Personal Information We Collect
Generally, we collect Personal Information when you provide it to us by visiting the Bright Bucks Sites and Features and/or using our Services. This may include registering for any account with us, filling out surveys, participating in our Card Linked Offer Programs, joining a mailing list, uploading receipts, corresponding with us, entering one of our sweepstakes or contests, choosing to submit testimonials, stories, photos or the like, or otherwise volunteering or providing information about yourself.
We use your Personal Information and other information we collect about you in order to (i) provide you with our Services, (ii) to improve the Bright Bucks Sites and Features, (iii) to provide advertising, content, surveys, location-based deals, special offers, promotions and rewards (collectively “Offers”), and (iv) for other marketing, administrative and operational purposes (collectively, our “Business Purposes”). The information we collect may be used by itself, aggregated, or combined with unique identifiers (such as Bright Bucks-assigned identifiers, Device IDs, etc), and shared with (x) our parent companies, subsidiaries, trusted agents and affiliated Services that we own and/or operate (“Affiliates”) and (y) our vendors, advertisers, merchants, survey partners, joint business ventures and other trusted service providers (collectively, “Trusted Service Providers”), for purposes related to our business, including, without limitation, advertising, attribution, measurement of campaigns, analytics and research. If you don’t provide us with your Personal Information, we will generally be unable to provide you with our Services and you will be unable to use the Bright Bucks Sites and Features. You can opt-out of data collection by changing the settings on your Device or by Contacting Us (but key services and features may lose functionality as a result).
Other User Information We Collect
In addition to the information referenced above, we also collect other information when you visit the Bright Bucks Sites and Features, use our Services, or when we conduct business transactions with our Affiliates and Trusted Service Providers. In some jurisdictions, this information may be considered personally identifiable. We collect this information to provide you with personalized Offers when reasonably possible and available and to improve the overall quality of your experience with the Bright Bucks Sites and Features and our Services. For example, we collect or may collect your IP address, Device ID, referrer data, and browser and platform type. You do not have to register on any of our Services before we can collect this information. We may assign a unique identification number to your activity and/or registration and link additional data to that number, such as the date and time you visited, the information you provide, and the links you choose to click. Like most standard website servers, we use log files to collect and store this user information. We may analyze and use this information for a variety of purposes, including operating and improving the Bright Bucks Sites and Features or our Services, collecting further information about and learning from user behavior and trends, measuring the effectiveness of our, our Affiliates and our Trusted Service Provider’s marketing campaigns, and gathering demographic information. Furthermore, we may combine or link information we collect from or about you offline with information we collect from or about you online through the Bright Bucks Sites and Features or your use of our Services.
You may choose to install and use optional Internet browser extensions, add-ons or similar plug-in software and technologies (the “Extensions”) which may collect and use your information in a variety of ways. Extensions allow you to shop directly with our merchant partners and earn rewards. The Extensions also provide other features and access to Offers which may include cash-back offers to take surveys, watch videos, complete tasks, monitor your earnings, customize your account information and other activities. If you install an Extension, we will automatically track the websites you visit to allow us to offer you the aforementioned features and to correlate your browser history, merchant visits and Bright Bucks Sites and Features engagements to provide better services and Offers to you.
To assist in rewarding you for purchases made through our shopping-rewards features, third-party affiliate or Ad Network cookies (as defined below) may be placed on your Device when you install and use an Extension or when you click on an affiliate or Ad Network link within a shopping-rewards feature. Your browsing activity on our merchant partners’ websites (and other websites you visit) will be tracked by cookies, Extensions or other Bright Bucks Sites and Features having such tracking capabilities. This information may be shared with our Trusted Service Providers in order to provide you with Offers and for our Business Purposes.
We may also use GPS or similar geo-location technology to determine the geo-coordinates of where you or your Device are located. As noted in the section on “Sharing” below, we may use and share your location information with our Trusted Service Providers in order to provide you with Offers and for Business Purposes, based on your location. In addition, our mobile applications may collect, among other things, certain information automatically, including, but not limited to the type of mobile Device you use, your mobile Device’s unique Device identifier (UDID), the IP address of your mobile Device, your mobile operating system, the type of mobile Internet browsers you use, and information about the way you use the mobile application.
Information We Receive from Third Parties
We may also receive and supplement the information we directly collect from or about you with information from third parties, such as our Trusted Service Providers. If you are on a third party website or service and you opt-in to receive information from us, the third party may forward to us your email address and other information about you so that we may contact you as requested. In addition, we may receive information from our Trusted Service Providers, including, without limitation, advertisers, merchant and/or survey partners to ensure that you properly receive any earned rewards and/or for the Business Purposes. We may also supplement and combine the information we collect about you with outside records from third parties in order to enhance our ability to provide you with Offers and for Business Purposes.
We may provide you with an opportunity to invite your friends, family and acquaintances (“Friends”) to use various Bright Bucks Sites and Features. If you elect to use our referral service for informing a Friend about any of the Bright Bucks Sites and Features, you will provide us with your Friend’s name and email address. Using our referral service permits us to automatically send the Friend one or more emails or other communications, on your behalf, inviting them to visit or register for the Bright Bucks Sites and Features (which invite may include additional subsequent reminders and communications). You warrant and represent that you have your Friend’s consent to provide us with his or her information for this purpose, and that you will not give us referral information for any person not permitted to use the Bright Bucks Sites and Features, including, without limitation a child under the age of 13, a person whose account has previously been suspended or deactivated, a person who unsubscribed from receiving communication from the applicable Bright Bucks Service, or a person residing or located in a territory where use of the Bright Bucks Sites and Features is not authorized.
Community Features and User Content
Advertising Networks and Analytics Companies
Cookies and Tracking Technologies
We also use Flash cookies, which are data files placed on a Device via the Adobe Flash plug-in (or other compatible Flash plugin) that may be built-in to the Bright Bucks Sites and Features or downloaded by you. Flash cookies may be used for various purposes, including, without limitation, enabling a Flash feature and remembering your preferences. We do not use Flash cookies or locally-shared objects in connection with Bright Bucks’ own ad effectiveness research activities.
Most web browsers automatically accept cookies, but you can usually configure your browser to prevent this. To learn more about interest-based advertising in general, to opt-out of certain cookies and for more information about cookies, you may visit optout.aboutads.info.
If you’d like to opt out of being tracked by Google Analytics, you may be able to do so through Google’s website. Not accepting cookies (or opting out of cookies), installing ad blocking technologies and/or and disabling analytics providers may make certain features of the Bright Bucks Sites and Features and our Services unavailable to you and may affect our ability to validate whether or not you earned a reward by successfully completing an Offer or action. For more information about Flash and the privacy choices Adobe offers, visit http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html.
Note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. Like many websites and online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a user’s browser. To find out more about “Do Not Track,” you may wish to visit http://www.allaboutdnt.com.
Card Linked Offers Program
The Bright Bucks Sites and Features may offer a service enabling you to enroll a qualifying payment card in order to earn rewards or benefits when you make qualifying transactions with participating merchants (“CLO Program”). Your participation in a CLO Program is further guided by the “Card Linked Offer Service Terms”. If you participate in a CLO Program and provide your Payment Information for that purpose, the Company and its Trusted Service Providers (including, without limitation, Braintree Payments, a division of PayPal, Inc., Visa Commerce Solutions, Inc., Rakuten Card Linked Offer Network, Inc., Groupon Inc., and MOGL Loyalty Services, Inc.) will have the right to use the transaction information generated in such CLO Program (“Transaction Data”) for the purposes of operating the CLO Program, including, without limitation, the following purposes: (a) Using Transaction Data to confirm a Qualifying Purchase or return to match transactions to confirm whether you qualify for an Offer, cash-back or points; (b) Sharing Transaction Data with the participating merchant where a transaction occurred as needed for the merchant to confirm a specific transaction occurred or cashback / points should be awarded (for example, the date and amount of your purchase and the last 4 digits of your card number so the merchant can verify your purchase if there is a missing or disputed transaction); (c) Providing participating merchants or Trusted Service Providers aggregated and anonymized data relating to Payment Information activity to allow participating merchants and the Trusted Service Providers to assess the results of their campaign and analyze ways to improve or optimize a CLO Program and its Offers; (d) Creating a record of the Transaction Data and thereafter maintain and use such record and Transaction Data in connection with operating the CLO Program; and (e) Providing information in response to a request from a government authority or a payment organization involved in a transaction with you, a merchant, a relevant Trusted Service Provider, or others. By participating in a CLO Program, you authorize the sharing, exchange, and use of Transaction Data described above and herein by and among the Company and its Trusted Service Providers, applicable payment card networks and participating merchants. Please visit the Card Linked Offer Service Terms to learn more about the data collection, use, and sharing practices related to the CLO Program. If you would like to opt out of card linking and transaction monitoring in connection with a CLO Program, please visit the card linking section of the applicable Service and remove any payment cards that you no longer wish to be associated with the CLO Program.
We may also share your Personal Information with our Affiliates for our Business Purposes, and with Trusted Service Providers in connection with their performance of services to, or on behalf of, the Bright Bucks Sites and Features or our Services (and vice versa). Such services include, for example, customer support, collecting and analyzing information about usage of the Bright Bucks Sites and Features or our Services, delivering (and confirming the successful delivery of) Offers to you on the Bright Bucks Sites and Features (or elsewhere online), processing payments, operating a CLO Program, analyzing receipt data, verifying activity, and performing our other Business Purposes. In addition, if you use our mobile applications, we may share your current location with our Affiliates and Trusted Service Providers for Business Purposes and so that we or they may provide you with Offers based on your location, including, without limitation, attribution, analytics and research. Please see the section on “Updating Your Information; Choice/Opt-Out” below for information about how you can opt out of such sharing.
We may share or sell aggregate or individualized information about you that may include, without limitation, (1) your personal information, (2) your use of the Bright Bucks Sites and Features and our Services, (3) websites you visit, and (4) your location and information derived therefrom which we believe reflects your interests. We share this information with Trusted Service Providers for the purpose of providing you with Offers and for Business Purposes. Additionally, such sharing of information is made with service providers in connection with anticipated, ongoing, completed or disputed transactions relating to you or your activity on the Bright Bucks Sites and Features. For a sample list of Trusted Service Providers and their respective privacy policies, please visit: https://www.Bright Bucks.com/trustedpartners/.
In the event the Company (or any of its Affiliates) goes through a business transition, such as a merger, consolidation, restructuring, acquisition by another company, sale or assignment of rights or assets (or a portion thereof), or other company change, we may transfer users’ information, including Personal Information, and other business data in connection with that business transition (e.g., to a subsequent owner, co-owner, or operator of any of the Bright Bucks Sites and Features, or any affiliates and trusted agents, service providers, or partners of the foregoing), including during the course of any due diligence process.
Updating Your Information; Choice/Opt-out
You may remove or disable cookies as described above in the section on “Cookies and Tracking Technologies” and you may clear your browser history in accordance with the system settings of your web browser. Certain advertising networks and exchanges may participate in the Digital Advertising Alliance (“DAA”) AdChoices Program and may display an Advertising Option Icon for interest-based ads. You can learn more about the DAA AdChoices Program here: http://www.youradchoices.com. In addition, certain advertising networks and exchanges may participate in the Network Advertising Initiative (NAI). The NAI has developed a tool that allows consumers to opt out of targeted advertising delivered by NAI members’ Ad Networks. To learn more about opting out of targeted advertising or to use the tool, click here: http://www.networkadvertising.org/choices.
Notification of Changes
The Bright Bucks Sites and Features and our Services are for general audiences and we do not knowingly collect any Personal Information from children younger than the age of 13. If you are under 18, you should use the Bright Bucks Sites and Features and our Services only with the permission and guidance of your parent or guardian. If you are under 13, you should not submit any Personal Information to us. If we learn that we have inadvertently collected Personal Information from a child younger than 13, we will take commercially reasonable efforts to delete such Personal Information from our databases. If a California resident is known to us to be between 13 and 15 years of age, we will promptly request that such consumer provide their expressed opt-in consent to the sale of their Personal Information in order to continue to use the Bright Bucks Sites and Features, in accordance with the CCPA and applicable regulations thereunder.
We maintain industry-standard security measures to help protect against the loss, misuse and alteration of the Personal Information under our control. Please be advised, however, that the Internet and other technologies and communication channels are, by their nature, not perfectly secure, and your information may therefore be subject to interception or loss which is beyond our reasonable control. While we strive to protect your Personal Information, we cannot ensure or warrant the security of any Personal Information you transmit to us, and any transmission is done at your own risk. Accordingly, we assume no responsibility or liability for disclosure of your Personal Information or other information due to errors in transmission, unauthorized third-party access or other causes beyond our reasonable control.
Location of Processing and Applicable Law
Your California Privacy Rights (FOR CALIFORNIA RESIDENTS ONLY)
As of January 1, 2020, California residents also have the following rights provided to them under the California Consumer Privacy Act of 2018, Civil Code §1798.100 et seq. (CCPA):
(1) Once per calendar year California residents may request that the business provide a list of companies with which it shares such Personal Information for the third parties’ or affiliates’ direct marketing purposes, and a list of the categories of such Personal Information that the business shares. California residents may request further information about our compliance with this law by emailing CaliforniaPrivacy@BrightBucks.com. Please include “California Privacy Rights Request” in the first line of the description and your California mailing or street address. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this e-mail address nor requests made by non-California residents.
(2) Right to Request Deletion of Personal Information. California residents also have the right to request the deletion of their Personal Information collected or maintained by Bright Bucks, subject to certain exceptions and limitations.
(3) Right to Opt-Out of the Sale of Personal Information. California residents have the right to opt-out of the sale of their Personal Information. Under the CCPA, the “sale” of Personal Information broadly includes any communication of Personal Information to any business that is deemed to be a “third party” (as defined in the CCPA) for monetary or other valuable consideration, subject to certain exceptions and limitations. For more information, please consult our Notice of Right to Opt Out of the Sale of Info (https://www.Bright Bucks.com/do-not-sell/).
(4) Authorized Agent. California residents may use an authorized agent to exercise certain privacy-related requests and rights on their behalf. The authorized agent’s exercise or request on your behalf sent by mail shall include a power of attorney or a notarized statement properly signed by you appointing such authorized agent for such purpose. If your authorized agent submits the exercise or request online via the link below, a copy of the power of attorney or the original notarized statement shall be mailed to the following address: Bright Bucks, Inc. 17503 La Cantera Parkway Suite 104-285, San Antonio, TX 78257; Attention: Privacy, within five (5) days after submitting such online request, or we may in our discretion otherwise verify the agent’s authority to our reasonable satisfaction.
(5) Notice of Financial Incentive. California residents have the right to receive notice of financial incentives provided to them by a business. Please consult our Notice of Financial Incentive (https://www.Bright Bucks.com/financial-incentives-notice/) which provides information regarding financial incentives or “price or service differences” that Bright Bucks may provide in exchange for your Personal Information.
(6) Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights. California residents have a right not to receive discriminatory treatment by a business in the event that the California resident exercises one or more of their privacy rights conferred by the CCPA.
(7) How to Submit Your Request. Bright Bucks offers California consumers (or their authorized agent) two (2) ways to submit requests concerning their California privacy rights under the CCPA: (i) by completing the online form located here: http://Bright Bucks.com/PrivacyRequests or (b) by mailing your request to the following address: Bright Bucks, Inc. 17503 La Cantera Parkway Suite 104-285, San Antonio, TX 78257; Attention: Privacy. Bright Bucks will review all properly-submitted requests and respond in a timely manner in accordance with the CCPA and applicable regulations thereunder. As part of this process, and to prevent unauthorized use of your Personal Information, you may be asked to verify your identity so that we can match you to a person in our systems. The verification methods we use may include requests to disclose your first name, last name, email address, location information, security question, Service activity and other information; such verification may be conducted by a third-party on our behalf. TO ENSURE THAT YOUR CCPA REQUESTS ARE EFFECTIVE AND RESPONDED TO IN A TIMELY MANNER, YOU MUST USE THE WEBFORM OR MAILING ADDRESS SPECIFIED IN THIS SECTION. PRIVACY REQUESTS SENT TO US BY ANY OTHER METHOD OF COMMUNICATION WILL NOT BE VALID AND MAY NOT BE RECEIVED BY OUR PERSONNEL AS WE CANNOT MONITOR ALL CHANNELS OF COMMUNICATION NOR CAN WE VERIFY THE AUTHENTICITY OF PRIVACY REQUESTS SENT VIA ANY OTHER CHANNELS.
(8) Publication of CCPA Statistical Data. Starting January 1, 2021, and updated each year thereafter (if and as required by the CCPA), Bright Bucks will publish a summary of statistical data pertaining to the following categories of California-resident consumer privacy requests: (1) “Requests to Know”, (2) “Requests to Delete”, and (3) “Requests to Opt-Out of Sale” in our Notice of Collation of Info (https://www.Bright Bucks.com/collection-notice/). The statistical data Bright Bucks will publish will include: (A) the number of requests Bright Bucks received in each category of California-resident consumer privacy request, (B) the number of such requests that Bright Bucks complied with in (in whole or in part), (C) the number of such requests which Bright Bucks denied and (D) the median number of days within which such requests were responded to.
Contact Us; Questions and Feedback
Bright Bucks, Inc.
17503 La Cantera Parkway Suite 104-285
San Antonio, TX 78257