Last Updated: August 15, 2019
PROTECTING CHILDREN’S PRIVACY
The Services are not directed, or intended to be attractive, to children under the age of 13. We do not knowingly collect personal information from children under the age of 13. If you are under the age of 13, do not use the Services or submit any information to us. If we learn we have collected or received personal information from a child under the age of 13 without verification of parental consent, we will delete that information. If you believe we might have any personal information from or about a child under the age of 13, please contact us.
TYPES OF INFORMATION WE COLLECT AND HOW WE COLLECT IT
Information You Provide to Us. In general, you may visit the Website or download the Application without telling us who you are or sharing any Personal Information with us. When you register for an account for the Services (an “Account”), use other aspects of the Services, or communicate with us for customer service or technical support for the Services, we may ask you to provide certain Personal Information, such as your name, email address, postal address, mobile number, and payment account information. Additionally, if we are required by law to send to you and file certain forms with tax authorities, we may ask you to provide us or our service provider certain personal information, including but not limited to your Taxpayer Identification Number. We may also ask you whether you want to receive text messages relating to the Services. By providing your mobile phone number, you expressly consent to receive text messages from us relating to the Services at that number. Third-party data and message fees may apply. You may decline to provide certain Personal Information to us, but, if you do so, certain features of the Services may not be available to you or the performance of certain features of the Services may be limited or not work at all.
Information Collected from Devices. When you access or use the Services via a computer or mobile device, including, without limitation, a desktop computer, laptop, mobile phone, tablet, or other electronic device (each, a “Device”), we may collect information from your Device, such as your Device type and manufacturer, your Device operating system and version, your mobile carrier, your Device identifiers, your mobile phone number, your IP address, your browser type, your network connection type, information about the webpage that referred you to the Website or that you visited prior to the Website, and your behavior and activity on the Website and the Application.
In addition, if you download the Application to your mobile Device, we may collect information from your mobile Device about your location while you are accessing or using the Application and while you are not accessing or using the Application. We may use this information to provide targeted offers to you and notify you of nearby third-party locations where you may use the Services. You may opt out of the collection of location data at any time by changing your settings on your mobile Device. However, if you do so, certain features of the Services may not be available to you or the performance of certain features of the Services may be limited or not work at all.
The Cookies we use in connection with the Services may include the following:
• Session Cookies: Session Cookies are temporary Cookies that expire and are automatically erased when you close your browser window. We may use session Cookies to grant you access to content and to enable actions that require you to be logged into your Account to perform.
• Persistent Cookies: Persistent Cookies are Cookies that usually have an expiration date in the distant future and remain in your browser until they expire or you manually delete them. We may use persistent Cookies to better understand usage patterns so we can improve the Services. For example, we may use a persistent Cookie to associate you with your Account or to remember your choices for the Services.
In some of our email messages to you, we may use “click-through URLs” linked to content on the Website or the Application. We track click-through data to help us understand and analyze interest in topics and use of the Services.
Do Not Track. Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not use technology that recognizes DNT signals from your web browser.
Information Collected from Payment Card Networks and Transaction Monitoring. When you link an eligible credit or debit card (a “Payment Card”) to your Account, we may collect Personal Information, including transaction information, from your Payment Card Network (e.g., Visa, Mastercard, American Express). By linking a Payment Card to your Account, you authorize: (a) us to share your Payment Card information with the third parties that enable us to provide the Services, such as the payment processor Braintree (“Third-Party Service Providers”) and your Payment Card Network so it knows you enrolled for the Services; and (b) the Payment Card Network to (i) monitor transactions on your Payment Card to identify qualifying purchases in order to determine whether you qualify for or earn an offer linked to your Payment Card in connection with the Services; and (ii) share such transaction details with us to provide the Services to you. You may opt-out of such transaction monitoring on the Payment Card(s) you have registered by de-linking them through the Services or by terminating your Account. To terminate your Account and your right to use the Services at any time and for any reason and for no reason, contact Customer Support and immediately discontinue all use of the Services. Please note that if you opt-out of transaction monitoring, certain features of the Services may not be available to you or the performance of certain features of the Services may be limited or not work at all.
• to confirm a qualifying purchase or return to match transactions to confirm whether you qualify for an offer or statement credit;
• to create a record of the transaction information and thereafter maintain and use data in connection with the Services;
• to provide targeted offers that may be of interest to you;
• to conduct analysis for the improvement and optimization of the Services;
• to inform participating merchants where a transaction occurred as needed for the merchant to confirm a specific transaction occurred or points should be awarded; for example, we may share the date and amount of your purchase and the last 4 digits of your card number so the merchant can verify your purchase with its records or confirm if there is a missing or disputed transaction;
• to provide participating merchants aggregated and anonymized information relating specifically to registered Payment Card activity solely to allow participating merchants to assess the results of their campaign;
• to provide information in order to respond to a request from government authority or a payment organization involved in a transaction with you or a merchant; and
• to enable the sharing, exchange and use of transaction information described above and herein by and among us, the Payment Card Networks, applicable Third-Party Service Providers and applicable merchants.
Information Collected from Other Third Parties. We may collect Personal Information from third-party social networks, subject their respective privacy policies and your privacy settings. We may also collect Anonymous Information, including Device identifiers, from third-party devices present at certain third-party locations, such as retail stores, restaurants, and other points of interest. Such devices may use wifi, near field communication (NFC), or Bluetooth low-energy (BLE) beacon technology to transmit signals about the location of your Device to us so that we may notify you via push message that you are near a location where you may use the Services.
HOW WE USE INFORMATION
• provide the Services and notices related thereto;
• analyze, improve and customize the Services;
• provide customer and technical support for the Services;
• send you announcements, newsletters, promotional materials, and other information about the Services and third-party products and services that we think may be of interest to you;
• detect, prevent and investigate actual or suspected fraud, hacking, infringement, or
• other misconduct involving the Services;
• collect fees and other amounts owed in connection with the Services; and
• comply with tax and other applicable laws.
In the event you or Dosh terminates your account, you agree that we may retain your data, including personal and transaction information, for one year from the date of termination for audit and merchant invoicing purposes.
HOW WE SHARE INFORMATION
• if you request or authorize it;
• to complete a transaction or provide a service requested by you;
• to our Third-Party Service Providers that provide services to support the Services, such as payment processing, data analysis, email delivery, hosting, order fulfillment, infrastructure, network storage, customer service, technical support, and promotional services and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them;
• to comply with applicable laws, rules, and regulations, including but not limited to tax laws;
• to comply with governmental and regulatory requests, court orders, and subpoenas;
• to protect our rights, property, and safety and the rights, property, and safety of our users and others
• to enforce our rights arising from any contracts entered into between you and us, including the Terms of Service;
• with merchants that you transact with that already have Personal Information about you for the purpose of verifying offer-qualifying transactions; and
• if the disclosure is done as part of a purchase, transfer, or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, your Personal Information may be one of the transferred assets) or in the event of bankruptcy.
YOUR CHOICES ABOUT YOUR INFORMATION
You may opt not to receive promotional emails from us by contacting us or by following the “unsubscribe” instructions in any promotional email you receive from us. Please note, however, that we may still send you non-promotional emails about your relationship with us.
INFORMATION YOU SHARE SOCIALLY
The Services may allow you to connect and share your actions, comments, content, and information publicly or with friends. The Company and the Payment Card Networks are not responsible for maintaining the confidentiality of any information you share publicly or with friends. In addition, the Services may allow you to connect with us on, share on, and use third-party websites, applications, and services. Please be mindful of your personal privacy needs and the privacy needs of others as you choose to connect and share information with friends and others. We cannot control the privacy or security of information you choose to make public or share with others. We also do not control the privacy practices of third parties. Please contact those websites and services directly if you want to learn about their privacy practices.
HOW WE PROTECT YOUR INFORMATION
We have, and require our Third-Party Service Providers to have, administrative, technical, and physical safeguards in place in our respective physical facilities and in our respective computer systems, databases, and communications networks that are reasonably designed to protect information contained within such systems from loss, misuse, and alteration. The measures we use may include storing Personal Information on secured servers, transmitting Personal Information using encryption technologies, and auditing and reviewing our data collection and storage practices.
To be clear, we do not store your Payment Card account information, and we do not have control over or responsibility for your Payment Card account information. When you provide your Payment Card account information through the Website or the Application, it is stored and/or processed by our Third-Party Service Providers in order for you to use the Services. Our contracts with these third parties require them to have administrative, technical, and physical safeguards to protect the security and confidentiality of such information.
No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your Personal Information. You also play a role in protecting your Personal Information. Please safeguard your username and password for your Account and do not share them with others. If we receive instructions using your Account log-in information, we will consider that you have authorized the instructions. You agree to notify us immediately of any unauthorized use of your Account or any other breach of security related to the Services. We reserve the right, in our sole discretion, to refuse to provide the Services, terminate your Account, and to remove or edit content.
ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
LINKS TO THIRD-PARTY WEBSITES AND APPLICATIONS
SOCIAL SECURITY NUMBERS AND TAXPAYER IDENTIFICATION NUMBERS
In certain circumstances we are required to collect Social Security Numbers or Taxpayer Identification Numbers in connection with an individual’s participation. This information is required by law for governmental and tax purposes. It is our policy to protect the confidentiality of Social Security and Taxpayer Identification Numbers. We use these types of data to carry out our business needs and to comply with local, state and national governmental requirements including tax reporting, among other things. We do not use this information for identification purposes.
We have adopted administrative, technical and physical procedures to restrict access to this information to those employees or agents who need to use it for our business purposes and to protect it from unauthorized use, disclosure, access, or destruction. We may disclose this information to third parties, such as our service providers, who agree to protect this information and to keep it confidential and secure. We destroy, erase or render unreadable this type of information when disposing of our records. Our employees periodically undergo training regarding the safeguarding of Social Security and Taxpayer Identification Numbers.
Version 1.0 (effective January 27, 2017 to July 19, 2017)
Version 2.0 (effective July 20, 2017 to January 9, 2018)
Version 3.0 (effective January 10, 2018 to July 15, 2018)
Version 4.0 (effective July 16, 2018 to October 29, 2018)
Version 5.0 (effective October 30, 2018 to August 14, 2019)
Version 6.0 (effective August 15, 2019 to present)