Our Services are used by our current and potential clients ("Clients"), Users who sign up for AdFreeway Rewards Program("Users") and individuals who visit our Site ("Site Visitors").
By using our Site or App or otherwise using our Services, you acknowledge this Policy. If you do not agree with our Terms & Conditions, then you should immediately discontinue use of our Services without providing us any personally identifiable information.
Although our Services may be available via Affiliate (defined below) or other third-party Wi-Fi networks, we do not operate or own these networks.
To receive a copy of this Policy or convey any concerns about our handling of your Personal Information, please Contact Us.
3. What Personal Information Do We Collect?
As a rule, we limit the Personal Information we collect to that which is adequate, relevant and reasonably necessary for us to provide our Services to you. You are not required to provide any Personal Information to us to interact with our Site; however, if you do not provide your Personal Information, you may not be able to benefit fully from our Services. For example, if you do not provide your name and email address, we cannot create a member account and you will be unable to participate in the Rewards Program.
We collect Personal Information as follows:
A. How Do We Collect Personal Information?
We may collect your Personal Information relating to our Services including when you:
We may also collect Personal Information from third-parties including:
B. Information That You Provide to Us
The types of Personal Information we collect about you may include information you provide to us directly as follows:
For Site Visitors
C. Information Automatically Collected
Like many businesses, we and our service providers automatically collect and/or store certain information when Clients, Site Visitors and Users visit or interact with the Site, App or Services ("Usage Information"), including via cookies and other tracking technologies. This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device ("Device") whenever you visit or interact with our Services. (We call this information "Device Data.") Usage Information includes:
For more information, please see the "Device Data and Other Technologies" section below.
D. Information Collected from Third Parties
As a part of our business, we append Personal Information that we collect with information such as unique advertising identifiers from third party sources.
We do not have control over the information that is collected, used, and shared by these third parties. We encourage you to review the privacy statements of these third parties to understand their privacy practices.
E. Information We Infer About You
We also may draw certain inferences drawn from other Personal Information to create a profile about you reflecting your preferences or behavior as related to certain advertisements. This may also be considered Personal Information in some jurisdictions.
4. Device Data and Other Technologies
We may use digital technologies such as cookies, location services, web server logs and web beacons, ad optimization technology, machine learning and user profile algorithms in connection with the Rewards Program website, platform, social pages and other digital portals. A cookie is a small data file that a website may write to your hard drive when you visit it. A cookie file can contain information, such as a session ID which the website uses to track the pages you have visited. Other technologies we use include web beacons. We allow cookies and other digital technologies to be used:
Generally, the cookies we use fall into the following categories:
Our ad optimization technology relies upon information we collect (including Usage Information and Device Data) to curate the ads you receive to improve your online experience. Our platform may block, re-prioritize or substitute ads that you would have otherwise received based on your Voting Activity, Device Data, online activity, and other information we have collected about you.
The Rewards Program website may use cookie data to track user traffic patterns and to provide better service when you revisit our website.
Whenever a URL or ad is accessed via the Rewards Program platform, information is recorded such as the time, date, URL hash, ad and Voting Activity.
A. Third-Party Technologies
We believe in being transparent about how our Services work. As a part of our business model, we use the following third-party technologies:
As allowed by applicable law, by using our Services, you consent to the collection, use and disclosure of any Personal Information contained in the Device Data in accordance with these Terms and the interception of any communications (to the extent contained in the Device Data) to provide our Services including curating and improving your online experience with ad optimization technology.
If you do not wish for cookies to be installed on your device, you can change the settings on your browser or device to reject cookies. For more information about how to reject cookies using your internet browser settings please consult the "Help" section of your internet browser (or alternatively visit http://www.aboutcookies.org). Please note that, if you do set your Internet browser to reject cookies or otherwise withdraw your consent in relation to cookies, you may not be able to access all of the functions of the site.
5. Children's Information
We are committed to protecting the online privacy of children. We do not knowingly collect Personal Information from children under 16 or allow them to create an account. If you are the parent or guardian of a child under 16 who you believe has provided her or his information to us, please Contact Us to request the deletion of that information.
6. How Do We Protect Your Personal Information?
We maintain Personal Information in a combination of our secure online systems, paper-based files and other records, both at our own premises and with the assistance of service providers located in Australia and/or the United States.
In doing so, we take reasonable steps to protect your Personal Information from misuse, interference and loss, and unauthorized access, modification or disclosure. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your information as it is transmitted to us.
7. Retention of Personal Information
We will retain your Personal Information only for as long as is necessary for the purposes set out in this Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations, prevent fraud, resolve disputes and enforce our agreements and policies.
We utilize the following criteria to determine the length of time for which we retain Personal Information:
8. Why Do We Collect Your Personal Information?
We handle your Personal Information for the following purposes: providing, administering, improving and personalizing the Rewards Program, our products and services, and the products and services of other Redemption Partners. This can include registering you to participate in the Rewards Program; enabling you to access the Rewards Program platform; providing Rewards Program benefits; procuring ads and online content matching your interests and voting feedback; verifying your identity, communicating with you (including through direct marketing, where we are permitted to do so); understanding your interests and preferences to help us tailor our communications and offers to your needs; handling your queries and complaints; assessing the performance of the Rewards Program website and platforms and improving their operation; analyzing data; conducting surveys, market and product research; producing analytics to improve their advertising and marketing services; otherwise providing goods, services and benefits you have requested or are eligible to receive in connection with the Rewards Program; working with our service providers; and any other purposes which we have notified to you at the time of collection of the information, or to which you have provided consent.
We may also handle your Personal Information:
9. Direct Marketing Choices
Where we have your consent or are otherwise permitted by law to do so, we may also use and disclose your Personal Information to provide you with marketing communications and targeted advertising on an ongoing basis by sending electronic messages (such as email), through our Services and by other means.
These communications may relate to the products and services we, other Rewards Program participants (such as our Redemption Partners) and other group companies provide, promotions run by us or for which there is automatic entry for Rewards Program members, and other products or developments which may be of interest to you.
You may opt-out of receiving future electronic and telephone direct marketing communications through the unsubscribe function that will be made available to you with each direct marketing communication. Please Contact Us to understand the consequences of unsubscribing from email communications.
10. To Whom Do We Disclose Your Personal Information?
We may disclose your Personal Information to:
11. Do Not Track Disclosures
We respect your privacy, but we do not alter the information we collect or change our services upon receiving "do-not-track" signals, as the term appears in California and Delaware law. For more information about DNT signals, visit http://allaboutdnt.com.
12. Social Media Login
As noted above, if you register as a member by accessing or logging-in to an Affiliate network through a third-party social media service, the information we may collect and use are your user ID and/or user name associated with that social media service, any information or content you have permitted the third-party social media service to share with the Affiliate network or us, such as your profile picture, email address, followers or friends lists, and any information you have disclosed in connection with that social media service. When you log-in to access our Services through third-party social media services, we may collect, store, use and disclose such information and content in accordance with this Policy. If you do not want your Personal Information collected, stored, used or disclosed in this way, please do not log-in through a third-party social media service. We do not collect your passwords from these third-party social media services.
13. Australia Privacy Rights
As applicable, this Policy is subject to and does not limit the rights and/or exceptions available to us under the Australian Privacy Principles of the Privacy Act 1988 (Cth) (the "Privacy Act").
We disclose Personal Information, for some of the purposes described above, to organizations located in Australia and in other countries, including New Zealand, Brazil, European Union member states, the United States, United Kingdom, Israel and South Africa. We or our service providers may also make Personal Information held in Australia or the other countries listed above remotely available for processing by service provider personnel located in other countries, such as New Zealand, Brazil, European Union member states, United States, United Kingdom, Israel and South Africa. We take reasonable steps to ensure that overseas recipients of your Personal Information do not breach the privacy obligations relating to your Personal Information, and only use it for the purpose for which it was disclosed.
At your request, we will provide a copy of any Personal Information we hold about you, unless an exception under the Privacy Act applies. We may charge reasonable fees for retrieving this information, in which case we will obtain your prior consent.
When your Personal Information is no longer required, we take reasonable steps to destroy or permanently de-identify the information.
We will promptly acknowledge and investigate any complaint about the way we manage Personal Information.
We will take reasonable steps to remedy any issues resulting from our failure to comply with privacy obligations. If our response to you does not satisfactorily address your concerns, you may have the right to make a complaint to a competent regulator (e.g., Office of the Australian Information Commissioner at www.oaic.gov.au).
14. Brazil Privacy Rights
If you are located in the national territory of Brazil, you have certain additional data protection rights under the Lei Geral de Proteção de Dados ("LGPD"). These rights include:
A. Legal Basis for Processing Data Under the LGPD
Our legal bases for collecting or processing your Personal Information are as follows:
B. Duration of Processing
For more information about how long we retain your Personal Information, please see the "Retention of Personal Information" section above.
C. Exercising Your Rights Under the LGPD
If applicable, you may exercise any of your rights under the LGPD by submitting a verifiable data subject request to us by using the details in the Contact Us section below. You may make a request related to your Personal Information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of Brazil in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency to obtain the information. We will respond to your request within 15 days or let you know if we need additional time.
15. EU Privacy Rights
This section of the Policy applies if you are a data subject who resides or is located in the European Economic Area ("EEA"). We adopt this section to comply with European privacy laws, including the General Data Protection Regulation ("GDPR"). Any terms defined in the GDPR have the same meaning when used in this section.
Under applicable law, we are considered the "data controller" of the Personal Information collected on the Site. In other words, we are responsible for deciding how to collect, use and disclose this information, subject to applicable law. In other circumstances, we may be considered a "data processor" of Personal Information for Affiliates and Redemption Partners, and process the Personal Information at the direction of those parties.
We want to ensure that the Personal Information we possess is always accurate and therefore we encourage you to update your information in your own account in case any changes have occurred. We have listed below the rights that you may be able to exercise in respect of the processing of your Personal Information, subject to applicable law. We take reasonable steps to ensure that the Personal Information that we process is limited to the Personal Information that are required in connection with the purposes set out in this Policy.
If you are a resident of or located within the EEA, you have certain data protection rights. These rights include:
A. Legal Basis for Processing Personal Information
We will only process your Personal Information where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and use your Personal Information. In almost every case the legal basis will be one of the following:
We rely on the following legal bases for processing your Personal Information:
B. How to Exercise Your Rights Under the GDPR
If applicable, you may exercise any of your rights under the GDPR by submitting a verifiable data subject request to us by using the contact details below. You may make a request related to your Personal Information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of the EEA by including your country of citizenship or residence in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in the EEA to obtain the information. We will respond to your request within 30 days or let you know if we need additional time.
Please note that we will ask you to verify your identity before responding to such requests, and we may deny your request if we are unable to verify your identity or authority to make the request.
Should you wish to raise a concern about our use of your data (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority; however, we hope that we can assist with any queries or concerns you may have about our use of your Personal Information first by contacting us here.
16. UK Privacy Rights
If you are based in the United Kingdom, the following provisions also apply:
If we share your personal data within Company or with third parties located outside the United Kingdom, we take steps to ensure that appropriate safeguards are in place to guarantee the continued protection of your personal data, such as by entering into the international data transfer addendum to the European Commission's Standard Contractual Clauses, adopted by the UK Government under section 119A of the Data Protection Act 2018.
You have the same data subject rights as those for the EU listed above, except that references to the "GDPR" should be read as references to the "UK GDPR" and complaints should be filed with the UK supervisory authority, the Information Commissioner's Office.
17. California Privacy Rights
This section of the Policy applies solely to California residents. While we do not currently meet the thresholds for the applications of the California Consumer Privacy Act of 2018 ("CCPA") as amended by the California Privacy Rights Act ("CPRA"), we provide the information below as a courtesy to California residents. Any terms defined in the CCPA or CPRA have the same meaning when used in this Section.
California residents have the following rights:
A. Request for Information, Correction, or Deletion
California residents have the right to request, under certain circumstances, that a business that collects Personal Information about them disclose the information listed below for the preceding 12 months:
Please note that if we collected information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.
You can also request that we correct or delete your Personal Information. There may be certain exceptions to our obligation to correct or delete your information such as if you have an existing account or transaction with us or if we have a legitimate business reason to keep your information.
B. Personal Information Collected
The categories of Personal Information from consumers within the last twelve (12) months are identified above in the "What Personal Information Do We Collect?" section.
Information related to how long we retain each category of Personal Information is included in the Retention of Personal Information section above.
C. Personal Information Sold, Shared or Disclosed for a Business Purpose
We have provided your Personal Information to third parties in the last twelve (12) months as detailed in the "To Whom Do We Disclose Your Personal Information" section above.
We do not have actual knowledge that we sell or share the Personal Information of consumers under 16 years of age.
D. Do Not Sell My Personal Information
As a California resident, you also have the right, at any time, to tell a business operating under the CCPA not to sell Personal Information – this is called the "right to opt-out" of the sale of Personal Information. While we do not meet the threshold required for application of the CCPA, we have provided information about opting out in the "Device Data and Other Technologies" section above.
E. Right to Limit Use of Sensitive Personal Information
California residents have the right to limit the use of each type of Sensitive Personal Information for each purpose with each type of third-party partner. Please note that we do not collect any Sensitive Personal Information.
F. Right Not to Be Discriminated Against
We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by California law, we will not:
G. Notice of Financial Incentives
While our activities are not subject to the CCPA, we wanted to inform you about certain financial incentives and benefits you receive by joining our Rewards Program. The information that we collect for enrollment in the program (listed above) allows us to provide our Services. This, in turn, helps us establish a stronger relationship with you – something we value.
If you participate in our Rewards Program, there are two types of financial incentives you may receive:
In determining the value of your Personal Information to us, we consider, among other things, the length of your relationship with us, your Voting Activity, your engagement with advertisements shown to you on or off our platform, and your assistance in reporting suspicious or undesirable content.
Participation in our Rewards Program is voluntary and requires your prior opt-in consent, which you may revoke at any time. If you wish to leave the Rewards Program, please Contact Us.
H. Third Party Marketing
California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us a list of what Personal Information (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. We do not currently disclose Personal Information protected under this section to third parties for their own direct marketing purposes.
I. Exercising Your California Privacy Rights
If you or your authorized agent may make a request to access, correct, delete, opt-out of the sale of your Personal Information, or limit the use of your Sensitive Personal Information, please Contact Us.
If you use an authorized agent to submit your request, we may require proof of the written authorization you have given. We also may require you to confirm your identity and your residency to obtain the information, and you are only entitled to make this request twice in a 12-month period. For emails, please include "California Privacy Rights" as the subject line. You must include your full name, email address, and attest to the fact that you are a California resident. We will acknowledge your request within 10 days and respond to your request within 45 days or let you know if we need additional time. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.
18. Privacy Rights under Other US State Laws
While we do not currently meet the thresholds for the application of several US state privacy laws, we provide the information below as a courtesy to residents of those states. Based on the applicable law in the state where you live, you may have the following rights with respect to your Personal Information:
To exercise any of these rights, please Contact Us.
We may require you to confirm your identity and your residency in order to obtain the information, and you are only entitled to make this request up to twice annually. For emails, please include “Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a resident. We will process your request within 45 days or let you know if we need additional time or cannot process your request. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.
A. Right to Opt Out
You may have the right to opt out of the sale of your Personal Information and targeted advertising. We have provided information about opting out in the “Device Data and Other Technologies” section above, or you may Contact Us.
B. Opt-Out Preference Signals
Some browsers and browser extensions support opt-out preference signals such as the Global Privacy Control (“GPC”) that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales. GPC is a web browser-level setting, maintained by either a browser or a browser extension, that a user or privacy-focused technology can set. If required by applicable law, when we detect such a signal, we will make reasonable efforts to respect your choices.
C. Appeals of Our Decisions
In some jurisdictions, you may appeal to us if we refuse to take action on your exercise of certain choices described above. In order to appeal such a refusal, please contact us using the information in the Contact Us section below with the subject line “Appeal of Refusal to Take Action on Privacy Request” and provide the relevant information in the email.
If we decline to take action on any request you make, we will provide you with the information required by the applicable law where you live. This may include an explanation of why we declined your request, information on how to appeal our decision, and/or how to make a complaint to your state Attorney General.
19. Contact Us
If you have any questions about this Policy, wish to update information we hold about you or wish to make a complaint about our collection, use or disclosure of your Personal Information in connection with the Rewards Program, please Contact Us.