Notice to Collinson CLO, Inc. Customers and Users signed up as of 28th March 2018.
- How the Collinson Services Work
- Information Collinson Collects
- How Collinson Uses Your Information
- When and with Whom Collinson Shares Your Information
- Transaction Monitoring
- Reviewing and Updating Your Information
- Protecting Your Information
- Electronic Communications
- Protecting Children’s Privacy
- Your California Privacy Rights; California Do Not Track Disclosures
- Stopping Use of Information
- Links to Other Websites
- Contact Us
1. How the Collinson Platform Works
The Collinson platform is the underlying technology that implements Offers that reward consumers with loyalty points or cash back rebates (e.g., credits to a registered Payment Card) for shopping at specific retailers or purchasing specific products (collectively, “Offers” and each, an “Offer”). As used herein, “Payment Card” means your debit or credit card that you register with Collinson. There are two types of Offers that are or may be supported by the Collinson platform, as more specifically set forth in our Terms of Service: (a) “Card Linked Offers”, which are Offers that reward you with cash back rebates when you shop at specific retailers or purchase specific products, and for which Collinson tracks your purchases automatically when you use your registered Payment Card, and (b) “Loyalty Program Offers” which provide loyalty points for a particular loyalty program (“Loyalty Program”) when you shop at specific retailers or purchase specific products, and for which Collinson tracks your purchases automatically when you use your registered Payment Card. When you sign up with the Collinson platform and register your Payment Card, you will be able to participate in all types of the above Offers as you choose when they are available.
Card Linked Offers and Loyalty Program Offers
Once you sign up with Collinson and register your Payment Card, where Card Linked Offers and/or Loyalty Program Offers are not automatically linked to your Payment Card, you may select one or more Card Linked Offer(s) and/or a Loyalty Program Offer(s) when available. When you select such Offers, Collinson will detect that you are registered with the Collinson Network and ask if you want to register for such Offer using the same card on file. If you agree, then Collinson will link your registered Payment Card to such Offers. This will allow you to shop at participating retailers and automatically earn towards your cash back rebate or earn loyalty points for doing so.
For the Card Linked Offers and Loyalty Program Offers you have selected, Collinson will share your Payment Card information and the pertinent terms of your selected Offer(s) with financial institutions or Payment Card networks that process your Payment Card transactions and/or other third parties aggregating Payment Card data and/or processing cash back rebates (“Payment Card Networks”). Collinson shares Payment Card information with Payment Card Networks via a PCI-compliant encrypted method as specified by the applicable Payment Card Network(s).
2. Information Collinson Collects
A. Information that you provide to Collinson
Collinson collects from you personal information (information that can be used to identify you as an individual) such as ZIP code, phone number, name, email and/or payment information (such as account or Payment Card number and expiration date) when you register for the Services. Collinson may also collect from you details of your transactions when you use your registered Payment Card at a participating retailer.
When you use the Services, Collinson may provide you with the option to supply us with additional demographic information such as your age, gender, and zip code. Collinson ties this demographic information to the personal information you submit to Collinson. Collinson does this to provide you with other Offers that may be relevant to you.
B. Information Collinson Automatically Collects
When you use the Site or open one of Collinson’s emails, Collinson automatically records information about you using automated tracking technology such as clear gifs or web beacons, cookies, and IP addresses. These terms are described in more detail below.
Collinson automatically collects the following information:
- Offers you link to in your account
- Offers you redeem
- web browser type
- the website that referred you to Collinson
- the web pages you viewed on the Site
- the dates and times you visited the Site
- your response to messages the Service sends
If you would like to opt-out of these emails, please see Electronic Communications below.
As is true of most Web sites, Collinson uses a third party tracking service to gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.
Collinson uses this information that Collinson automatically collects, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about Collinson’s user base as a whole.
C. Direct Communications With Collinson
When you send email or other communications to Collinson, Collinson may retain those communications in order to process your inquiries, respond to your requests and improve the Services or Site.
D. Social Media Widgets
E. Information about you provided to Collinson by Payment Card Networks and Retailers
For Card Linked Offers and Loyalty Program Offers, Collinson also collects details of your transactions from the applicable Payment Card Network(s) (“Purchase Data”) and/or from participating retailers (“Retailer SKU Data”) when you use your registered Payment Card at a participating retailer in order for Collinson to process the cash back rebate or loyalty points information necessary to process your redemption of the Offer. Purchase Data and Retailer SKU Data is sent to us with a unique identifier such as user token along with the details of your transaction.
F. Information about you provided by Loyalty Providers
Collinson Networks powers third party-branded Loyalty Programs that distribute and implement their own and/or third party Loyalty Programs (“Loyalty Providers”). If you choose to join the Loyalty Program of, or distributed by, a Loyalty Provider, any information that you provide to such Loyalty Provider may be shared with Collinson Networks to the extent necessary to implement your participation in such Loyalty Program.
3. How Collinson Uses Your Information
A. Collinson may use your personal and other information for any of the following purposes:
- to provide the Services to you, including the display of personalized content, opportunities for savings and new offers sent by email or SMS message, and advertising;
- to help address problems with and the functioning of the Site and the Services;
- to monitor and conduct internal reviews of the Site and the Services;
- to help Collinson better understand and improve the use of the Site and the Services, and to develop new services;
- to protect the security and integrity of the Site and the Services; and
- to contact you, if necessary, or at your request.
B. Specific Uses of Data
- Collinson will use your Purchase Data or Retailer SKU Data to confirm a qualifying purchase or return in order to match transactions to confirm whether you qualify for redemption of an Offer.
- Collinson may use your Purchase Data or Retailer SKU Data to identify other Offers that you may be interested in that are part of a Collinson program, including by creating a profile of your transactions and interests, and sending you such Offers by text or email.
- As set forth in Section 5 (When and with whom Collinson shares your information), Collinson shares your personal information with business partners to help them understand the performance of their Offers and to confirm redemptions and with other third parties as set forth in Section 5.
4. When and with Whom Collinson Shares Your Information
A. Collinson may share aggregated, non-personal information with Collinson’s related companies, consultants, advertising clients, Sponsors and their advertising agencies, service providers, advertising agencies and other third parties for various purposes, such as delivering and improving the Services and for Site analytics and performance reporting. As used herein, “Sponsor”means a manufacturer, retailer or other entity making an Offer.
B. Collinson may share your personal information in Collinson’s possession with other parties under the following circumstances:
- Service Providers. To service providers to enable such service providers to enable Collinson to provide the Services to you, including but not limited to: (a) providing Collinson with your Purchase Data, (b) delivering Offer redemptions and savings to your Payment Card(s), Account and loyalty accounts, and/or (c) collecting your feedback and administering technical support to provide customer support to you. These companies work with Collinson under confidentiality agreements and are prohibited from making any other use or disclosure of your personal information (unless they otherwise independently possess or have lawful access to such information).
- Payment Card Networks. Collinson share your Payment Card number and expiration date with Payment Card Networks via a PCI-compliant encrypted method as specified by the Payment Card Networks in order for such Payment Card Networks to track your transactions at participating retailers and to return Purchase Data to Collinson.
- Purchase Data. Except as provided above, Personal information combined with your Purchase Data will not be disclosed to any third party.
- Retailer SKU Data. Except as otherwise provided in this Section 5.B, personal information combined with or included in your Retailer SKU Data will not be disclosed to any third party.
- Email. If you authorize Collinson to disclose your email address to a Sponsor of an Offer, once you redeem such Offer, Collinson may disclose (a) your email address and your Purchase Data (or portions thereof) with such Sponsor, but these will be provided to such Sponsor separately and not in a combined form, and/or (b) your email address and your Retailer SKU Data (or portions thereof) with such Sponsor, but these may be provided to such Sponsor together or in a combined form, but these may be provided to such Sponsor separately, together or in a combined form. Collinson shares such email address with Sponsors for the purposes of such Sponsors verifying the redemption of their Offers, verifying your purchase of their products, goods and/or services and/or to assess the performance of their Offers. You may provide Collinson such authorization by accepting the terms of an Offer containing such authorization.
- To applicable third parties, if Collinson has reason to believe that such disclosure is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference (either intentionally or unintentionally) with Collinson’s rights or property, other users of the Services or anyone else that could be harmed by such activities.
- In certain situations, Collinson may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
- Collinson and/or its Payment Card Networks may provide your personal information, Purchase Data and Retailer SKU Data , in response to a request from a government authority or a payment organization involved in a transaction with you or a retailer.
- In the event Collinson files for bankruptcy and another party purchases Collinson or assets in whole or part or Collinson is purchased or merged into another entity.
C. You are responsible for reviewing the Offer’s terms before accepting or linking any Offer to your Payment Card.
By registering a Payment Card in connection with transaction monitoring, you authorize Collinson to share your Payment Card information with the applicable payment network(s) (such as MasterCard, VISA, and American Express) so they know you enrolled. You authorize the applicable Payment Card Network(s) and Collinson to monitor transactions on your registered Payment Card(s) to identify qualifying purchases in order to determine whether you have qualified for or earned an Offer linked to your Payment Card, and for the above Payment Card Networks to share such transaction details with Collinson to enable your Offer(s). You may opt-out of transaction monitoring on specific Payment Card(s) you have registered by deleting your card from within the applicable Loyalty Program.
Upon request Collinson will provide you with information about whether Collinson holds any of your personal information. You may view and modify all your information within yourapplicable Loyalty Program. Collinson encourages you to promptly update or delete your information if it changes. Additionally, you may file a request for Collinson to make updates to your information via the feedback form that is integrated within the Site or by emailing us at PLRSupport@collinsongroup.com. Collinson will respond to your request within a reasonable timeframe, not more than forty-five (45) working days. Please indicate what information you would like to update or delete when you contact Collinson.
Collinson takes security seriously and take numerous precautions that are intended to protect the security of your information. Collinson follows generally accepted industry standards to protect the personal information submitted to Collinson, both during transmission and once Collinson receives it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, Collinson cannot guarantee it is absolute security. Collinson encrypts the transmission of information using secure transport layer security (TLS).
Collinson may send you Administrative Communications and Promotional Communications on its own behalf and on behalf of our affiliates, and on behalf of Loyalty Providers and Sponsors. “Administrative Communications” are emails and/or SMS messages related to your activity , and include messages regarding your account, requests or inquiries.
“Promotional Communications” are emails and/or SMS messages that advertise our products and services, including exclusive Offers, and/or the products and services of our affiliates, Sponsors and Loyalty Providers.
You can opt-out of such electronic communications by replying “STOP” to SMS messaging from Collinson, by clicking “unsubscribe” on emails.
Protecting the privacy of children is especially important to Collinson. The Services are not directed to or intended for use by children under the age of 18. As such, Collinson does not knowingly or intentionally collect personal information from children under 18 on the Site. If you believe Collinson has inadvertently collected information from a child under 18, please contact Collinson using the contact information listed herein.
If you are a resident of the State of California, under California Civil Code sections 1798.83-1798.84, you have the right to ask Collinson for a notice identifying the categories of personal information that Collinson share with our affiliates and/or third parties for direct marketing purposes. Since Collinson do not share personal information with affiliates or third parties for direct marketing purposes, Collinson is exempt from this requirement. Collinson currently does honor Do Not Track signals.
If you wish to request that Collinson no longer use your information to provide you Services, you may contact us at PLRSupport@collinsongroup.com. Collinson will retain and use your information as necessary to comply with any legal obligations, resolve disputes, and enforce any agreements.
The Site includes links to other Web sites whose privacy practices may differ from those of Collinson. If you submit personal information to any of those sites, your information is governed by their privacy statements. Collinson encourages you to carefully read the privacy statement of any Web site you visit.
14. Contact Us
Collinson CLO, Inc.
Attn: Privacy Officer
50 Federal Street, 7th Floor
Boston, MA 02110