controls that allow you to control sharing of your actions taken from within the App, such as selecting a favorite store or saving a coupon. First, you can adjust the App's settings in order to control sharing outside of the App (e.g., with other Facebook users who have not authorized the App themselves). Second, you can adjust the App's sharing button to control sharing throughout Facebook (e.g., with all Facebook users regardless of whether they have authorized the App themselves). Both of these controls are explained in more detail below.
When you authorize the App, you may select who on Facebook can see activity created by your actions outside of the App. The default setting is “Friends”. The “Friends” setting means that your activity within the App may be shared outside of the App with your friends. For example, some of your friends may see, on your activity feed, newsfeed, ticker, and elsewhere on Facebook, the coupons you save or redeem.
During the authorization step, pictured above, you can change this setting to “Public”, “Only Me” or “Custom”. Alternatively, at any time after authorizing the App you can update your settings in Facebook by visiting Account Settings > Apps > RetailMeNot > Edit and changing the selection for "Posts on your behalf:"
Please note that the “Only Me” setting means that your activity within the App will not be shared outside of the App with other Facebook users. However, the App will continue to post your activity on a unique profile page that is shared with your friends who have authorized the App themselves unless you turn off the App's sharing button as explained below.
When you begin using the RetailMeNot App on Facebook, a unique profile page is created to display your actions taken from within the App. This profile page is automatically shared with any of your friends who have also authorized the App. The App's sharing button allows you to control (i) what activities are posted to your unique profile page and (ii) what activities are shared outside of the App.
At any time during your use of the App, you can click the sharing button, pictured above, to “OFF” or “ON”. The default setting of the App's sharing button is “ON”. Setting the App's sharing button to “ON” means your activities (regardless of the App's settings described above) will be posted to your unique profile page which is shared with all of your friends who have also authorized the App.
Turning the App's sharing button to “OFF” will prevent your actions taken from within the App (while the sharing button is set to “OFF”) from being posted to your unique profile page. In addition, your actions taken from within the App while the sharing button is set to “OFF” will not be displayed outside of the App, regardless of the App's settings described above. In this manner, the App's sharing button functions as an override to the App's settings to ensure you may control sharing of your activity from right within the App. If you have any questions concerning these privacy controls, please do not hesitate to Contact Us.
RetailMeNot SMS Programs
To utilize certain features of the Services, you may be required to enter your mobile phone number. We will only use your mobile phone number to send you specific coupons that you have requested to be sent to your mobile device and to send you alerts, from time to time, related to special coupon offers. You can opt out of RetailMeNot SMS programs at any time by emailing [email protected] or texting STOP to 42767 from your mobile device. Standard messaging rates may apply to SMS programs. Check your service carrier plan for your standard text messaging fees.
7. Accessing and Correcting Personal Information
Keeping Personal Information about you current helps ensure that we offer you the best coupons available through our merchants and business partners. You can do several things to help keep Personal Information about you current. You can access, update and delete your Contact Information and the other information you provided us to use in your profile by logging into the Community and clicking on the "Profile" link.
If you want to close your account or have other questions or requests, or if you would like to access or request a correction to any other personal information we hold regarding you, please Contact Us.
We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at [email protected]. In response, we will cancel or remove your information but may retain and use copies of your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
8. Security of Personal Information
RetailMeNot follows generally accepted industry standards to protect the Personal Information that you provide. For example, we regularly monitor our system for possible vulnerabilities and attacks, and we use a tier-one secured-access data center. No method of transmission over the Internet, or method of electronic storage, is one hundred percent secure, however. For this reason, there is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you have any questions about our security practices, please Contact Us.
9. Notice to Residents of Countries outside the United States of America
RetailMeNot complies with the US-EU Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. RetailMeNot 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 our certification page, please visit http://www.export.gov/safeharbor/
RetailMeNot has further committed to refer unresolved privacy complaints under the US-EU Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, 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, please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.
10. Privacy Practices of Third Parties
13. Children's Privacy
RetailMeNot does not intend that any portion of the Services will be accessed or used by children under the age of eighteen, and such use is prohibited. The Services are designed and intended for adults. By using the Services, you represent that you are at least eighteen years old and understand that you must be at least eighteen years old in order to create an account and purchase the goods or services advertised through the Services. We will promptly delete information associated with any account for which we obtain actual knowledge that the registered user associated with the account is not at least eighteen years old.
14. California Privacy Rights
Pursuant to Section 1798.83 of the California Civil Code, residents of California can obtain certain information about the types of Personal Information that companies with whom they have an established business relationship have shared with third parties for direct marketing purposes during the preceding calendar year. In particular, the law provides that companies must inform consumers about the categories of Personal Information that have been shared with third parties, the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. To request a copy of the information disclosure provided by RetailMeNot pursuant to Section 1798.83 of the California Civil Code, please contact us via email to [email protected], or by writing us at the following address:
Attention: Legal Department
301 Congress Avenue, Suite 700
Austin, Texas 78701
Please allow 30 days for a response.