Privacy Policy

Coin Out Inc.

Last Updated: May 11, 2021

This Privacy Policy (“Policy”) describes how Coin Out Inc. (“Company” or “we” or “our” or “us”), a wholly owned company of Information Resources, Inc., treats information collected or provided in connection with an end user’s (“you” or “your” or “User”) use of the Company’s website at http://www.coinout.com and mobile applications (the “Services”). Please note that your use of the Services constitutes your acceptance of this Policy as set forth herein. Please also read our Terms of Use (the “Terms”), which also apply and are incorporated by reference into this Policy.

1.   WHAT IS THE COINOUT APP?

Coin Out Inc. and its corporate affiliates (“Company” or “we” or “our” or “us”) provide consumer and retail information and insights for a wide range of industries. The CoinOut App (the “App”) is a mobile application that the Company uses to enhance its consumer receipt panel. In exchange for your participation, you can earn points for rewards as well as have your receipt information automatically collected to allow for easy submission and participation.

2.   OUR COMMITMENT TO PRIVACY

The Company protect the Personal Information and identities of our Users. We will not use your Personal Information to advertise, promote, or market goods or services directly to you, and we do not allow our clients or commercial partners to market directly to you.

3.   WHAT IS PERSONAL INFORMATION?

Personal Information means information that directly identifies you or that may reasonably be used to identify you as a specific individual (“Personal Information”).

4.   SUMMARY

This Policy describes how we collect, use, share, and secure the Personal Information we may collect when you use the Services. It also describes your choices regarding use, access, deletion, and correction of your Personal Information.  We will review the notice regularly and publish updates as required by law, statute and/or regulation where your rights will be no less than what is required by law, statute, and/or regulation.

When you use the Services, we collect information related to your purchase and consumer behavior to the extent you choose to share it with us.  We use this information as part of the products and services we make available to our clients and affiliates to help them better understand consumer behavior and the markets in which they do business.

All the information set out in this Policy may not apply to you.  Our interactions with you, and the choices you make with regard to how you use the Services, will determine which portions of the Policy apply to you and your Personal Information.  Wherever we provide examples of information in this Policy, the examples are not intended to be an exhaustive list. When you share Personal Information with us or when we collect Personal Information about you, we will do so in alignment with this Policy.

This Policy does not cover our clients’ or affiliates’ use of your Personal Information outside of the products and services we may provide them. We are not responsible for the privacy practices of our clients. Further, you may elect to participate in surveys, contests, sweepstakes, or other programs that may be offered or sponsored by us or third parties, and any such participation may be subject to separate terms and conditions or policies.

5.   PERSONAL INFORMATION WE MAY COLLECT

Information You Give Us. As part of using the Services, you may submit certain information to us. For example, when registering for an account on the Services we may collect information including Personal Information such as your first and last name, phone number and email address We also collect information from any photographs or other materials you submit through your use of the Services (e.g., the products you purchase, the amount you spent for a transaction, or the metadata within images you submit). Additionally, we may also administer surveys to you and collect your responses for use in an aggregated and deidentified way for market research.

Information You Allow Us to Collect on Your Behalf. Only if you have provided us with your consent to do so, we may obtain read-only access to your email account to collect information from your email related to your digital shopping history. We may automatically collect receipt information from your emails about purchase transactions including details of what was purchased, the merchant from which the goods/services were purchased, the amount spent, and the date of the purchase. Consent for this process is controlled by you. You may withdraw your consent at any time within the App.

Only if you have provided us with your consent to do so, we may obtain read-only access to one or more of your merchant accounts to collect information from your account related to your digital shopping history. We may automatically collect information from your account about purchase transactions including receipts or order histories, details of what was purchased, the merchant from which the goods/services were purchased, the amount spent and the date of the purchase. Consent for this process is controlled by you. You may withdraw your consent at any time within the App.

Automatically Collected Information. When you use the Services, we gather certain information from you, and this information can be associated with your user account. This includes usage information, such as information on when, how often and for how long you use the Services, as well as server log data such as a computer’s IP address, browser type, or the webpage you were visiting before you came to the Service.

Device Information. We may collect Personal Information from you to enable certain features within our app. For example, we request access to your phone's location data to verify your submissions and residence. These features may be disabled on your local device at any time; however, some service offerings and features may become unavailable.

Cookies, Beacons, and Other Technologies. The Services may use both web beacons and cookies to collect information. “Beacons” (also often referred to as “pixels”) are tiny graphics on a web page designed to track when a page is viewed. “Cookies” are small text files containing a string of alphanumeric characters that are downloaded by your web browser or mobile device when you visit a website. We may use both session cookies and persistent cookies when you access and use the Services. Cookies may be used, for example, to remember your user account information and your preferences, to customize the interface of the Services for you and to assist us in measuring and analyzing Service traffic. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Services. Persistent cookies can be removed. Please review your browser’s documentation to learn the best way to modify your cookie settings. Like many websites, the Services do not currently respond to “do not track” browser headers. However, you can take steps to limit tracking by erasing cookies from your computer’s hard drive and by setting your browser to block all cookies or warn you before a cookie is stored.

Analytics. We use certain third party services to assist us in analysis, auditing, research, and reporting regarding the Services. These third parties may use web logs or web beacons, and they may set and access cookies on your computer or other device. We use Google Analytics to help collect and analyze certain information for the purposes discussed in this Policy. You may opt out of the use of cookies by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Information from Third Parties or Other Sources. We work with third party vendors and service providers to gather deidentified or aggregated information about how users interact with our app or software. This may include information such as demographic information, preference information, what you watch or buy, or your exposure to advertising. These sources include, for example: census data, the manufacturers or sellers of the products you purchase or use, organizations that collect online data, data suppliers, companies that combine purchase information, and other entities that have a legal right to provide such information to us.

6.   HOW WE MAY USE YOUR PERSONAL INFORMATION

Provision of Services. We may use collected information for the purposes for which you provided the information including, for example, to create and maintain an account for you for storing your Coin Out credit or to respond to a question that you e-mail to us. We also use the collected information as necessary to provide the features and functionality of the Services to you and as reasonably necessary for our business operations.

Market Research to help clients and commercial partners better understand consumer behavior on a deidentified, aggregate level. You are never identifiable and your Personal Information is not sold to these partners.

Promotional Offers We may use the collected information to provide you with promotional materials and offers. However, we will give you the ability to opt out of receiving such e-mails in accordance with applicable law. We will not provide your Personal Information to third parties for their own marketing purposes without your consent.

Combination We may combine Personal Information collected through the Services with other information that we or third parties collect about you in other contexts, such as our communications with you via email, SMS text or phone, or your customer service records.

Personalized Content We may use the collected information to personalize the content that you and others see based on personal characteristics or preferences.

Analytics and Improvements We may also analyze collected information relating to your use of the Services in order to help us improve the Services and develop and improve other products and services.

Updates and Troubleshooting. We may also use the collected information to contact you regarding updates or modifications to the Services or to help troubleshoot problems, provide you with required notices in connection with disputes between you and another user or alert you to changes in our policies or agreements that may affect your use of the Services.

Legal Purposes. We may use your information to comply with federal, state, or other applicable laws and regulations or to enforce or apply our rights under any agreements with our users and/or to protect the property, rights, or safety of our users, Coin Out, or others to the extent we deem it necessary or appropriate.

7.   DISCLOSURE OF INFORMATION

Service Providers. We may use third-party service providers to assist us in making the Services available. Such service providers may obtain access to the information you provide, including Personal Information. Service providers are required to protect this information in a manner that is consistent with this Policy by, for example, not using the information for any purpose other than to carry out the Services they are performing for us. We may also disclose deidentified, aggregated information to our business partners or clients in furtherance of our business arrangements with them, including, without limitation, to jointly offer a product or service to you or create interoperability between our products and services and the products and services of such partners or clients.

Advertisers. We may provide advertisers and other third parties with aggregated, deidentified information about you and your interests or usage patterns. We may also partner with third party advertising companies in order to serve advertising regarding our products and services to users elsewhere on the web after they visit our website. This is a common practice called “retargeting.” For more information on such practices and the ability to opt-out, you may visit http://www.aboutads.info.

Business Partners or Clients. We may deidentify and aggregate your Personal Information regarding activity on this Service and make such information available to our business partners, clients, or other third parties. For example, this may include sending aggregated reports to clients regarding characteristics or performance of all components in a given category or a report comparing the price and performance of that client’s products to competitive products listed on the Services.

Affiliate, Parent, and Subsidiary Organizations. We may disclose the information we collect from you to our corporate affiliates or subsidiaries; however, if we do so, their use and disclosure of your Personal Information will be subject to this Notice. In the event of a merger, sale of capital stock or assets, reorganization, consolidation, or similar transaction involving Company, the information we possess, including Personal Information, shall be transferred as a corporate asset to the acquiring entity.

Analytics Partners. We may disclose certain web logs or web beacons, or cookies on your computer or other device to third party analytics providers to assist us in analysis, auditing, research, and reporting regarding the Services. We use Google Analytics to help collect and analyze certain information for the purposes discussed in this Policy. You may opt out of the use of cookies by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Legal Purposes. We may disclose information where we, in good faith, believe that the law or legal process (such as a court order, search warrant or subpoena) requires us to do so or in other circumstances where we believe it is necessary to protect the rights or property of Company, our users and/or third parties.

8.   COMMUNICATIONS & TEXT MESSAGES

Email Communications. If you authorize us to contact you through email, we may use the email associated with your account to contact you with information related to our Services, including important information about your account activity. To opt-out of email communications, please click the unsubscribe option within the most recent email sent to you.

Email Opt-Out. You have complete control over your email preferences with us. To opt-out of email communications, please click the unsubscribe option within the most recent email sent to you.

Text Message Communications. If you authorize us to contact you through SMS text messaging, we may use the phone number associated with your account to contact you with information related to our services, including important information about your account activity. By authorizing us to contact you via SMS text messaging, you understand and agree that by electing to opt-in, you are authorizing the Company to send text messages to your mobile phone. Standard text message and data rates apply.

Text Message Opt-Out. You may opt out of text messaging at any time by emailing the Company at support@coinout.com, and you may also text STOP to (914) 315-2097. Your consent is voluntary and is not required to use the Services.

9.   CHILDREN

We do not knowingly collect information from children under 17 and the Services are not directed at children under 17. If you are a parent and believe your child under the age of 17 has used the Services, please contact us and we will work to delete that Service account and any such information.

10. THIRD PARTIES

The Services may contain offers from third parties or links to third-party websites. This Policy does not apply to information that you may provide to or that may be collected by third parties. We encourage you to request such third parties to provide you with their applicable privacy policies and other terms and conditions before engaging with or making a purchase from such third parties.

11. SECURITY

We comply with our legal obligations by keeping Personal Information up to date; by storing it securely; by not collecting or retaining excessive amounts of Personal Information; by protecting Personal Information from loss, misuse, unauthorized access and disclosure and by employing physical, technical, and administrative protections and procedures to help prevent unauthorized access to, disclosure, misuse, or loss of the data collected on the App and through our service, in accordance with generally accepted, appropriate standards in the research industry. We will not modify, alter, delete, publish, or disclose any of your Personal Information to any unauthorized third party, nor allow any unauthorized third party to process such Personal Information on our behalf unless the third party is bound to similar confidentiality and data handling provisions. We will only process your Personal Information to the extent necessary to perform our obligations under the terms of this Notice, upon written instructions from you (only as mutually agreed upon), and in accordance with applicable laws and regulations.

The data is stored on secure servers and only specific, authorized personnel have access to non-aggregated data. Such personnel work on password-protected computers and are subject to confidentiality and security policies and procedures. The security technology is updated and tested on an on-going basis. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of member information.

Please be aware that despite our efforts, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

12. TRANSFER TO THE U.S. OR OTHER COUNTRIES

We use facilities in the United States. Your information will be stored and processed in the United States or other countries where Company has facilities. By using the Services, you consent to the transfer of information outside of your country, even if your country has more rigorous data protection standards. The Services are intended for users located within the United States. We make no representation that the Services are appropriate or available for use outside of the United States. Access to the Services from countries or territories or by individuals where such access is illegal is prohibited. If you are visiting our website from the European Union or other regions with laws governing data collection and use, then please note that you are agreeing to the transfer of your information to the United States and processing globally. By providing your information to the website, you consent to any transfer and processing in accordance with this Policy.

13. VIEWING, AMENDING AND DELETING INFORMATION

You can log into your account and view, amend, or delete your account information at any time. Please note that while changes to your profile information are reflected promptly in active user databases, our servers may retain previously provided information. You may also email us at privacy@coinout.com. If you are a California resident, please see Section 16 below for more information about your rights.

14. CHANGES TO THIS POLICY

We may make modifications, deletions, or additions to this Policy (“Changes”) at any time. Changes will be effective immediately after the Company publishes, or, where legally required, provides notice of the Changes (whether such notice is provided through the Service user interface, by posting the updated version on the Company’s website, is sent to the email address associated with your account or otherwise, or when you opt-in or otherwise expressly agree to the Changes or a version of this Policy incorporating the Changes, whichever comes first). Your continued use of the Service after such Changes means that you accept all such Changes. You should consult this Policy each time you use the Service. This Policy was last modified on the date indicated at the top of this Policy.

15. CONTACT US

If you have any questions about this Policy, please contact us using any method below.

Email: privacy@coinout.com

Phone: (646) 481-7435

Mail: Coin Out Inc., Attn: Privacy Questions, 203 North LaSalle Street, Suite 1500, Chicago, IL 60661

16. YOUR CALIFORNIA PRIVACY RIGHTS

Summary

Beginning January 1, 2020, the California Consumer Privacy Act (“CCPA”) provides California consumers the right to request that a business disclose what Personal Information it collects, uses, discloses, and sells. You may, for no fee, make the following verifiable requests to a business collecting their Personal Information:

·       request to know categories of Personal Information collected and disclosed;

Description of Consumer Rights

Upon verifying a consumer’s identity in response to a request to know, the business must disclose to the consumer, in a portable and readily usable form, the categories of Personal Information that the business has collected about the consumer, the categories of sources from which the information is collected, the business or commercial purposes for collecting the information (as applicable), the categories of third parties with whom the information is shared, or the specific pieces of information collected about that consumer. Upon verifying a Consumer’s identity in response to a request to delete, the Company must delete any Personal Information about you which we have collected. If we do not produce the information or delete your Personal Information as requested, we must provide an explanation in terms of the exemptions and exceptions provided in CCPA.

Categories of Personal Information We May Collect and How We May Use It

The Personal Information about California consumers that we may collect and use in the preceding 12 months for a business purpose are as follows:

Sources of Personal Information We Collect and Use

Categories of Personal Information We Collect and Use

Business Purpose for Collecting and Using Personal Information

Legal Basis for Collecting and Using Personal Information

Personal Information we collect when you use our App

When you use our App, we may ask you to provide first and last name, zip code, email address, date of birth, information about your activities and interests, your current location (geolocation), hashed credit card information, purchase history from receipts, electronic receipts, other profile data such as contact information, occupation, gender, physical activities or characteristics, health related information, application or device usage data, and your hashed loyalty card numbers.

Only if you have provided us with your consent to do so, we may obtain read-only access to your email account to collect information from your email related to your digital shopping history. We may automatically collect receipt information from your emails about purchase transactions including details of what was purchased, the merchant from which the goods/services were purchased, the amount spent, and the date of the purchase. Consent for this process is controlled by you. You may withdraw your consent at any time within the App.

Only if you have provided us with your consent to do so, we may obtain read-only access to one or more of your merchant accounts to collect information from your account related to your digital shopping history. We may automatically collect information from your account about purchase transactions including receipts or order histories, details of what was purchased, the merchant from which the goods/services were purchased, the amount spent and the date of the purchase. Consent for this process is controlled by you. You may withdraw your consent at any time within the App.

We use the information we collect to manage your account(s). For example, we use the information you provide us and the purchase information you have chosen to provide us with, or otherwise authorized us to collect, to track, process, post and fulfill rewards you earn and to provide customer service. In addition, we may use this information to keep you informed of new features and product developments as well as to provide more relevant offers to you.

We also may use this information for servicing our business partners or clients in a deidentified, aggregated way.  For example, we may use the information we collect to provide clients with deidentified, aggregated market research reports and consumer insights. For example, “What percentage of Males in New York buy Brand X products?”

We also may share this information in other ways as described below.

Our legal basis for using this information includes: (1) your consent when it is required; (2) our legitimate interests, including to improve our sites and services, to better engage with you, and to secure our sites, apps, and services; and, (3) performance of contract so you can receive rewards related to your use of our app.

Personal Information we collect and use when you subscribe to receiving our marketing communications or other communications

We may collect first and last name, gender, email address, phone number, username and password, preferences, or other information you have chosen to share with us about yourself.

We may use this information to send you marketing communications (where you have asked us to), including via text messages, which may be tailored to you based on your preferences and the personal data we know about you.

Our legal basis for using this information includes (1) our legitimate interests which include to improve our sites and services and better engage with you; and, (2) your consent to receive marketing communications from us.

Personal Information we collect and use when you contact our support team

We may collect first and last name, email address, phone number, date of birth, information about your activities and interests, and other information you have shared with us about yourself in relation to your inquiry.

We use this information to communicate with you about your use of our services, to provide support, and to verify your identity for compliance reasons.

Our lawful basis to use this information includes (1) performance of contract to provide you with our service; and, (2) our legitimate interests which include to improve our services, to better engage with you and to secure our sites.

Personal Information we collect by cookies or similar technologies when you visit our website

We may collect data related to your use of our site including where you came from, login details, pages you looked at, duration of your visit, geographic location, and/or the links you click. Technical information collected may include your browser type and operating system, device information, and your Internet Protocol (“IP”) address.

We may use this information to tailor our website for you, that is to show you recommendations, marketing, or content based on your profile and interests.

This data also allows our website to function properly, that is to ensure the proper display of content, create and remember your account login details, improve our App or website, and keep our technology secure and safe and to protect against fraud.

Our legal basis to use this information includes our legitimate interests, including to improve our sites and services, to better engage with you, and to secure our technology.

Categories of Third Parties to Whom Your Information May Be Disclosed

Service Providers. We may use third-party service providers to assist us in making the Services available. Such service providers may obtain access to the information you provide, including Personal Information. Service providers are required to protect this information in a manner that is consistent with this Policy by, for example, not using the information for any purpose other than to carry out the Services they are performing for us. We may also disclose deidentified, aggregated information to service providers in furtherance of our business arrangements with them, including, without limitation, to jointly offer a product or service to you or create interoperability between our services and the services of such providers.

Advertisers. We may provide advertisers and other third parties with aggregated, deidentified information about our user base and its interests and usage patterns. We may also partner with third party advertising companies in order to serve advertising regarding our products and services to users elsewhere on the web after they visit our website. This is a common practice called “retargeting.” For more information on such practices and the ability to opt-out, you may visit http://www.aboutads.info.

Business Partners. We may deidentify and aggregate your Personal Information regarding activity on this Service and make such information available to our business partners, clients, or other third parties. For example, this may include sending aggregated reports to clients regarding characteristics or performance of all components in a given category or a report comparing the price and performance of that client’s products to competitive products listed on the Services.

Government Entities. We may disclose information where we, in good faith, believe that the law or legal process (such as a court order, search warrant or subpoena) requires us to do so or in other circumstances where we believe it is necessary to protect the rights or property of Company, our users and/or third parties.

Affiliates, Parent, or Subsidiary Organizations. We may disclose the information we collect from you to our corporate affiliates or parent and subsidiary organizations. If we do so, their use and disclosure of your Personal Information will be subject to this Notice. In the event of a merger, sale of capital stock or assets, reorganization, consolidation, or similar transaction involving Company, the information we possess, including Personal Information, shall be transferred as a corporate asset to the acquiring entity.

Analytics Providers. We may disclose certain web logs or web beacons, or cookies on your computer or other device to third party analytics providers to assist us in analysis, auditing, research, and reporting regarding the Services. We use Google Analytics to help collect and analyze certain information for the purposes discussed in this Policy. You may opt out of the use of cookies by Google Analytics at https://tools.google.com/dlpage/gaoptout.

How to Make a Consumer Rights Request

You can login to your account within the App at any time to view or amend your account information or to see how to opt-out of your communications. Please note that while changes to your profile information are reflected promptly in active user databases, our servers may retain previously provided information.

To submit a CCPA request to access or delete your Personal Information, please use one of the following methods:

·      Email: privacy@coinout.com

·      Phone: (646) 481-7435

For submitting requests not related to CCPA, please see Section 13 above.

Verification

We must verify your identity before the request can be fulfilled. We may require you to verify yourself via email, phone number, or a third party service. Before we can produce any specific pieces Personal Information, you must submit a signed declaration attesting to your identity under penalty of perjury. Consistent with California law, you may designate an authorized agent to make a request on your behalf. To designate an authorized agent to make a request on your behalf, you must provide valid power of attorney, the requester’s valid government issued identification, and the authorized agent’s valid government issued identification.

No Sale

Coin Out does not and will not sell Personal Information, as defined by the CCPA. Any information disclosed to third parties is aggregated and deidentified so that no person can reasonably identify you as an individual.

Non-Discrimination

Consistent with California law, Company may not deny Services, provide different quality of Services, offer its products at a different price, limit your eligibility for products, or otherwise discriminate against you because you exercise any rights conferred by the CCPA.

17. FINANCIAL INCENTIVE NOTICE

If you are a California resident, starting January 1, 2020, you have a right to receive this Notice of Financial Incentive, as defined in the California Consumer Privacy Act of 2018, Civil Code §1798.100 et seq. (CCPA).  This Notice is to provide you with information regarding any financial incentive that may be provide to you in exchange for your Personal Information. All terms are used in this Notice as defined in the CCPA or applicable regulations thereunder.

Summary of the Financial Incentive

We enable you to earn rewards for submitting your receipts that you got when making purchases in stores and/or online. In exchange for your participation, you have the opportunity to earn points for submitted receipts and other methods in exchange for rewards as well as to have your receipt information automatically collected to allow for easy submission. You may also be eligible to earn points through various promotional offers as stated within the App from time to time.

For more specifics on how the CoinOut Rewards Program works, please review the official rules at https://www.coinout.com/pages/terms.

How Do I Qualify for the Financial Incentive?

The incentives that are offered are financial rewards in exchange for the disclosure of certain information (i.e., the categories of information as stated above). To redeem rewards through the App, you must register an account with us and submit eligible receipts. In some instances, you may have the opportunity to provide Personal Information on an ongoing basis in exchange for rewards or other financial incentives, and the amount or nature of which will be specified in each instance within the App at the time the Personal Information is to be submitted.

Please review this section carefully prior to registration. We review the information, materials, and activities regularly to ensure compliance with rules, regulations, and Company policies and terms.  We reserve the right, in our sole discretion, to suspend or disqualify an account if we determine, in our sole discretion, that an act or activity taken by you may be inconsistent with applicable laws, regulations, or Company policies and terms.  We reserve the right, in any such prospective suspension or termination, to nullify any and all rewards that your account may have accumulated, if we so determine in our sole discretion.

For more specifics on how the CoinOut Rewards Program works, please review the official rules at https://www.coinout.com/pages/terms.

Opt-In/Opt-Out to the Financial Incentive

You can opt-in the financial incentive by downloading and successfully registering for the App (including connecting your email address) and submitting receipts or participating in any promotional offers as stated within the App. If you subsequently wish to withdraw from the financial incentive, you may do so at any time within the App or contacting us.

For more specifics on how the CoinOut Rewards Program works, please review the official rules at https://www.coinout.com/pages/terms.

Valuation

Each financial incentive is reasonably related to your submission and the use of your information, which is based upon good-faith estimates by us and/or our service provider(s) and/or commercial partner(s) of the value of such information. To value this exchange, items taken into consideration include, without limitation, estimates regarding the anticipated revenue generated from such information, the anticipated expenses which might be incurred in the collection, storage, and use of such information in the operation of the Services, and other relevant factors related to the estimated value of such information to our commercial partner(s), as permitted under the CCPA.

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