Coupgon Privacy Policy

Effective Date November 2, 2015

This privacy policy (“Policy”) describes the practices of Coupgon Inc. (“Coupgon”, “we”, “us”, “our”) with respect to our collection, use, storage and disclosure of personally identifiable information about you (“Personal Information”) and other information we gather in connection with your use of the websites, services, products, promotions, email, mobile applications, beacon technology, and software applications owned, managed or provided to you by us or on behalf of us by third parties (“Services”). This Policy also describes the information we collect, how we collect it, how we use it, share it and the choices available to you regarding our use of your Personal Information and how you can access and update this information.

By using the Services, you are consenting to our collection, use and disclosure of your Personal Information and other information we gather in accordance with this Policy.

INFORMATION WE COLLECT AND HOW WE USE IT

We collect Personal Information when you voluntarily provide it or use the Services. In connection with your use of the Services, we may collect and store information that you submit through the Services, as well as information about your use of and activities on the Services. This Policy does not apply to any unsolicited information that you provide, including, but is not limited to, information posted to any public areas of the Service and any unsolicited submissions. All unsolicited information is non-confidential and we are free to reproduce, disclose and distribute it without limitation or attribution. Among the Personal Information we collect, please note the following:

Your Account. If you create an account with us, we may collect and store your email address, telephone number, postal code, gender and your age. You can make changes to your account details at www.coupgon.com.

Your Activty. We may collect and store information about how you use the Services, such as the digital coupons viewed, clipped and/or redeemed, promotions which appear to be of interest to you, your searches, connections to online third party services such as Facebook or other social networks, the pages you visit from within our website or mobile application, the date and time of your access to the Services. You should review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our Services.

Location. To provide the Services and facilitate the redemption of coupons, beacons and/or other promotions made available through the Services, Coupgon needs to know your geographic location (e.g. latitude and/or longitude) or similar information regarding your location. For example, when you use the mobile application or our website, we may collect your location information, which will allow us to provide you with deals and information relevant to a particular geographic location. You may decline to provide location information at any time using your mobile device’s system settings, however you will likely be unable to use the Services. Please consult your mobile device’s instruction manual for additional information about controlling system and application settings.

Redemption Information. If you redeem a digital coupon or other promotion using your mobile device, we may collect and store information about that transaction such as the location, store, time and date of the related purchase. We may also be provided with a copy of your receipt or other transactional record information associated with that purchase.

Your Hardware. We may collect and store information about your mobile device or computer, including the type of device, web browser information and referring URLs, mobile carrier, phone number, IP address, Bluetooth connection, location data and compass information, unique device or account identifier.

Contest, Promotions or Surveys. From time to time, we may sponsor digital coupons, beacon notifications, contests, promotions, surveys or other types of sweepstakes. Personal Information may be required as a condition of participation for purposes of verifying entrants’ identities, notifying winners and fulfilling prizes. If we engage a third party to assist us in administering a promotion or fulfilling prizes, this information will be disclosed to that third party.

Emails and Notifications. If you create an account with us, you are agreeing to receive emails and electronic notifications from Coupgon. In using the Services, you are agreeing to opt-in for email (as part of the Canadian anti-spam legislation (“CASL”)) and/or electronic notifications. You can change your email preferences by clicking www.coupgon.com and your notification preferences on your mobile phone, but please note that you may opt-out of receiving commercial messages, but not others, such as important service messages or legal notices from Coupgon.

We use the information to fulfill your requests, verify your eligibility to redeem the digital coupon or other promotional offer, provide the functionality of the Services, improve the quality of the Services, personalize your experience, track usage of the Services, provide feedback to businesses that currently make or may, in the future, make promotional offers available through the Services, display relevant digital coupons, beacon notifications, advertising, provide customer support, communicate with you, create backups of our platform and Services, implement security on the Services and make security improvements, and comply with legal obligations. You are not obligated to provide your Personal Information, however we may not be able to provide you with access to the Services, or portions of the Services, without that Personal Information. To change your preferences you may contact us by one of the methods described under ‘Contact Us’.

COOKIES AND OTHER SIMILAR TECHNOLOGIES

We, and third parties with whom we partner, may use cookies, web beacons, pixel tags, log files, local shared objects (which may, on the web-coded portions of the Services, include “flash cookies”) barcodes and other technologies to collect certain information about users of the Services, digital coupons, beacon notifications, promotion redemptions and interactions with our applications, websites, emails and online advertisements. For example, through these means, we may collect your browser, device type and its operating system, viewed webpages, links that are clicked, IP address, sites visited before coming to our website, emails we send that you open, forward, or click through to our website. We may also track digital coupons, beacon notifications, promotion redemptions which are downloaded from third party websites, in connection with the Services. Collecting this information, and linking it with your Personal Information, helps us to best tailor the Services and enhance your experience by saving your preferences while you are using the Services, and to help identify products, site features, advertisements, and offers that may be of particular interest to you.

It may be possible to disable some cookies and similar technologies through settings on your device or Internet browser, for example to stop accepting new cookies, to receive notice when you receive a new cookie, to disable existing cookies, and to omit images (which will disable pixel tags). Note that the opt-out will apply only to the device or browser that you are using when you elect to opt out.

HOW COUPGON USES YOUR INFORMATION

We use any information you supply to deliver the Services you expected when you provided us the Personal Information. For example, when you provide your name and email address when you log in, we use this information to identify your account so you can use our Services. We may also use your Personal Information to help us improve the Services and to contact you regarding the Services. We may use your email address to email you about products and services that our clients or partners offer. Coupgon may use information that we collect from your use of the Services, any information you provide when you register with us, and information provided to us by third parties as follows:

Sharing and Third Parties. We may share your Personal Information or portions of your Personal Information with third parties with your prior consent to do so or as part of a specific program or feature in which you have chosen to participate, in which case we authorize those third parties to use your personally identifiable information in connection with the specific program or feature. For example, we may offer coupons that require you to fill out an advertiser survey in order to receive the coupon. If you choose to participate in the survey, then we will share the information you provide with the advertiser who provided the survey.

De-Identified Data. We may share aggregated and anonymous data (such as age, gender, postal code, province, coupon activation and redemption data, purchase data and other automatically collected information that does not personally identify you) which we learn about our users with third parties. These third parties may include advertisers, ad servers, data exchanges or other businesses interested in purchasing or licensing demographic information, as well as the retailers and suppliers that currently, or may in the future, offer or redeem promotions made through the Services. Some Services may be co-branded and offered in conjunction with another company. If you register for or use such services, both Coupgon and the other company may receive information collected in conjunction with the co-branded services.

External Links. The Services may contain links to unaffiliated third party websites. Except as discussed in this Policy, we do not share your Personal Information with them, and are not responsible for their privacy practices. Any information submitted by you to such a third party is subject to that third party’s privacy policy. Please review the privacy policies on these linked sites before sharing your Personal Information.

Facilitating Your Sharing. The Services may provide you with the opportunity to share your promotion redemptions, your cash savings statistics and other activities, as well as your Coupgon profile, through social media services like Facebook and Twitter. Note that the Personal Information you share on those platforms will be governed by the terms of use and privacy policies of those social media services.

Legal Process and Investigations. We may make disclosures or investigations involving your Personal Information if we have a reasonable belief that a disclosure to a third party or an investigation:

  • (i) is necessary for us to comply with legal process or instructions or orders from law enforcement, for example through our receipt of a search warrant, subpoena, judicial proceeding or other legal process;
  • (ii) is made to protect the reputation, rights or property of Coupgon and its affiliates, users of the Services, or members of the general public; or
  • (iii) is necessary to prevent or identify possible fraud or other wrongdoings involving the Services or to protect your safety or the safety of others.

Our Corporate Family. We may share Personal Information with our parent, subsidiaries, joint ventures and other organizations under joint or common control of Coupgon.

Business Transactions and Related Companies. If we are involved in a merger, acquisition, reorganization, or sale of all or a portion of our assets or shares. Personal Information may be part of the transferred assets during these types of events. We may also share Personal Information with our subsidiaries and affiliates.

Our Service Providers. We may provide your Personal Information to companies that provide services to help us with our business activities such as data hosting providers, payment processors or customer service agencies in Canada or outside of Canada. These companies are authorized to use your Personal Information only as necessary to provide these services to us, and in a manner consistent with this Policy.

YOUR CHOICES REGARDING ACCOUNT DATA AND ACCOUNT TERMINATION

You may delete your account by contacting us by one of the methods described under ‘Contact Us’. We will delete the account but we may retain your Personal Information for the purposes authorized under this Policy, unless you have changed your consent under this Privacy Policy or unless prohibited by law.

You can opt-out of email alerts and other emails by following the instructions included in our emails to you. Note that you are not permitted to unsubscribe or opt-out of non-promotional messages regarding your account, such as account verification, change or updates to features of the websites or mobile applications, or technical and security notices.

There may be instances where we may not be able to delete or provide you access to your Personal Information, for certain reasons. Among these are it has been destroyed or deleted after expiry of applicable retention periods, it contains Personal Information of other persons or it contains commercially sensitive or proprietary information owned by us. If we are unable to provide you access, we will explain why and document that for our records.

CHILDREN

We have no intention of collecting Personal Information from children under the age of thirteen (13). This website is not intended for children under the age of thirteen (13) and there is no reason to suspect that our website is designed in a manner that would attract such children. If you are under the age of thirteen (13), please do not provide Personal Information to us of any kind whatsoever. If a child provides us with Personal Information, a parent or guardian of that child may contact us to have this information deleted from our records.

DATA RETENTION

Personal Information will be retained only as long as necessary for the fulfillment of the purpose for which it was disclosed and for a reasonable time thereafter or for so long as we are required to maintain such information by law or other applicable rules or regulations (such as backup, archival, and/or audit purposes). We destroy your information when it is no longer needed or required to be kept, or we remove your personally identifiable information to render it anonymous. We may retain your information in aggregate or anonymized form indefinitely.

SECURITY AND TRANSFERS

We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is ever completely secure. Therefore, we encourage you to take special care in deciding what information you provide to us as we cannot guarantee its absolute security.

The Personal Information that you provide to us may be transferred outside of Canada for processing. We or our service providers may store Personal Information on servers located in other jurisdictions, including the United States. Please note that the privacy laws in such jurisdictions differ from Canadian privacy laws and that in some jurisdictions your Personal Information may be accessed by law enforcement authorities or the courts.

If you would like to obtain more information about Coupgon’s policies and practices with respect to the transfer and processing of Personal Information outside of Canada, please contact us in any of the ways described below under ‘Contact Us’.

CONTACT US

If you have any questions about this Policy or if you wish to view your Personal Information file, change or correct your information or have it deleted, you can contact our Privacy Officer at:

Coupgon Privacy Officer
Coupgon Inc.
1183 King Street West, Suite 200
Toronto, ON
M6K 3C5
E-mail: [email protected]
Phone: 1-888-289-4059

We are happy to answer your questions and we will use reasonable commercial efforts to address any concerns that you may have.

UPDATES TO THIS PRIVACY POLICY

We may change or update portions of this Policy at any time. Please check back from time to time so you are aware of any changes or updates to the Policy. If we make material changes to the Policy we will notify you by email or post a notice on the Services prior to the effective date of the changes. We will indicate the Policy’s effective date at the top of this Policy. If you continue to access or use the Services after the changes are effective, you agree to be bound by the revised Policy.

LANGUAGE

This Policy shall be interpreted consistent with its English linguistic construction, and all communications between the parties shall be deemed to be conducted in the English language. Les parties aux présentes confirment leur volonté que cette convention soit rédigée en langue anglaise seulement.