CCPA COMPLIANCE

About the California Consumer Privacy Act

The California Consumer Privacy Act (CCPA) is a new data privacy law that establishes various rights for California state residents. The law applies to companies that do business in California and meet one of several criteria related to revenue, data processing, and other factors. CCPA requires giving residents the right to opt-out of the “sale” of their “personal information” (as the law defines those terms).

Personal Information We Collect

ConFusion L.L.C. dba Promotion Vault. (herein “Promotion Vault” “we,” “us”, “our” or “PV”) collects, stores, and uses certain information from sponsoring businesses.  Such information may include “personal information” which means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.  Personal Information we collect includes identifiers such as your name, and email address. We may also collect non-personally identifiable information, such as the date and time of your visit to the Website, pages accessed, the type of browser used, and other “traffic data”. We may link traffic data to the Personal Information you submit while on the Website, when you are logged into the Website, or in connection with a service you have requested.

Personal Information

Promotion Vault manages the distribution of eGift Cards used as promotional incentives for our client(s) the sponsoring business. Eligible Participant data shared with PV in order to fulfill and support the redemption of the reward on behalf of the sponsoring business includes: first name, last name, email address, purchase data, time stamps, and customer demographics.

From time to time we may also use the “cookies” feature of major browser applications. This feature allows us to store a small piece of data on your computer about your visit to the Website. Cookies are small files of information that save and retrieve information about your visit to the Website. We may use cookies to make your visit to the Website easier. Most browsers are initially set-up to accept cookies. If you do not wish information to be gathered on a cookie, it may be possible to disable the acceptance of cookies by changing the settings on your web browser. However, disabling cookies may impair your access to and ability to utilize certain features on the Website. Your experience at the Website may be diminished and some features may not work as they were intended if you disable cookies. If you are not sure whether your browser has the capability to opt-out of receiving cookies, you should check with the software manufacturer or your internet service provider.

Promotion Vault is not responsible for the privacy practices or the content of other websites that may be linked to the Website. You should carefully review the privacy policies of those websites to determine how they treat your Personal Information.

PURPOSE AND USE OF COLLECTING PERSONAL INFORMATION

Our Use of Personal Information

We may use Personal Information for business purposes, including to facilitate processing of transactions, to send you information about Promotion Vault, or to otherwise contact you. We may also use your Personal Information to inform you of any changes to the Website, to verify your identity or check your qualifications. We may also use your Personal Information to operate, understand, optimize, develop, or improve the Website, including bug detection and error reporting, and to ensure security, fraud, and legal compliance.

Personal Information may be shared with third-party service providers utilized by Promotion Vault to perform services for the Website, providing key functions of the Website, information processing, responding to inquiries and sending email. Service providers and affiliates may be provided with your Personal Information to perform core services related to the operation of the Website (such as hosting or data storage and security) or perform services on your behalf that you initiate through the Website. The service providers utilized by Promotion Vault and its affiliates are obligated to protect your Personal Information.

Notwithstanding the above, we may disclose Personal Information if required to do so by law or in the good-faith belief that such action is necessary to:

• conform with the law or comply with legal process such as a search warrant, subpoena, or court order;


• enforce or investigate potential violations of our policies, procedures, disclaimers, and conditions of use for the Website;


• protect and defend our rights or property;


• investigate and defend ourselves against any third-party claims or allegations;


• protect against misuse or unauthorized use of the Website; or


• during emergencies, such as when we believe someone’s physical safety is at risk or to protect the safety of the public or users of the Website.

We reserve the right to send communications to you which alert you to important information regarding the Website, including, but not limited to, communications regarding administrative, policy, or legal matters which may affect your use of the Website.

How We Share Personal Information with Third Parties

Promotion Vault does not sell your Personal Information.  We do share your Personal Information, such as your name, address and email address with our clients (Sponsoring Business) with whom you’ve chosen to interact to purchase a service or product.

In the event that all or a portion of our business is acquired by or merged with a third-party, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from you, including Personal Information, to the third-party as part of such merger, acquisition, sale, or other change of control.

CONSUMERS’ RIGHTS CONCERNING THE COLLECTION, DISCLOSURE OR SALE OF THEIR PERSONAL INFORMATION UNDER THE CALIFORNIA CONSUMER PRIVACY ACT

The following information on the California Consumer Privacy Act (Cal. Civ. Code § 1798.100 et seq.) (“CCPA”), applies to California residents who have certain rights regarding Personal Information collected by Promotion Vault. It does not cover Personal Information not subject to the CCPA rights identified below, such as Personal Information we collect from our employees or job applicants. The CCPA does not extend all the rights identified below to Personal Information collected from employees, owners, directors, officers, or contractors of businesses in the course of our provision or receipt of business-related services.

Under the CCPA, California residents have the following rights:

• Right to Know. Subject to certain exceptions, you have the right to know what specific pieces of Personal Information Promotion Vault has collected about you in the 12 months preceding your request, along with the categories of Personal Information we have collected, the categories of sources of that Personal Information, our business or commercial purpose for collecting your Personal Information, and the categories of third parties with whom we share your Personal Information. You may make this request no more than twice per 12-month period.


• Categories of Personal Information We Collect. We collect the following categories of Personal Information, as described in more detail in this Privacy Policy: identifiers and commercial information.


• Categories of Personal Information We Sell.  Promotion Vault does not and will not sell your Personal Information.


• Categories of Personal Information We Disclose. We provide the following categories of Personal Information to third parties for business purposes, as described in more detail in this notice: identifiers and commercial information.


• Right to Delete. Subject to certain exceptions, you have the right to request deletion of the Personal Information Promotion Vault has collected from you.  Pursuant to the CCPA, the exceptions include:
  
  • Completing the transaction for which the Personal Information was collected;
  
  
  • Detecting security incidents or protecting against and prosecuting malicious, deceptive, fraudulent, or illegal activity;
  
  
  • Complying with our legal or compliance obligations; and
  
  
  • Other reasons that are in connection with our lawful internal uses that are consistent with your relationship with us and the context in which the Personal Information was collected.


• Non-Discrimination. Promotion Vault will not discriminate against you if you exercise your rights under CCPA. However, if your request requires us to delete, restrict, or not share information, please be advised that this may inhibit some functionality of the Website. Any subsequent interaction with the Website after deletion will require new requests for action on your data.

Exercising Your Rights under CCPA

You can exercise any of your rights under the CCPA, or obtain more information for your questions or concerns, by filling out the form provided for this purpose below, or by calling our toll-free telephone number at 866.996.5825

You are permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide written permission for the authorized agent to make such requests or a power of attorney. We may also follow up with you to verify your identity according to the following methods before processing the authorized agent’s request.

We will take reasonable steps in light of the nature of the Personal Information requested to verify your identity before responding to a request.  To complete the verification process, we will ask you to both: (1) provide at least two pieces of evidence that match the Personal Information that we have on file for you, such as your email address and full name; and (2) provide a statement that you “declare under penalty of perjury” that you are the person about whom the request has been made. 

In the unlikely event that we are not able to verify your identity from the Personal Information that we already have on file for you, we may request additional information from you.  Such additional information would only be used for purposes of verifying your identity and for security or fraud prevention purposes, and we would delete such additional information as soon as practical after processing your request.

PROMOTION VAULT PRIVACY POLICY TO CONSUMERS

In this Privacy Policy, we, ConFusion L.L.C. dba Promotion Vault. (herein “Promotion Vault” or “PV”) provide information about how we collect, use and transfer personally identified data from you, an individual person and eligible participant. Promotion Vault is committed to maintaining the privacy of our clients and sponsoring businesses customers and those that directly or indirectly utilize our services. The following policy guidelines explain how PV collects and uses the data provided by you the participant and our clients.

Data Collection

PV data collection is limited to just what is needed to fulfill and support the reward(s) being provided to you by the sponsoring business, our client. PV is provided your data from the sponsoring business when you take a qualifying action for a specific promotion and / or are eligible for a reward. PV also collects data if you contact customer support as needed for eligibility identity purposes and enhancing the overall experience of the Promotion Vault application and service.

How PV Uses Information

PV manages the distribution of eGift Cards used as promotional incentives for our client(s) the sponsoring business. Eligible Participant data shared with PV in order to fulfill and support the redemption of the reward on behalf of the sponsoring business includes: first name, last name, email address, purchase data, time stamps, and customer demographics.

Data Disclosure

PV will not disclose eligible recipient information to third parties. We do reserve the right to disclose information that we believe is appropriate or necessary to take precautions against liability; protect sponsoring businesses from unlawful uses or if required to do so by law.  From time to time we may ask for feedback as it relates to the gift cards chosen in an effort to provide feedback to our retail partners.

Eligibility Communication Rights

PV will not be able to provide fulfillment or support services to anyone who chooses to not share the data needed to qualify them as an Eligible Recipient. If you do not want to receive offers from our sponsoring businesses you may opt-out directly from those sponsoring businesses by following the opt-out instructions in their communication channels.  You may also opt-out from receiving any communications from Promotion Vault @ https://my.promotionvault.com/unsubscribe/.

Questions Or Concerns Related To The Data We Collect

If you have any questions or concerns related to the data we collect please contact us at engage@promotionvault.com. We maintain the data we collect for as long as needed to provide fulfillment and support services, enhance the eligible recipient experience and to maintain and meet all legal requirements.

Minor Privacy

We will not knowingly collect Personal Information from the sponsoring business or through our customer support channels for anyone we know to be under 18 years of age.

Change of Control

If Promotion Vault is acquired or merged with another entity, we reserve the right to transfer or assign the information we have collected as part of such change of control.

OPT-OUT AND REQUEST FOR DATA