Effective Date: January 1st 2020
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Last Updated: December 29, 2022
Your use of the Service is also governed by our Terms and Conditions SteadFastLoyalty
PLEASE NOTE THE ARBITRATION PROVISION SET FORTH BELOW, WHICH, EXCEPT WHERE AND TO THE EXTENT PROHIBITED BY LAW, REQUIRES YOU TO ARBITRATE ANY CLAIMS YOU MAY HAVE AGAINST COMPANY ON AN INDIVIDUAL BASIS. ARBITRATION ON AN INDIVIDUAL BASIS MEANS THAT YOU WILL NOT HAVE, AND YOU WAIVE, THE RIGHT FOR A JUDGE OR JURY TO DECIDE YOUR CLAIMS, AND THAT YOU MAY NOT PROCEED IN A CLASS, CONSOLIDATED, OR REPRESENTATIVE CAPACITY.
1. Collection of Information
We collect “personal information,” which we define as any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or can reasonably be linked, directly or indirectly, to an individual, household, or device. We have collected the following personal information from users of our Service in the last 12 months:
|Category of personal information||Source(s)||Purpose(s)||Disclosure to third parties
|Identifiers, e.g., name, postal address, online identifier, Internet Protocol address, email address or account name||Directly from youIndirectly from you (e.g., from observing your actions on our Service)From third party service providers, such as a data analytics provider or lead generation providers||To fulfill or meet the reason you provided the information, e.g., to respond to an inquiry, process your order or request||Sale to: advertising networks and lead purchasersDisclosure for business purposes to: internet service providers, payment processors, lead vendors
|Private, non-public personal information contained in customer records, e.g., name, address, telephone number, bank account number, credit card number, debit card number, or any other payment and financial information||Directly from youIndirectly from you (e.g., from observing your actions on our Service)From third party service providers, such as a data analytics provider or lead generation providers||To fulfill or meet the reason you provided the information, e.g., to respond to an inquiry or process your order or inquiry||Disclosure for business purposes to: internet service providers, payment processors, lead vendors
|Protected classification information, e.g., race, political affiliations, etc.||Directly from youFrom third party service providers, such as a data analytics provider or lead generation providers||To fulfill or meet the reason you provided the information, e.g., to provide targeted advertising||Sale to: advertising networks
|Employment information, e.g. employment history, background check information, etc.||Directly from you||To fulfill or meet the reason you provided the information, e.g., to respond to an inquiry or process your order or inquiry||Sale to: advertising networks, lead vendors
|Commercial information, e.g., records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies||Directly from youFrom third party service providers, such as a data analytics provider or lead generation providers||To fulfill or meet the reason you provided the information, e.g., to respond to an inquiry or process your order||Disclosure for business purposes to: payment processors, lead vendors
|Internet or other similar network activity, e.g., browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement||Indirectly from you (e.g., from observing your actions on our Service)From third party service providers, such as a data analytics provider||To fulfill or meet the reason you provided the information, e.g., to provide targeted advertising||Sale to: advertising networks, lead vendorsDisclosure for business purposes to: internet service providers, payment processors
|Geolocation data, e.g., physical location or movements||Directly from youFrom third party service providers, such as data analytics providers||To fulfill or meet the reason you provided the information, e.g., to respond to an inquiry, process your order, or provide targeted advertising||Sale to: advertising networks, lead vendorsDisclosure for business purposes to: internet service providers, payment processors
|Inferences drawn from other personal information, e.g., profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes||Directly from youIndirectly from you (e.g., from observing your actions on our Service)From third party service providers, such as a data analytics provider or lead generation providers||To fulfill or meet the reason you provided the information, e.g., to respond to an inquiry, process your order or request||Sale to: advertising networks and lead purchasersDisclosure for business purposes to: internet service providers, payment processors, lead vendors
xamples of specific pieces of personal information we may collect include:
Other personal information voluntarily disclosed by you
Online identifiers, such as username and IP address
Interactions with our partners’ websites, e.g., what you are viewing, your interactions with certain campaigns, etc.
2. Use of Information
We use the personal information we collect for the following purposes:
To provide our Service, e.g., to provide you with information regarding other third party service providers and or to share your information to facilitate your request.
To send you marketing communications.
To respond to your requests and inquiries.
To improve user experiences by making our Service easier to use and navigate.
For other legitimate business purposes.
3. Sharing and Disclosure of Information
We may disclose your personal information to a third-party for a business purpose or sell your personal information (subject to your right to opt-out of those sales if you are a California consumer; see below in Section 11). We may also sell your personal information to third parties that may themselves re-sell your personal information. We may share or disclose your information to the following categories of third parties and for the following reasons:
To our partners, whose advertisements you view and click on.
To our partners when you ask us to find applicable servicers for you.
To third party service providers, agents or independent contractors who help us maintain our Services, provide other administrative services to us, and also provide relevant information to you.
We may share your personal information in the course of any reorganization process including, but not limited to, mergers, acquisitions, and sales of all or substantially all of our assets.
We may disclose your personal information to law enforcement, government agencies, and other related third parties, in order to comply with the law, enforce our policies, or protect our or others’ rights, property or safety.
We, or third parties, may use session cookies or persistent cookies. Session cookies only last for the specific duration of your visit and are deleted when you close your browser. Persistent cookies remain on your device’s hard drive until you delete them or they expire. Different cookies are used to perform different functions, which we explain below:
Essential. Some cookies are essential in order to enable you to move around our website and mobile applications and use their features, such as accessing secure areas of the Services. Without these cookies, we cannot enable appropriate content based on the type of device you are using.
Browsing and Functionality. We use these cookies to remember choices you make on the Services, such as your preferred language and the country from which you are visiting, and to provide enhanced, more personalized features.
Performance and Analytics. We use third party cookies to see how you use our Services in order to improve their performance and develop them according to your preferences.
There are several ways to manage cookies. Please check your browser and browser settings to determine where these types of cookies are stored and whether and how they may be deleted. The help portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable most cookies altogether. Please note that if cookies are disabled or removed, not all features of our Service will operate as intended.
4. Collection and Use of Information from Children
Our Services are not intended for children. We do not knowingly collect personal information from children, and our Services are not designed to attract children. In the event that we learn that a child under the age of 18 has provided personal information to us, we will delete such personal information as soon as possible.
5. Third Party Links
When you use our Service, there may be links and you may be directed to third party websites. We are not responsible for the privacy practices or content of such other sites. If you have any questions about how these other sites use your information, you should review their policies and contact them directly.
We implement reasonable security measures to ensure the security of your personal information. Please understand, however, that no data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to us is done at your own risk. If we learn of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using our Service or otherwise providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Service. We may post a notice via our Service or website if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
7. International Data Transfers
8. Dispute Resolution and Agreement to Arbitrate
You, at the address we have on file for you.
Both you and SteadFastLoyalty. agree that this dispute resolution procedure is a condition precedent that must be satisfied before initiating any litigation or filing any claim against the other party. IF ANY DISPUTE CANNOT BE RESOLVED BY THE ABOVE DISPUTE RESOLUTION PROCEDURE, YOU AGREE THAT THE SOLE AND EXCLUSIVE JURISDICTION FOR SUCH DISPUTE WILL BE DECIDED BY BINDING ARBITRATION ON AN INDIVIDUAL BASIS. ARBITRATION ON AN INDIVIDUAL BASIS MEANS THAT YOU WILL NOT HAVE, AND YOU WAIVE, THE RIGHT FOR A JUDGE OR JURY TO DECIDE YOUR CLAIMS, AND THAT YOU MAY NOT PROCEED IN A CLASS OR CONSOLIDATED CAPACITY. Other rights that you and we would otherwise have in court will not be available or will be more limited in arbitration, including discovery and appeal rights. All such disputes shall be exclusively submitted to JAMS (www.jamsadr.com) for binding arbitration under its rules then in effect, before one arbitrator to be mutually agreed upon by both parties.
9. Choice of Law
In the event that all or part of our assets are sold or acquired by another party, or in the event of a merger, you grant us the right to assign the personal information collected via the Service.
11. Your California Privacy Rights
California Civil Code Section 1798.83 permits users who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please email us using the contact information provided below and put “Shine the Light” in the subject line of your request.
From January 1, 2020, many California consumers now have the following rights:
Right to know
You have the right to request information about the categories and specific pieces of personal information we have collected about you, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties with whom we share such information.
You also have the right to request information about our sale or disclosure for business purposes of your personal information to third parties in the preceding 12 months.
You may also request a copy of the personal information we have collected, and upon request, we will provide this information to you in electronic form.
Right to delete
You have the right to request the deletion of your personal information, subject to certain exceptions.
Right to opt-out of sale
You have the right to opt out of the sale of your personal information to third parties. Note that some of the third parties to whom we sell your personal information may also sell the personal information that they receive from us. You can exercise this right through the webform “Do Not Sell My Personal Information” link in the footer of our websites. We do not sell the personal information of minors under the age of 16 without affirmative authorization.
Right to non-discrimination
You have the right to not be discriminated against for exercising any of these rights.
If you would like to exercise one or more of the rights above, please contact us using the contact information provided below. If you are emailing, please write “Data Subject Request” as your subject line, and explicitly state which right you are exercising in the body of the email. If using the webform, then explicitly state which right you are exercising within the body of the description section. You may designate an authorized agent to make a request on your behalf. Such authorized agent must be registered with the California Secretary of State. We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf.
When submitting a request, we may need to take certain steps to ensure that we are receiving a verifiable consumer request before completing your request, and, for example, may ask for you to confirm data points we already have about you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Whenever feasible for verification, we will match the identifying information provided by you to the personal information already maintained by us. If, however, we cannot verify your identity from the information already maintained by us, we may request additional information.
12. How We Respond to Do Not Track Signals
We do not support “Do Not Track” browser settings and do not currently participate in any Do Not Track frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your personal information.
14. Contact Us