Shopkick Privacy Policy

Welcome to Shopkick!

Here at Shopkick, we are committed to being open and transparent with you about how we collect, store, share, or otherwise ‘process’ your personal information. This Privacy Policy lays out how and why we process your personal information, along with explaining your individual rights and how you can exercise them to give you control over your personal information.

Who we are

Shopkick Inc., including our parent company and affiliates “Shopkick”, “we”, “us” is a mobile application (the “Shopkick App”) that rewards consumers for shopping when they scan products, upload receipts, shop online, and more! Through our Shopkick App, consumers earn reward points, or “kicks” that they can use to claim free gift cards for well-known brands and retailers that partner with us. We currently offer our services to consumers based in the US and Puerto Rico.

This Privacy Policy relates to the processing of:

• Consumer personal information that we collect when individuals sign up to and/or use the Shopkick App.
• Consumer personal information that we collect from our brand and retail partners and payment card networks to deliver our Shopkick App and related services.
• Personal information of the employees, or similar individuals that work for or with our current and potential future brand and retail partners.
• Personal information of any other person that visits our website or provides information to us.

When we refer to “personal information” in this Privacy Policy we mean: “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly to a particular individual or household.”

Please read this Privacy Policy carefully. By using the Shopkick App, visiting our website and otherwise sharing any personal information with Shopkick, you are agreeing to the terms of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not register, subscribe, create an account or otherwise interact with Shopkick.

If you have any questions about this Privacy Policy then we are happy to help – please contact us at: help@shopkick.com Please include the words ‘Privacy request’ in the title bar of any emails you send to us.

This Privacy Policy is split into the following sections:

1. How do we collect your personal information?
2. What personal information do we process about you (including sensitive personal information) and why?
3. Who do we disclose your personal information to?
4. How do we use cookies and similar technologies?
5. Your rights and choices.
6. How long do we keep your personal information for?
7. Children’s personal information.
8. For California Consumers – use and disclosure of your sensitive personal information and your rights.
9. For California Consumers – do we ‘sell’ or ‘share’ your personal information and your rights.
10. For California Consumers – Financial Incentive Notice.
11. For Colorado Consumers – do we ‘sell’ or disclose your personal information for targeted advertising purposes and your rights.
12. Third party websites.
13. Changes and updates to this Privacy Policy.
14. How to contact us.

1. How do we collect your personal information?

We collect personal information about you from the following sources depending upon the types of Shopkick services you have signed up for or whether you are a consumer or one of our brand or retail partners.

• From information you provide directly to us through the Shopkick App, via our website, in person at events or through any other communication channels you use to provide information to us, such as through social media channels, online forms and sweepstake entries.
• From information automatically transmitted or collected from your devices via the Shopkick App or when you visit our website – such as your IP address, mobile device ID, location data and other information collected via website cookies and similar technologies that run on our App and website.
• From information provided to us by our brand and retail partners and/or payment card networks – such as credit card details (data is either fully encrypted or consists of the last 4 card digits only) or purchase and product return history (a unique user identification associated with your payment card, transaction amount, date and time and merchant name and location) where you have signed up to certain Shopkick programs such as ‘kicks for purchases’. We collect this information so we can validate a product purchase or return to confirm whether you have qualified for or earned an offer or ‘kicks’ linked to your chosen payment card.
• From information provided to us by our brand and retail partners where Shopkick is acting as a service provider or enabling our partners to undertake promotional and marketing activities on their behalf through the use of our platforms.
• From your linked e-mail account i.e. Yahoo, Google, AOL, Outlook etc. where you have agreed to this and for the purpose of receiving scanned receipts for purchases you have made where you have signed up to the ‘kicks for receipts’ program. We only ever collect the information contained within your purchase receipts and do not have access to any other communication data.
• From other Shopkick Group companies or Affiliates for marketing, business development and communication purposes.
• From information we collect through our attendance at trade shows or conferences for marketing to current and potential business partners.
• From other third-party data companies or platforms for marketing to current and potential business partners and Shopkick consumers and users, for analytics purposes and to understand your preferences and behaviors to tailor and improve our services to better meet the needs of consumers.
• From information we collect via online platforms and websites that are in the public domain.
• From third parties and vendors that manage or provide Shopkick services on our behalf such as IT software providers, data analytics services, customer management and marketing service providers, e-mail distribution and notification providers and IT and cyber security services.

2. What personal information (including sensitive personal information*) do we process about you and why?
   
   For California residents this includes information that we have collected about you in the preceding 12 months.

To deliver our services to you

We collect and process the following types of personal
information to provide you the consumer, with access to the Shopkick App, to deliver to you the ‘kicks’ and rewards you have earned and to provide related Shopkick services you have signed up to.

• Basic contact and demographic information such as your name, email, phone number, address and gender.
• Date of birth. We collect your date of birth to ensure that we do not present consumers with any content that is age inappropriate and ensure compliance with our Terms of Service.
• Your Shopkick user ID.
• Your ‘kick balance’.
• Your precise geolocation data*.
• Rewards history such as ‘kicks’ earnt or redeemed and linked to product purchases and stores visited.
• Savings you have made by using the Shopkick App and services.
• Copies of receipts* you scan into the Shopkick App. We only use this information for the specific purpose of verifying your purchase and providing you with rewards or
  kicks for purchases made and only if you have specifically activated this service on your Shopkick App through the ‘eReceipts’ functionality.
• Details about any loyalty or rewards cards or retail accounts you have linked to your Shopkick user account.
• Your purchase history made at participating merchants – including products purchased, date and time of purchase, retailer purchased from, brand information and the transaction amount.
• Details of products or content you have viewed, scanned or otherwise engaged with via the Shopkick App or our related services.
• Details of any products you have returned to our brand or retail partners and where this impacts upon your rewards or ‘kicks’ balance.
• Mobile Device Information including device identifier, user settings, the make model and operating system of your device.
• Encrypted credit or payment card details or a random ID linked to your card where you have chosen to link a payment card within the Shopkick App (we do not have the ability to access your full card details at Shopkick). We collect the last 4 digits of your payment card so you can choose and identify which card to use for payment when you have linked multiple cards on the Shopkick App.
• The Social Security Numbers* of certain Shopkick users where we have a legal requirement to collect this. For example, for individuals that have earned over $600 in kicks in a single year for certain types of Shopkick rewards. We will contact you directly if you need to provide this information to us.
• The contents of any communications you send via our various communication channels to Shopkick or to any of our partners in relation to our Shopkick services.

To provide you with additional rewards, offers and benefits

We collect and process the following types of personal information to tell you the consumer about or provide you with general or personalized product and brand information and recommendations, advertising and rewards, additional ‘kicks’, offers and other benefits, to enter you into
competitions and prize draws, including when you complete surveys, quizzes or similar engagement activities with us and to seek your feedback about our services.

• Basic contact and demographic information such as your name, email, phone number, address, gender and date of birth.
• Your gender.
• Your ‘kick balance’.
• Mobile Device Information including device identifier, user settings, the make model and operating system of your device and analytics information about how you browse and use our Shopkick platforms and Services.
• Your browsing activity in the Shopkick App e.g. clicks, swipes, views etc.
• Your precise geolocation data.*
• Rewards history such as ‘kicks’ earned or redeemed and linked to product purchases and stores visited.
• Savings you have made by using the Shopkick App and services.
• Details about any loyalty or rewards cards you have linked to your account.
• Your purchase history – including products purchased, date of purchase, retailer purchased from, brand information and the transaction amount.
• Details of how you use the Shopkick App and services such as sign-ups, pages visited etc.
• Details about how you engage with our marketing messaging and communications, emails you clicked on, notifications you opened etc.
• Details of brands and companies, products or content you have viewed, scanned or otherwise engaged with via the Shopkick App or our related services.
• Your views or feedback about certain brands or products.
• Information about your purchasing habits and preferences.
• The contents of any communications you send via our various communication channels to Shopkick or to any of our partners in relation to our Shopkick services.
• Any additional information you choose to provide to us or that you share on the Shopkick App or services when taking part in any surveys or competitions run by Shopkick or in partnership with our brand or retail partners.
• Any views, feedback, opinions, posts or messages that you share with us directly, on Shopkick’s App or services or more widely on other social media or public facing platforms.

To enter into agreements with our brand and retail partners

We collect and process the following types of personal information to meet the agreements we enter into with our corporate brand and retail partners and to undertake linked processes such as billing and customer services.

• Name and business contact details such as business email or phone number.
• Job title and company you work for.
• Billing information such as bank name, address. acct number and credit/trade references in certain circumstances.
• Your location.

To keep our business, brand and retail partners and potential partners informed about our products and services

We collect the following types of personal information about our business, brand and retail partners to keep you informed about Shopkick and our related products and services.

• Name and business contact details such as business email or phone number.
• Job title and company you work for.
• Your location.

To manage and improve the Shopkick App and website and better understand individual browsing preferences and behavior

We collect the following information from your device in order to manage and improve the Shopkick App and website, enable certain features on the Shopkick App and to better understand your browsing or on-line behavior and to provide you with personalized rewards, offers and advertising.

• Mobile device information including device identifiers, user settings, the make model and operating system of your device.
• Information collected when you visit the Shopkick website such as your IP address and other information regarding your device such as information about your operating system, browser version, language settings.
• Information about your use of our services while using your device, such as your use of any features, functions or clicks on notifications or content.
• Search terms you may have used, or which referring/exit pages brought you to our website.
• Information collection via our Shopkick App and website from cookies and similar technologies including pixel tags, web beacons, SDKs, browser analysis tools, and web server logs. For more information about how we use cookies and similar technologies, see ‘ Cookies and Similar Technologies’ below.

To support our wider business operations

We may use the product and shelf images and photographs that you scan and collect via the Shopkick App to inform and develop the business operations and services of other Trax Group companies, including our Signal Based Merchandising offer. This may include the collection of your device ID and related device information but we do not share this information with any third parties outside of Shopkick.

Other additional purposes

We may also use the personal information listed above for the following purposes where we have a legal requirement or a legitimate business interest to do so:

• Merger, Sale, or Other Asset Transfers. We may process your information to effect a corporate transaction involving Shopkick, including a merger, acquisition, or otherwise, and to support the sale or transfer of our business assets.

• As Required by Law, to Enforce Laws and Similar Disclosures. We may process your information, including information that identifies you, to defend ourselves in litigation or a regulatory action; 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; to enforce our rights or protect our property; to protect the rights, property or safety of others, investigate fraud, or respond to a government request; or as needed to support auditing and legal compliance functions.

• To create aggregated and de-identified statistical data. We may use your information tocreate anonymized, aggregated statistical or de-identified data (that is no longer identifiable personal information), to develop and improve and promote our services and products within the Trax Group of companies and to create statistical insights to share with our retail and brand partners to deliver our agreements with them.

3. Who do we disclose your Personal Information to?

We take care to only disclose or allow access to your personal information to individuals or third parties who really need it to perform their tasks and duties, and who= have a legitimate purpose for accessing it.

We may disclose your personal information to the following:

• Other Shopkick or Trax Group companies – in order to develop and provide the Shopkick App and related services to you and to promote our products and services.
• Service providers and vendors who provide services on our behalf – such as IT software and cloud providers, payment and transactions providers, data analytics services, marketing companies, survey platforms and IT and cyber security services.
• Our brand and retail partners – Shopkick only discloses de-identified or aggregated data about Shopkick consumers and their use of the Services to our brand and retail partners. When you interact with a brand or retailer through the Shopkick App, for example to purchase one of their products or services, you will be re-directed to that brand or retailer’s own site
  or platform. Please note that Shopkick is not responsible for any personal information you provide to or via another brand or retailer’s site or platform and you should read their individual privacy policies to find out how they use, store or other process your personal information.
• Transaction and payment card providers/payment networks – by registering your payment card, you authorize your payment card network (e.g. Mastercard/Visa/Amex) to monitor activity on your payment card and to provide information to Shopkick regarding your purchase and return transactions to enable us to award you with ‘kicks’ based on these purchases. If you unlink your card account number(s) from your ‘kicks for purchases’ profile, Shopkick will no longer request your transaction data and your transaction provider will no longer share or collect such information in relation to your use of the Shopkick services.
• Our location services partner, Foursquare – this enables the use of certain location services on the Shopkick App such as serving you with real time notifications about additional ‘kick’ earning opportunities based on your current location. FourSquare may also use your personal information for their own purposes such as for advertising and analytics purposes and
  may share your personal information with their own partners and other third parties. You can access FourSquare’s privacy policy here.
• Advertising networks and platforms – in order to keep you informed about products, brands and services that may be of interest to you and to serve you advertisements (including targeted advertising) via the Shopkick App and to gain insights about your
  preferences, activities and behavior based on your use of the Shopkick App and our services.
• Data agencies and data brokers – to gain insights about your preferences, activities and behavior based on your use of the Shopkick App and services to help tailor our services and marketing efforts and to enable these third parties to use your personal
  information for their own, legitimate business purposes, including selling and disclosing your personal information to other third parties.
• Analytics providers – we use Analytics providers such as Google Analytics and AppsFlyer to help us analyze and understand how you use and interact with our Services to improve and develop them.
• Social media platforms– at various places on our
  Shopkick App and website we have implemented social network/ social media features. These features include:

• Links to Shopkick Brands’ websites on social networks.
• ‘Like’ or ‘Share’ buttons on our websites or emails; and
• Embedded content such as videos.

The providers of the features above may use embedded content to identify you, the source of the visit, and how you use our services. We have integrated social media tools from social media providers such as: Facebook, Twitter, YouTube, LinkedIn, and Instagram.

• Location services and maps – please note that when using location services and maps
  on the Shopkick App that the following third parties may have access to your personal
  information:

• Google Inc. and its Affiliates. You can find Google’s privacy policy here and information about how to manage your Android device’s location settings here.
  
• Apple Inc. and its Affiliates. You can find Apple’s privacy policy here and information about how to manage your iOS device’s location and privacy settings here.

• With other third parties such as our legal advisors or law enforcement or federal agencies – but only in specific cases and where we have a legal requirement to do so and for the following types of purposes:

• In connection with the establishment, exercise, or defense of legal claims.
• To comply with laws and regulations or to respond to lawful requests made to us.
• To protect our rights and property and the rights and property of our agents, consumers, and other, including to enforce our agreements, policies and terms of use.
• To detect, suppress, or prevent fraud.
• To reduce credit risk and collect debts owned to us.
• As otherwise required by applicable law.

• Otherwise with your consent or at your discretion – we may disclose your personal data to certain other third parties or publicly with your consent or direction. If you post a comment or review on our website, Apple App Store, or Google Play Store or a comment on our social media sites, the information you provide may be displayed publicly online for others to view.

4. How do we use cookies and similar technologies?

Like many mobile apps and websites, we use “cookies,” and similar technologies, such as pixel tags, embedded links, web beacons, browser analysis tools, SDKs and web server logs to obtain certain types of information when you access our sites and services. Some cookies are temporary and
will disappear when you close your browser, others are persistent and will stay on your computer or device for some time. We also use marketing and targeting cookies that are used to track visitors across websites. We use them with the intention to display ads that are relevant and engaging to the individual user.

How can I change my cookie settings?

You can change your cookie preferences through the Privacy Preference Center on our Shopkick website at any time by clicking on the cookie icon in the left-hand corner of your web browser.

You can change your cookie preferences through the Privacy Preference Center on our Shopkick App by clicking on ‘Manage Your Privacy Choices; in your App’s Settings Menu.

Most browsers also allow you to refuse cookies. You may block our cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. You can find out more
about cookies and how to delete and control them on <span ‘>https://allaboutcookies.org/ or click help in your browser menu.

Note, if you block our use of cookies and similar technologies, you may be unable to access certain areas of our website and certain functions and pages will not work in the usual way. If you disable the use of Functional and Analytical/Performance Mobile App Cookies some of the Shopkick App
functionality may be affected. For example, you may not be able to undertake certain activities or
see or access certain content in order to earn ‘kicks’ and rewards.

We use the following types of cookies on our website and in the Shopkick App:

Strictly necessary cookies and mobile app cookies
These cookies are necessary for the website or Shopkick App to function and cannot be
switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms and enabling you to use the app for earning basic Shopkick ‘ kicks’ or rewards. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work.

Analytical/Performance cookies and mobile app cookies
These cookies allow us to recognize and count the number of visitors and to see how visitors move around our website and Shopkick App when they are using it. This helps us to improve the way our website and app work, for example, by ensuring that users are finding what they are looking for easily.

Functional cookies
These cookies enable us to provide enhanced functionality and personalisation on our
website and Shopkick App. They are used to recognise you when you return to our website. This enables us to personalise our content for you and remember your preferences and enable you to view and access additional content.
If you do not allow these cookies then some or all of these services may not function properly.

Targeting cookies
These cookies record your visit to our website and Shopkick App, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. These cookies allow you to share and like and send information to other websites to customize their advertisements. These cookies may be set by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other apps. If you do not allow these cookies, you will experience less targeted advertising.

Social media cookies
These cookies are set by social media services that we have added to the site and Shopkick App to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites and platforms you visit. If you do not allow these cookies you may not be able to use or see these sharing tools.

5. Your rights and choices

Managing your account and contact with us.

Profile Access. You can directly access and update your profile information, such as your username, address, or billing information, and can change some of your preferences on your account page within the Shopkick App.

Location and Device Permissions. You can control location tracking by adjusting your location services options on the “Settings” app on your mobile device. We may continue to approximate your location based on your IP address when you access the services through a computer or device. If you would like to update your device content access permissions, such as permissions to access your camera, you can do so in the “Settings” menu on your mobile device. Please note that if you choose to disable location tracking this will mean that we are unable to offer you certain key features and benefits of the Shopkick program such as awarding ‘Kicks for walk-ins’ or when you are near certain stores.

Promotional and Marketing Messages. You can stop receiving promotional email communications from us by following the “unsubscribe” instructions provided in such communications or by contacting us through the details provided here.  We make every effort to promptly process all unsubscribe requests. You may still receive service-related communications, including account verification, transactional communications, changes/updates to features of the services, and technical and security notices.

Your data privacy rights.

Depending upon your state of residency and certain legal limitations and exceptions, you may be able to access some or all of the following rights.

In order to make a request to exercise any of your data privacy rights, please contact us at help@shopkick.com or through the contact details provided here. Please include the words ‘Privacy request’ in the title bar of any emails you send to us.

We will acknowledge receipt of your data privacy right request within 5 working days and provide a full response to you within the legally required timescales.

An authorized agent may submit a data privacy rights request on your behalf. An authorized agent must have your signed permission to submit a request on your behalf or provide proof that they have power of attorney in accordance with applicable state laws. Authorized agents may submit requests by emailing help@shopkick.com or through the contact details provided here. We may contact you directly to verify the authorized agent’s status before completing such a request.

The right to access – You may request access to copies of the personal information that Shopkick has collected about you. Specifically, you may ask Shopkick to tell you: (a) the categories of personal information Shopkick has collected about you; (b) the categories of sources from which the personal information was collected; (c) the business or commercial purposes for which Shopkick has collected, sold, or shared your personal information; (d) the categories of third parties to whom Shopkick has disclosed your personal information; and the specific pieces of your personal information Shopkick has collected. You may request for a copy of your personal information in a portable and to, the extent technically feasible, in a readily useable format that allows you to transmit it to another third party.

The right to deletion – You may request that Shopkick delete all the personal information it has collected from you in the past, subject to certain exceptions. If you request deletion, please know that your user experience within the Shopkick App will look different and any personalization will be lost. Shopkick will not be able to send you targeted offers for items that may be of interest to you and you may not receive personalized recommendations or emails.

If you request deletion, Shopkick will retain your account login information so that you may continue to use your account after exercising your right to delete. If you continue to use your account after submitting a request to delete, Shopkick will again begin collecting purchase history and other information and using it in accordance with this Privacy Policy.

If you ask us to delete your Shopkick account, please be aware that we may continue to process some of your personal information where we have a legal or legitimate business requirement to do so as outlined in this Privacy Policy.

The right to correct inaccurate information – You may update or correct your personal information at any time by visiting your profile’s account setting page. If you are unable to update or correct any inaccurate information through your
account settings, you can also ask us to correct inaccurate personal information about you on your behalf.

The right to non-discrimination – If you exercise any of the rights listed above, Shopkick will not discriminate against you for doing so. Because you make or have made a data privacy rights request, Shopkick will not: (a) deny you the ability to use our services; (b) charge you a different price or rate for the services, including through the use of discounts or other benefits or imposing penalties; (c) provide you with a different level or quality of service, unless your exercise of rights degrades Shopkick’s ability to deliver the same level or quality of our services as outlined here; or (d) suggest to you that you will receive a different price or rate for our services or a different level or quality of our services, except where your exercise of rights degrades Shopkick’s ability to deliver the same level or quality of service as outlined here. For instance, Shopkick uses personal information to provide its users with unique or differentiated offers or bonuses. If you request deletion of your personal information, that will degrade Shopkick’s ability to provide you with such unique or differentiated offers or bonuses.

The right to opt out of selling or sharing your personal information

Consumers in certain states have a general right to direct a business not to “share” or “sell” or use their personal information for targeted advertising. You can find out more about how to exercise these rights and whether they apply to you in Sections 9-11 below.

The right to limit or restrict the use of your sensitive personal information

Consumers in California have a general right to direct a business that collects their sensitive personal information to limit its use and disclosure to that which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those
goods or services.

Please see here for more details about how to exercise that right.

How Do We Verify Your Identity to Complete your Data Subject Rights Request?

If you request access to, or the correction or deletion of, your personal information we will verify your identity before disclosing the requested information. To do so, we may ask that you log into
your account or provide us with your:

• First name, middle initial, last name
• Address or state of residence
• Email address
• Mobile phone number
• Shopkick User ID and other identifying information relating to your use of the Shopkick App

California’ s “Shine the Light” law (CA Civil Code Section § 1798.83) permits users of our website who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

6. How long do we keep your personal information for?

We strive to retain your personal information only for as long as is reasonably necessary to fulfil the purpose for which it was collected. However, if necessary, we may retain your personal information for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and/or accounting requirements set by a legislature, regulator, or other government authority.

To determine the appropriate amount of time that we retain your personal information for, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.

If you delete your Shopkick account with us, or your account remains inactive for a period of five years, we will no longer retain your personal information unless we need to in order to comply with a legal obligation, to resolve disputes and defend claims or for other legitimate business purposes, as well as for any purpose based on the choices you have made, such as to receive marketing communications.

Once retention of your personal information is no longer necessary for the purposes outlined above, we will either delete or de-identify the personal information or, if this is not possible (for example, because personal information has been stored in backup archives), we will securely store your personal information and isolate it from further processing until deletion or de-identification is possible.

7. Children’s Personal Information

The Shopkick App and Website is not directed to children under the age of 14. If you are under the age of 14, please do not use our websites, Shopkick App or online services or otherwise provide us with any personal information. All users under the age of 18 require parental consent prior to creating an account with Shopkick. Please see our Terms of Service for further information.

We always take reasonable steps through the Shopkick App to verify the age of our users to ensure that content delivered is age appropriate.

If you are under the age of 18 and you want to remove your name or comments from our website or publicly displayed content, please contact us directly at help@shopkick.com

We may not be able to modify or delete your information in all circumstances.

If you are a parent or guardian that has become aware that your child or minor has provided us with personal information without your consent, please contact us and we will promptly delete that personal information.

8. For California Consumers – do we use or disclose your sensitive personal information to a third party for any additional purposes than those necessary to provide you with the Shopkick services you have signed up to or for related business purposes?

Precise location data is considered to be ‘sensitive personal information’ under California data privacy law.

Necessary use of precise location to provide the Shopkick services or related business purposes

We generally use your precise location data to provide you with the Shopkick services you have signed up to, for example providing you with ‘kicks for walk-ins’, and ‘kicks for scans’ where we need to know your precise location to verify the rewards or ‘kicks’ that you have earned. We only collect this information when you have agreed to this by signing up to these services and by activating geo-location tracking on your device and within the Shopkick App.

Additional, non-necessary use of precise location data

We may also disclose your precise location data collected via the Shopkick App, together with identifying personal information such as your Device ID or Mobile Ad ID, to a small number of third parties who act as partners to Shopkick in providing you with notifications based on your precise location, serving you with targeted advertising and using your data to better understanding your preferences. These third parties may also use the data shared for their own purposes, including for targeted advertising, attribution and analytics and to create profiles about you and may share it with other third parties for their own legitimate business purposes.

You can limit the use and disclosure of your precise location data to third parties for the abovenon-necessary purposes by taking the following steps:

• Open the Shopkick App and go to the Settings Menu.
• Click on ‘Manage your privacy choices’.
• In the ‘Manage Your Privacy Choices’ Preference Centre, move the ‘Allow the Sale or Sharing and Use of my Sensitive Personal Information’ button to the ‘off’ position (slide left). This will immediately stop your precise geolocation data being used or disclosed for non-necessary business purposes. (This button is set to ‘off’ by default for California residents unless you have already given your consent).

Please note that if you limit the use and disclosure of your precise location data, we will not be able to provide you with certain services such as notifying you about additional ‘kick’ and reward earning opportunities based on your location.

If you require any help or support or have questions about the above, please contact us at help@shopkick.com or through the contact details provided here. Please include the words ‘Privacy request’ in the title bar of any emails you send to us.

9. For California Consumers – do we “sell” or “share” your Personal Information?

For consumers in California we are required to advise you if we ‘sell’ or ‘share’ your personal information and provide you with the option to opt-out of this ‘sale’ and ‘sharing’.

Personal Information collected from the Shopkick Mobile App

To protect your privacy, we ask for your agreement or ‘opt-in consent’ before disclosing your personal information to third parties, including advertising, data agencies and social media networks, to:

• Provide you with personalized offers and recommendations (including targeting advertising).
• Send you notifications about additional ‘kick’ and reward earning opportunities in real-time based on your precise location.
• Gain insights from your behavior, likes and preferences to develop and improve our product, services and marketing and advertising efforts and to enable our approved partners to do the same.

If you would like to opt-in to the activities listed above, including to receive personalized offers, recommendations, targeted adverts and the ability to collect additional ‘kick’ rewards in real-time based on your location you can easily do this through the Shopkick App by taking the steps below:

• Open the Shopkick App and go to the Settings Menu.
• Click on ‘Manage your privacy choices’.
• In the ‘Manage Your Privacy Choices’ Preference Centre, move the ‘Allow the Sale and Sharing and Use of my Sensitive Personal Information’ button to the ‘on’ position (slide right). You can opt-out or remove your consent at anytime by moving the button to the ‘off’ positions (slide left). (This button is set to ‘off’ by default for California residents unless you have already given your consent).

Please note that if you remove your consent/opt-out you may still receive notifications and advertising from Shopkick, however they will not be based on the disclosure of your personal information to third parties.

We also support your use of the Global Privacy Control (GPC). If you notify us of your privacy preferences through GPC, we will honor your request with respect to the browser or device that sends us the GPC signal.

For California consumers between the ages of 14 and 16

Because the Shopkick App is available to consumers aged 14 and over, we are required to collect your opt-in consent for any activities that may be considered a ‘sale’ or ‘sharing’ of your personal information as described above.

If you would like to opt-in to the activities listed above, including to receive personalized offers, recommendations, targeted adverts and the ability to collect additional ‘kick’ rewards in real-time based on your location you can easily do this through the Shopkick App by taking the steps below:

• Open the Shopkick App and go to the Settings Menu.
• Click on ‘Manage your privacy choices’.
• In the ‘Manage Your Privacy Choices’ Preference Centre, move the ‘Allow the Sale and Sharing and Use of my Sensitive Personal Information’ button to the ‘on’ position (slide right). You can opt-out or remove your consent at anytime by moving the button to the ‘off’ positions (slide left). (This button is set to ‘off’ by default for California residents unless you have already given your consent).

Personal Information collected from the Shopkick Website

To protect your privacy, we ask for your agreement or ‘opt-in consent’ before disclosing your personal information to third parties, including advertising and social media networks, to provide you with personalized offers, recommendations, targeted advertising and notifications about additional ‘kick’ earning opportunities and who may also use your personal information to develop insights about how you use our website and Services.

To manage how your Personal Information is ‘sold’ and ‘shared’ via the Shopkick website click on either:

• the ‘Your Privacy Choices’ link at the bottom of the Shopkick landing page and follow the instructions, or;
• the cookie icon on the bottom left-hand corner of the Shopkick landing page and manage your preferences

Categories of Information Sold/Shared and Third Party Recipients

Category of Personal Information Sold or Shared

Category of Third-Party Recipient

Mobile Device Information including device identifiers, user settings, the make model and operating system of your device. Mobile ad identifiers. Name and contact data. Geolocation data. Store visit data including name of store, location and date and time of visit. Your browsing activity in the Shopkick App e.g. clicks, swipes, views etc. Diagnostic information relating to App performance such as crash logs, app launch time, energy use etc. Details of products or content you have viewed, scanned, purchased or otherwise engaged with via the Shopkick App or our related services. Shopping preferences. Demographic information. Timestamps.

Our location services partner, FourSqaure. Analytics providers. Advertising agencies, demand partners, networks and platforms. Social media networks. Third party data agencies.

1. For California Consumers – Notice of Financial Incentive.

The Shopkick program works by providing you with rewards and benefits (‘ kicks’) based, in part, on the processing of your Personal Information.

Under California Data Privacy Law, because your participation in the Shopkick program enables you to earn rewards or ‘kicks’, it may be considered a financial incentive program or a ‘price or service difference.’

Financial incentive program

When you sign-up to or opt-in to the Shopkick program, in order to provide you with rewards or ‘kicks’, you direct us to collect and retain the Personal Information you provide when you register and as outlined in Section 2 of this Privacy Policy.

The value you receive in participating in the Shopkick program is calculated by and depends on the amount and nature of your interaction with us and our participating brand and retail partners to obtain ‘kicks’. Kicks do not have monetary value, but each kick can generally be redeemed for approximately 0.004 cents or 250 kicks are equivalent to $1 when redeemed in rewards, but this may vary from time to time.

Note that participation in the Shopkick program is completely voluntary and you can withdraw your participation at any time. For further details of the Shopkick program and its terms, including how to withdraw or terminate your participation, please refer to our Terms of Service.

Price or service difference

If you decide to opt-out of the ‘ sale’ and ‘sharing’ of your personal information as outlined in Section 9 of this Privacy Policy, we will not be able to provide you with or, your ability to collect certain rewards or ‘kicks’ may be impacted for the following activities:

• Receiving notifications in real time about additional available kicks based on your precise location – to provide this service we are required to disclose your Personal Information to a third party for activities that may be considered as a ‘sale’ and ‘sharing’ of your Personal Information.
• Receiving ‘kicks’ for viewing certain videos and adverts that are targeted towards you – to provide this service we are required to disclose your Personal Information to certain third parties for activities that may be considered as a ‘sale’ and ‘sharing’ of your Personal Information.

The categories of your Personal Information impacted by the above activities are: Mobile Device Information including device identifiers and AD ID, user settings, the make model and operating system of your device, your precise location data, store visit data including name of store, location and date and time of visit, your browsing activity in the Shopkick App e.g. clicks, swipes, views etc, your gender and your age.

You can direct us to ‘sell’ and ‘share’ your personal information to provide you with the above additional kick earning opportunities when you opt-in to the ‘sale’ and ‘sharing’ of your Personal Information as outlined in Section 9 of this Privacy Policy. You can opt-out of the sale and sharing of your personal information at any time as outlined in Section 9 of this Privacy Policy.

1. For Colorado Consumers – do we “sell” or disclose your Personal Information for targeted advertising purposes?

Colorado consumers have the right to opt-out of the processing of their personal information for the purposes of a ‘sale’ of that information or for targeted advertising purposes.

Personal Information collected from the Shopkick Mobile App

When you use the Shopkick Mobile App we may disclose your personal information to third parties for the purposes listed below. These activities may be deemed ‘selling’ under Colorado data privacy law.

• Provide you with personalized offers and recommendations (including targeted advertising).
• Tell you about additional ‘kick’ and reward earning opportunities in real-time based on your precise location.
• Gain insights from your behavior, likes and preferences to develop and improve our product, services and marketing and advertising efforts and to enable our approved partners to do the same.

You can Opt-out of the Sale and processing of your personal information for targeted advertising purposes by taking the following steps:

• Open the Shopkick App and go to the Settings Menu.
• Click on ‘Manage Your Privacy Choices’.
• In the ‘Manage Your Privacy Choices’ Preference Centre, move the ‘Allow the Sale of my Personal Data and Targeted Advertising’ button to the ‘off’ position (slide left).

We also support your use of the Global Privacy Control (GPC). If you notify us of your privacy preferences through GPC, we will honor your request with respect to the browser or device that sends us the GPC signal.

Personal Information collected from the Shopkick Website

When you use the Shopkick we may disclose your personal information to third parties, including advertising and social media networks, to provide you with personalized offers, recommendations and targeted advertising. These activities may be deemed ‘selling’ under Colorado data privacy law.

To manage how your Personal Information is ‘sold’ and ‘shared’ via the Shopkick website click on either:

• The ‘Your Privacy Choices’ link at the bottom of the Shopkick landing page and follow the instructions, or;
• The cookie icon on the bottom left-hand corner of the Shopkick landing page and manage your preferences

Category of Personal Information Sold or Shared

Category of Third-Party Recipient

Mobile Device Information including device identifiers, user settings, the make model and operating system of your device. Mobile ad identifiers. Name and contact data. Geolocation data. Store visit data including name of store, location and date and time of visit. Your browsing activity in the Shopkick App e.g. clicks, swipes, views etc. Diagnostic information relating to App performance such as crash logs, app launch time, energy use etc. Details of products or content you have viewed, scanned, purchased or otherwise engaged with via the Shopkick App or our related services. Shopping preferences. Demographic information. Timestamps.

Our location services partner, FourSqaure. Analytics providers. Advertising agencies, networks and platforms. Social media networks. Third party data agencies.

1. Third party websites

Our websites and online services may include links to or redirect you to third-party websites, and applications, including social media services where you may connect with us.

Third-party websites may also reference or link to our websites and online services.

Except where we post, link to, expressly adopt or refer to this Privacy Policy or have a specific responsibility under applicable data privacy law, this Privacy Policy does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of these third parties, please visit their respective privacy notices or policies.

1. Changes and updates to this Privacy Policy.

We will keep this Privacy Policy under regular review and send you an alert via the Shopkick App if we make any material changes or updates. All changes shall be effective from the date of publication unless otherwise provided in the notification.

1. How to contact us

If you would like any further information about how we collect, use or share your personal information then you can contact us using the details below:

By email at: help@shopkick.com – please include the words ‘ Privacy request’ in the title bar of any emails you send to us.

By writing to us at:

One Beacon St.,
15th Floor,
Boston, MA, 02108, United States.