Types of Information Collected
"Personal Information" which includes any information that can be used to identify, locate, or contact you including but not limited to your name, mailing address, email address, social media account names and telephone numbers. We may also collect Personal Information about you from third- parties and that information that may be added to your Personal Information or a related category of information.
"Non-Personal Information" which includes any information that does not identify you or has been provided anonymously and may be obtained either by you or through information collected as part of your use of our Applications and Services including, but not limited to, the type of browser you are using, where your visit originated from (i.e., what website), the terms searched to located our Applications and Services, etc.
"Association Information" which includes any information collected that provides us with a better understanding of you, your likes and dislikes. This may include information about your lifestyle, location, areas of interest, demographic information such as your birthday, age and gender, and other information obtained from social media interactions. This information also includes information about Treats received and purchased by you and information regarding referrals from friends and your referral of friends.
"Commerce Information" which includes information related to your use of Treater such as, but not limited to, "Treats" viewed, purchased and/or redeemed and use and interaction with Treater's Applications and Services. This includes any comments that you may make in a public forum including but not limited to social media sites, discussion groups, bulletin boards or the Treater Activity Wall.
"Monetary Account Information" which includes information provided by you in processing payment for any "Treats" purchased including, but not limited to, financial information such as debit or credit card numbers, expiration date and card verification numbers.
"Location Information" which includes location based information about your real-time location that is collected from your mobile device, or a mobile application activated by you, and that you permit or authorize to be transmitted to us. Separate notice regarding the ability of any mobile application to access your Location Information will be provided as part of any download of the mobile application or as update to the application prior to use
Collectively, the information defined and listed above is referred to as "Information" and when that term is used is intended to cover all types and categories of information collected.
When Information is Collected
Information is collected at various points during the use of our Applications and Services. We may ask for Personal Information including Association Information when registering or creating an account with Treater. When you are using our Applications and Services we may collect Personal Information, Non-Personal Information, Association Information and Commerce Information from you. Cookies and related technologies may also be used to collect Association Information, Commerce Information and Non-Personal Information and this information may be collected even when you are not using our Applications and Services. When you contact us for customer support purposes either by email, telephone, text, mail, social media or other methods Information is collected and if such interactions are verbal they may be recorded for quality assurance purposes.
Information about a Recipient, including Personal Information and Association Information, is collected when you select, purchase and transmit a "Treat" to that Recipient.
Personal Information and Location Information may be collected in using our Applications and Services if your Connection is through a mobile device. If you have any concerns or questions regarding the security and privacy setting on your mobile device and the use of our Applications and Services, please consult the instructions for your mobile device, contact its manufacturer or contact your mobile carrier. Monetary Account Information is collected and transmitted to third-party providers when you purchase a Treat.
How Information Collected Is Used
In general, Information collected is used to operate and improve Treater Applications and Services including but not limited to user interface and suggested "Treats." Information collected is used to provide customer support, reminders, notices, updates, security alerts and to administer surveys, conduct analytics and generally manage Treater's day-to-day business operations, which includes, but is not limited to, Applications and Services management and administration, reporting obligations and compliance with the law and fraud prevention.
Personal Information collected is used to complete transactions and requests initiated by you, improve customer service and respond to questions by you regarding the transaction or request. Personal Information may be used for future contact by us about promotions, offers or other information from us or an affiliated company. You can opt-out of receiving future promotions, offers or other information from us or an affiliated company at any time by clicking a related opt-out link on the notice page or by contacting us as discussed in more detail below.
Personal Information may be shared with the merchant identified with the "Treat" so the merchant can send specific offers to the user, confirm the purchase, assist with redemption, combat fraud, and generally enhance the overall Treater experience. Those merchants are encouraged to and should have their own privacy policies and statements that should be provided and disclosed to you as part of any contact from them. Personal Information will also be shared with third-parties where you have specifically elected to share such information by joining, clicking or assenting to the sharing of such information after receiving notice.
Non-Personal Information is used in a variety of ways to evaluate our Applications and Services and track usage and redemption rates, decipher customer trends and needs, facilitate marketing and advertising campaigns, and other similar type uses. Non-Personal Information, Commerce Information and Association Information maybe be aggregated, manipulated and provided to merchants, partners or other third parties for statistical purposes as well as to provide interested parties with non-identifiable information about our users and Recipients.
Non-Personal Information, Association Information and Commerce Information is collected and stored to assist you and/or other users in selecting future "Treats" that a particular user may enjoy. This information may be collected through third-party sources.
Information is collected and used to create a transaction record of the "Treat" purchased and/or redeemed. Information may be shared with third-party vendors responsible for performing functions related to the use and operation of Treater's Applications and Services, including, but not limited to, credit card processing, marketing assistance, data analysis and customer service. This Information is shared with vendors to complete requests made of them and the vendors are required by law, or contract, to protect any such Information and use it only as set forth in our agreements and/or contracts with them. In some instances, Personal Information, Non-Personal Information, Commerce Information and Association Information may be shared with sponsors of a particular program or service that we have a relationship with to facilitate the operation of the program or service. Personal Information is not, except as set forth below, shared or sold to third parties without your prior notice and approval.
Information may be disclosed in the case of litigation, legal claims, regulatory actions and law enforcement actions or when required to by law in response to a legal process such as, but not limited to, a subpoena.
Postings to Facebook, Social Media Sites and the Treater Activity Wall
YOUR USE OF TREATER, INCLUDING THE GIVING AND RECEIVING OF "TREATS" IS POSTED ON YOUR AND YOUR RECIPIENT'S FACEBOOK WALL AND/OR IN THE LIVE FEED. IN REDEEMING A "TREAT," A RECIPIENT IS AGREEING TO ALLOW TREATER TO POST NOTICE OF THAT REDEMPTION ON THE PURCHASER'S AND/OR RECIPIENTS' FACEBOOK WALL AND/OR LIVE FEED. IF YOU, DO NOT WANT INFORMATION ABOUT YOUR USE OF TREATER POSTED ON YOUR FACEBOOK WALL OR IN YOUR LIVE FEED, PLEASE DO NOT USE OR REDEEM ANY "TREATS." DEPENDING ON YOUR PRIVACY SETTINGS ON FACEBOOK, POSTINGS ON YOUR WALL MAY BE VISIBLE WITHIN YOUR PRIVATE NETWORK AS WELL AS TO THE PUBLIC.
Treater maintains an "Activity Wall" that contains a randomly selected collection of messages, photos or videos (collectively referred to as "messages") created by individuals when sending, receiving or redeeming a Treat and this live stream of messages is visible to anyone visiting the Treater website or using Treater's Applications and Services. Individuals can elect to not have messages sent, or a particular message, included on the Activity Wall by changing the default settings for their account or individually selecting not to include a message in the Activity Wall. If you do not change your default Treater settings, or if you do not actively elect not to list a message on the Activity Wall, any message you send or receive including photos and videos may be selected and posted to the Treater Activity Wall which is visible to the public and includes Personal Information such as your Facebook username or id.
Treater does provide an ability to "opt-out" of the posting and receipt of "Treat" notices and the inclusion of messages on the Activity Wall. Information and notice regarding opting out is provided to you as part of your use of Treater's Applications and Services.
Information Collected From Facebook
Information Received from Contests and Promotions
Cookies and Related Technologies
To assist us in recognizing you and to improve your use of our Applications and Services, we collect Non-Personal Information, Commerce Information and Association Information through the use of automated or electronic means such as cookies, pixel tags, web beacons, browser analysis tools, web server logs and other technologies. These technologies, such as cookies or web beacons, work by placing small files on your Connection's hard drive, memory or web browser that then allow us to remember you when you return or revisit our Applications and Services. They also allows us to track your online movements to provide additional useful information to you for future visits. Any technologies used do not collect and are not tied to Personal Information. Non-Personal Information, Commerce Information and Association Information collected includes information such as, but not limited to, your operating system type, browser type, system setting, language used, country, time zone, sites visited, items clicked, etc. all of which helps us optimize our Applications and Services. Connection devices can be set to limit the acceptance of cookies and other technologies, and cookies and other technologies can be removed from devices, however, limiting acceptance of the same and removing them may impact the functionality of our Applications and Services.
Our Applications and Services are not intended for use by children. As set forth in our Terms and Conditions, you must be 18 years old to register for Treater. Treater does not knowingly collect any Personal Information about children under the age of 13 and if you are parent or guardian of a child under the age of 13 and believe he or she has disclosed Personal Information please contact us immediately at email@example.com concerning removing or deleting such Information and prohibiting use of that Information.
Security of Information
Treater has reasonable security measures in place that contain administrative, technical and physical controls to protect and safeguard Information, including Personal Information, against loss, misuse or alteration. Treater, however, cannot guarantee or warrant the security of any Information disclosed by you or transmitted to us via the internet or mobile device and is not responsible for the inadvertent disclosure or destruction of said Information. If you believe that there has been a breach in the security of Information disclosed to us, please contact us immediately at firstname.lastname@example.org.
Information about you and any transactions or purchases you make will be retained for as long as your account is active or as needed for financial reporting and compliance reasons. If you would like to close your account please contact us. Records of past interactions and transactions may not be available for closing or deleting due to reporting and compliance requirements.
California Privacy Rights
If you live in California, pursuant to Section 1798.83 of the California Civil Code, you have the right to request from companies certain information about the types of Personal Information they have shared with third-parties for direct marketing purposes during the previous calendar year. The law requires that companies inform consumers about (1) the categories of Personal Information that have been shared with third parties, (2) the names and addresses of those third parties, and (3) examples of the types of services or products marketed by those third parties. If you would like a copy of the disclosures provided by Treater under Section 1798.83, please contact us at email@example.com or SGN Inc., Attn: Privacy Officer, 1515 N Courthouse Road, Suite 1000, Arlington, VA 22201, and please include your name, address where you would like the response sent, and username so that we can identify your account. Please allow 30 days for a response.
Contacting Us – Opting-Out
Attn: Privacy Officer
1515 N Courthouse Road, Suite 1000
Arlington, VA 22201
All requests will be responded to and addressed, but in certain instances may not be able to be met while still allowing access to and use of Treater Applications and Services.