Engage3, Inc. (hereinafter referred
to as "Engage3,"
"we" or
"us")
strongly believes in maintaining the privacy of information we collect about
individuals. We want you to understand how and why we use and disclose the
information we collect from you. This Policy describes our practices and
procedures for protecting the privacy and security of nonpublic personal
information that we have collected about you.
By accessing or using Engage3 websites, Engage3
mobile applications, or other Engage3 products or services (collectively, the
"Site"), you are accepting the terms of this Privacy Policy and the
practices described herein and you consent to the collection and processing of
your information in accordance with this Privacy Policy.
INFORMATION WE COLLECT
Information That We Obtain From You. We receive and
store any information you enter or submit on or through the Site.
This
includes information that can identify or contact you ("personal information"),
including your first and last name; your email address; your current location,
including zip code, city and state; and any other non-public information about
you that is associated with or linked to any of the foregoing information.
We may also
receive and store other information from you, including your recommendations,
evaluations, survey responses, feedback, and forum submissions; information
that you submit through our mobile application, including in-store pricing and
photos of products; store-related information that you provide to us or to
which you grant us access, including grocery membership information, loyalty
card numbers, grocery store logons, and purchasing history; and information
about your purchasing preferences, including which products you search for and
purchase on a regular basis, products that you have denoted as among your
favorites, your store preferences and your attribute settings (including
allergens, diet preferences, etc.).
You can
choose not to provide information to us, but in general some information about
you is required in order for you to sign up as a user of the Engage3 service,
complete a shopper profile, ask us a question, or fully utilize our services or
products. You may opt out of having personal information used for secondary
purposes by selecting the appropriate opt-out box online or the
"unsubscribe" link on our emails to you.
Please
note, we do not control communications between you and other third parties.
Please refer to such third parties in order to determine their opt-out
procedures.
Information That We Obtain From Other
Sources. We also may periodically obtain both personal and
non-personal information about you from affiliated entities, business partners
and other independent third-party sources.
Automatically-Collected Information. We automatically collect some
information about your computer or other device when you access or use the
Site, including your IP address, Web browser software (such as Firefox, Safari,
or Internet Explorer), and access times. We also may collect information about
your shopping and web browsing activity, including products viewed and
referring website addresses.
We may,
directly or through our contractors, store information on your computer or
other device in the form of a "cookie" or similar file for purposes
of enhancing your experience on the Site, such as by personalizing the Site,
tailoring web content to your interests, recording session information,
securely storing sign in information, and tracking click stream data. If you
choose not to accept our cookies, you may have to re-enter information when you
revisit the Site and certain features and services of the Site may not work
properly.
Our goals
in collecting this automatic information include improving our products and
services, customizing your user experience, and inhibiting fraud.
The Site
may provide links to and information relating to many other websites,
applications, and internet properties (collectively, "Other Internet Properties"),
including Other Internet Properties with whom we may have a marketing
relationship. We do not exercise control over those Other Internet Properties,
and each has its own privacy policy distinct from this one. These Other
Internet Properties may also place their own cookies or other files on your
computer or other device, collect data or solicit personal information from
you.
HOW WE USE YOUR INFORMATION
We use
personal information about you for the following general purposes: (i) to provide you with information and links to the
products and services you request and to provide you with recommendations; (ii)
to assign in-store Missions for data collection; (iii) to manage your account;
(iv) to communicate with you via email and social media, including for
marketing purposes; (v) to respond to your questions and comments; (vi) to
measure interest in and improve our internal operations, services, products,
software and the Site; (vii) to notify you about special offers and products or
services that may be of interest to you, as well as updates to our software and
the Site; (viii) to otherwise customize your experience with the Site; (ix) to
solicit information from you, including through surveys; (x) to resolve
disputes or troubleshoot problems with the operation of the Site; (xi) to
prevent potentially prohibited or illegal activities; (xii) to enforce our
Terms of Use; and (xiii) as otherwise described to you under the Information We
Collect section.
Lawful
Basis for Processing Your Personal Information.
If European data protection law applies and where Engage3 acts as a data
controller, our lawful basis for collecting and using the personal information
described in this Notice will depend on the type of personal information
concerned and the specific context in which we collect or use it.
We
normally collect or use personal information only where we have your consent to
do so, where we need the personal information to perform a contract with you,
or where the processing is in our legitimate interests and not overridden by
your data protection interests or fundamental rights and freedoms. In some
cases, we may have a legal obligation to collect or retain personal information
or may need the personal information to protect your vital interests or those
of another person. For example, when we:
If
you have questions about or need further information concerning the lawful
basis on which we collect and use your personal information, please contact us
at Privacy@engage3.com. Note that in situations where Engage3 acts as a
processor, it is our customer who determines the appropriate legal basis
associated with processing activities, and queries about the applicable lawful
basis should be directed to them.
RETENTION OF PERSONAL INFORMATION
We keep your personal information for
no longer than necessary for the purposes for which it is processed. The length
of time for which we retain personal information depends on the purposes for
which we collected and use it and/or as required to comply with applicable laws
as set out in our data retention policy and information handling standards.
Generally, this means we retain your personal information to comply with any
retention or statutory limitations or for purposes of performing a contract
with you. Where there are technical limitations that prevent deletion or
anonymization, we safeguard personal information and limit active use of it.
INFORMATION WE DISCLOSE
We do not disclose any personal information to
anyone except in accordance with this Privacy Policy or otherwise with your
consent.
We may share
your information: (i) in response to subpoenas, court
orders, or other legal process; (ii) to establish or exercise our legal rights;
(iii) to defend against legal claims; (iv) when we believe it is appropriate to
investigate, prevent, or take action regarding illegal or suspected illegal
activities; (v) to protect and defend the rights, property, or safety of our
company or the Site, our customers, or others; (vi) as described in our Terms
of Use; or (vii) in connection with a corporate transaction, such as a
divestiture, merger, consolidation, or asset sale, or in the unlikely event of
bankruptcy.
We may
share some or all of your personal information or other information with a
parent company, subsidiaries, joint ventures, or other affiliates, in which
case we will require them to agree to honor this Privacy Policy.
We may
share your personal information with third party vendors who provide services
or functions on our behalf, including business analytics, customer service, and
fraud prevention. We may also authorize third party vendors to collect
information on our behalf, including as necessary to operate features of the
Site or to facilitate the delivery of online advertising tailored to your
interests. Our third party vendors have access to and
may collect information only as needed to perform their functions and are not
permitted to share or use the information for any other purpose. They are also
required to follow substantially comparable security practices that we
ourselves adhere to.
We also may
share your loyalty card numbers and information related to coupons and offers
you receive with third parties for purposes of providing you with such coupons
and offers.
We also may
share aggregate or anonymous information in our discretion with third parties,
including advertisers, investors, manufacturers, retailers, and other business
partners. For example, we may tell our advertisers the number of visitors the
Site receives or the most popular products. This information does not contain
any personal information and is used to develop content, products, and services
we hope you will find of interest.
By using
the Site, you will be linked to third parties who may request additional
personal information in order to complete a purchase or use their services or
products. Such third party suppliers are not our
vendors and do not operate under the terms of this Privacy Policy. We do not
control, monitor or endorse the privacy practices of any such third party suppliers, nor are we aware of how such third party
suppliers use your personal information. Accordingly, we encourage you to
review the privacy policies of any third party
suppliers whose services or products you purchase through the Site in order to
understand their procedures for collecting, using, and disclosing personal
information. Please note that these suppliers also may contact you as necessary
to obtain additional information about you, facilitate your purchase, or use
their services or products.
THE RIGHT TO VERIFY THE
ACCURACY OF INFORMATION WE COLLECT
Keeping information accurate and up to date is
important to us. Individuals may see and correct their personal information
that we collect except for information relating to a claim or a criminal or
civil proceeding. You can access and update your contact information and
preferences by accessing the Site’s user profile page. For deletions, please
contact us at Privacy@engage3.com
You can
close your account by emailing us at the following address:
accounts@shoppingscout.com. Please note that after you close an account, you
will not be able to sign in or access any of your personal information.
However, you can open a new account at any time. Please also note that we may
retain certain information, including personal information, associated with your
account, including for analytical purposes as well as for recordkeeping
integrity. To the extent any such information is retained, it will be subject
to this Privacy Policy.
CONFIDENTIALITY AND SECURITY
We restrict access to personal information on our
servers to our authorized personnel and contractors. We maintain appropriate
physical, electronic, and procedural safeguards to protect the personal
information we collect. Despite these measures, however, Engage3 cannot
guarantee the security of personal information, including information that is
transmitted wirelessly or over public networks.
Upon
creating an account, you will be assigned a sign in ID and a password that will
allow you to access your personal information. For security purposes, we impose
guidelines, such as a minimum password length, for passwords created by you,
and we may require you to update and change your password after a certain
period of time. It is important for you to protect against unauthorized access
to your password and to your computer or other device. Be sure to sign off and
clear caches when finished using a shared computer or other device. Engage3 is
not responsible for any unauthorized access to your account by an individual
who has obtained your sign in ID and/or password through no fault of Engage3.
Please note
that any information you post or submit to a public bulletin board, blog or
chat room is available to all persons accessing that location, and your e-mail
address may also be posted on these venues. The information you share,
including your email address, would then be available to all persons accessing
these venues, and such information may be read, collected
or used by others for any purpose, including sending you unsolicited messages. Engage3
is not responsible for any information you elect to submit in these venues or
the use of such information.
INTERNATIONAL DATA
TRANSFERS
Engage3 is headquartered in the United
States of America. Your information, including Personal Data, may be
transferred to and maintained on computers located
outside of your state, province, country or other governmental jurisdiction
where the data protection laws may differ than those from your jurisdiction. If
you are located outside United States and choose to provide information to us,
please note that we transfer the data, including Personal Data, to United
States and process it there. Your consent to this Privacy Policy followed by
your submission of such information represents your agreement to that transfer.
Engage3 will take all steps reasonably necessary to ensure that your data is
treated securely and in accordance with this Privacy Policy and no transfer of
your Personal Data will take place to an organization or a country unless there
are adequate controls in place including the security of your data and other
personal information.
Engage3
complies with certain legal frameworks relating to the transfer of data from
the European Economic Area, the United Kingdom, and Switzerland (collectively,
“EU”) to the United States. When Engage3 engages in such transfers, Engage3
relies on Standard Contractual Clauses as the legal mechanism to help ensure
your rights and protections travel with your personal information. SCCs are contractual commitments between
companies transferring personal data, binding them to protect the privacy and
security of such data. Engage3 adopted SCCs so that the necessary data flows
can be protected when transferred outside the EU to countries which have not
been deemed by the European Commission to adequately protect personal data,
including protecting data transfers to the United States.
CHILDREN’S PRIVACY
This is a general audience Site and does not offer
services or products directed to children. Should a child whom we know to be
under 13 send personal information to us, we will use that information only to
respond directly to that child that he or she is prohibited from accessing or
using the Site.
APPLYING FOR A JOB ON
OUR SITE
If you apply for a job through the Engage3
website, we, or a human resources company assisting us, may ask you to provide
self-identifying information (such as gender, marital status, and ethnicity) in
conjunction with laws and regulations enforced by local government and
regulatory agencies. Providing
self-identifying information is voluntary, but if you do provide us with that
information, we may submit it to the local government and regulatory agencies
for business-related purposes, including responding to information requests,
fulfilling regulatory reporting requirements, and defending against employment
related complaints.
RESOLVING COMPLAINTS
If you have concerns about the
way Engage3 is handling your User Personal Information, please let us know
immediately. We want to help. You may contact us directly
at privacy@engage3.com with the subject line "Privacy
Concerns." We will respond promptly — within 45 days at the latest.
DISPUTE RESOLUTION PROCESS
In the
unlikely event that a dispute arises between you and Engage3 regarding our
handling of your User Personal Information, we will do our best to resolve it.
Additionally, if you are a resident of an EU member state or the UK, you have
the right to file a complaint with your local supervisory authority, and you
might have more options.
COMPROMISE OF PERSONAL INFORMATION
In the
event that personal information is compromised as a result of a breach of
security, Engage3 will promptly notify those persons whose personal information
has been compromised, in accordance with the notification procedures set forth
in this Statement, or as otherwise required by applicable law.
CALIFORNIA RESIDENTS
This Privacy Notice for
California Residents (“CA Privacy Notice”) supplements the information
contained in our Privacy Statement and applies solely to all
visitors, users, and others who reside in the State of California
("consumers" or "you").
CONTACTING US
If you have any questions about this Privacy
Policy or would like to learn more about how we protect privacy, please email
us at: Privacy@engage3.com.
CHANGES TO THIS POLICY
We may update this Privacy Policy in the future.
We will notify you about material changes to this Privacy Policy by sending a
notice to the email address you provided to us or by placing a prominent notice
on the Site. The date the Statement was last reviewed is located at the bottom
of the page. You are responsible for ensuring we have an up-to-date, and
deliverable email address for you, and for periodically visiting the Website
and this Statement to check for any changes.
This
Privacy Policy is effective as of December 15, 2021