Saltwater Software, Inc. (together with its affiliates, "Saltwater," "we", “us” or "our") is a software company that hosts loyalty programs on behalf of local organizations and others, among other lines of business.
Personal Information We Collect
Information you provide to us. Personal information about you that we collect from you may include:
- Contact data, such as your first and last name, email address, mailing addresses, and phone number.
- Registration data, such as information that you submit when you complete an online registration form to access and use certain features of our Services, or when you register for contests, sweepstakes or promotions.
- Communications that we exchange when you contact us with questions, feedback, or otherwise.
- Marketing data, such as the email address or contact details that we use to send marketing communications to you, your marketing preferences, and information about your responses to our marketing communications.
Data from other sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:
- Merchants, with whom you have shopped;
- Data providers, such as information services and data licensors.
- Publicly-available sources, such as social media platforms.
- Business partners, such as joint marketing partners and event co-sponsors.
Data collected automatically. We, our service providers and third party partners may automatically log information about you, your computer or mobile device, and your activity over time on the Services and other online services, such as:
- Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, unique identifiers (e.g., Apple's ID for Advertising or Google's Advertising ID), general location information (such as city or state), and precise geolocation (if you permit our Services to access it from your device settings).
- Online activity data, such as the website you visited before browsing to our website, pages or screens you viewed on the Services, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
- Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies. Cookies are small data files placed on your computer when you visit a site. We may set cookies when you use the Services to track user trends and patterns, help you navigate between pages efficiently, remember your preferences and generally improve your browsing experience. Cookies used on the Services may also be set by analytics service providers and advertising partners. In addition to cookies, the Services and our emails may use pixel tags (also known as web beacons and clear GIFs) to compile statistics about use of the Services, measure the success of our marketing campaigns, and indicate whether recipients of our emails open or click links within them.
How We Use Your Personal Information
Service delivery. We use your personal information to:
- provide, operate and improve the Services;
- communicate with you about the Services, including by sending you announcements, updates, security codes, security alerts, and support and administrative messages; and
- provide support for the Services, and respond to your requests, questions and feedback.
Research and development. We may use your personal information to administer surveys and other market research and for other research and development purposes, including to analyze and improve the Services and our business. As part of these activities, we may create anonymous data (including aggregated and/or de-identified data) from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
How we use your transaction data
We collect transaction data from service providers, including the companies that match your credit card transactions to your Saltwater loyalty account, who provide us with transaction-level data regarding your purchases. Some data, including your credit card information, may be directly collected by our service providers on our Services. Our service providers use that information to verify relevant transactions as part of our loyalty program Services. For more information about the privacy policies of our service provider, Fidel LTD, please visit: https://fidel.uk/legal/privacy/
- Use transaction data to confirm a Qualifying Purchase or return to match transactions to confirm whether you qualify for a statement credit or an Offer;
- Share transaction data with the participating merchant where a transaction occurred as needed for the merchant to confirm a specific transaction occurred or points should be awarded; for example, the date and amount of your purchase and the last 4 digits of your card number so the merchant can verify your purchase with its records if there is a missing or disputed transaction;
- Provide participating merchants or Third Party Service Providers aggregated and anonymized information relating specifically to registered card activity solely to allow participating merchants and Third Party Service Providers to assess the results of their campaign;
- Create a record of the transaction data and thereafter maintain and use data in connection with operating the Program;
- Conduct analysis for the improvement and optimization of the Program; and
- Provide information in order to respond to a request from government authority or a payment organization involved in a transaction with you or a merchant.
You authorize the sharing, exchange and use of transaction data described above and herein by and among Company and Company’s Third Party Service Providers, applicable Payment Card Networks and applicable Merchants.
Compliance and operations. We may use your personal information to:
- operate our business;
- comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
- protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
- enforce the terms and conditions that govern the Services; and
- prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
How We Share Your Personal Information
Service providers. Companies and individuals that provide services on our behalf or help us operate the Service or our business, such as customer service and support providers; technology providers (including technology support, web hosting providers, email and text communications providers, and mobile app developers); survey and market research providers; advertising and marketing partners; and analytics services providers.
Advertising partners. Third party advertising companies that collect information about your activity on the Services and other online services to help us advertise our services.
Professional advisors. Professional advisors, such as lawyers, auditors and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, central banks and private parties, as we believe necessary or appropriate for the compliance and operations purposes described above.
Business transferees. Relevant third parties in the event of a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business, assets, or equity interests in Saltwater or our affiliates (including, in connection with a bankruptcy or similar proceedings).
Please keep in mind that whenever you voluntarily make your personal information available for viewing by third parties on our Services, that information can be seen, collected and used by others besides us. We cannot be responsible for any unauthorized third-party use of such information.
Opt out of marketing emails. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email. You may continue to receive Service-related and other non-marketing emails. You may also change your email newsletter preferences via the “Newsletter” section of the site.
Text message alerts. We may offer text news alerts for your phone or wireless device via short message service ("SMS") or similar technology. You must register with us to receive this service, which may require providing us your name, telephone number, and other personal information. You can cancel or modify your alerts by accessing your account through the Services or by texting "STOP" to the number associated with the text news alert. Message and data rates may apply for this service.
Google and many of our other advertising service providers are members of the Network Advertising Initiative (NAI) and are subject to the Self-Regulatory Principles for Online Behavioral Advertising published by the Digital Advertising Alliance (DAA). You can obtain more information about these advertising service providers' information collection practices, and opt out of receiving targeted advertising from some participating NAI and DAA members, at http://www.networkadvertising.org/managing/opt_out.asp and/or the DAA's website at http://optout.aboutads.info. Mobile app users may opt out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available at https://www.youradchoices.com/appchoices, and selecting the user's choices. Please note that we also may work with companies that offer their own opt-out mechanisms and/or may not participate in the opt-out mechanisms described above.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Cookies. Most browsers let you remove and/or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, our Services may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit http://www.allaboutcookies.org.
Declining to provide information. We need to collect personal information to provide certain Services. If you do not provide the information requested, we may not be able to provide those Services.
Other Sites and Services
The Services may contain links to other websites and online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or other online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions.
The security of your personal information is important to us. We employ organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
International Data Transfers
Our Services are intended to be used only by residents of the United States.
We are headquartered in the United States, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective.
How to Contact Us
Please direct any questions or comments to:
201 Wilshire Blvd, 2nd Floor, Santa Monica, CA 90401
Important Information for California Residents
This section applies only to California residents. It describes how we collect, use and share Personal Information of California residents in operating our business, and their rights with respect to that Personal Information. For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA.
Your California privacy rights. As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted or required by law. For example, the CCPA prohibits us from providing certain sensitive Personal Information in response to an access request. If we deny your request, we will communicate our decision to you.
- Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
- The categories of Personal Information that we have collected.
- TThe categories of sources from which we collected Personal Information.
- TThe business or commercial purpose for collecting and/or selling Personal Information.
- TThe categories of third parties with whom we share Personal Information.
- TWhether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.
- TWhether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
- Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
- Deletion. You can ask us to delete the Personal Information that we collected or maintain about you.
- Opt-out of sales. If we sell your Personal Information, you can opt-out. While we refer to the term “sell” as the CCPA requires, please note that CCPA defines “sale” very broadly to include most sharing of personal information where the recipient may use the information for its own purposes, even when we do not get paid for the information. In addition, if you direct us not to sell your Personal Information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.
- Opt-in. If we know that you are younger than 16 years old, we will ask for your permission (or if you are younger than 13 years old, your parent’s or guardian’s permission) to sell your Personal Information before we do so.
- Nondiscrimination. You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you services; increasing the price/rate of services; decreasing service quality; or suggesting that we may penalize you as described above for exercising your rights.
How to exercise your rights
You may exercise your California privacy rights described above as follows:
- Right to information, access and deletion. You can request to exercise your information, access and deletion rights by:
- Right to opt-out of the “sale” of your Personal Information. [We do not sell your Personal Information in the conventional sense (i.e., for money). However, like many companies, we may use services that help deliver interest-based ads to you. California law classifies our use of these services as a “sale” of your Personal Information to the companies that provide the services. This is because we allow them to collect information from our website users (e.g., online identifiers and browsing activity) so they can help serve ads more likely to interest you. If we do sell your Personal Information, you can request to opt-out out of this “sale” of your personal information here: Do Not Sell My Personal Information.
We will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
California residents may also empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority.
Personal information that we collect, use and share
We have not sold your personal information in the preceding 12 months.
|Category of personal information (PI) (click for details)||PI we collect||Source of PI||Business/ commercial purpose for collection||Categories of third parties to which we “disclose” PI for a business purpose||Categories of third parties to whom we “sell” PI|
|Internet or Network Information||
May be derived from your:
• the sources from which we collect this information in the section above entitled Personal Information We Collect; and • the business and commercial purposes for which we collect this information in the section above entitled How We Use Your Personal Information.
Please note that we may also disclose Personal Information to (a) comply with federal, state, or local laws; (b) comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (c) cooperate with law enforcement agencies concerning conduct or activity that we believe may violate federal, state, or local law, (d) when we sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction), or (e) to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us. These disclosures are not “sales” under the CCPA.
|Statutory category||Definition (categories may overlap)|
|Commercial Information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.|
|Geolocation Data||Precise location, e.g., derived from GPS coordinates or telemetry data|
|Identifiers||Real name, alias, postal address, unique personal identifier, customer number, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.|
|Inferences||The derivation of information, data, assumptions, or conclusions from any other category of Personal Information to create a profile about a person reflecting the person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.|
|Internet or Network Information||Browsing history, search history, and information regarding a person’s interaction with an Internet website, application, or advertisement.|
|Online Identifiers||An online identifier or other persistent identifier that can be used to recognize a person, family or device, over time and across different services, including but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, mobile ad identifiers, or similar technology; customer number, unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers (i.e., the identification of a person or a device to a degree of certainty of more probable than not) that can be used to identify a particular person or device.|
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