Privacy Policy

Bright Bucks Privacy Policy

This Privacy Policy is intended to cover residents and persons located within the United States and Canada. We are concerned about your privacy and want you to be familiar with how we collect, use and share your Personal Information (as defined below). This Privacy Policy outlines the type of information that we collect and receive from and about you. Additionally, this Privacy Policy identifies the ways in which we process, and sometimes share, such information and what control and choices you have with regard to the collection and use of your Personal Information. Please review this Privacy Policy carefully, especially before providing any Personal Information through the Bright Bucks Sites and Features. Our Bright Bucks Sites and Features are operated in and controlled from the United States of America unless otherwise stated. IF YOU DO NOT WISH TO HAVE US COLLECT, USE AND SHARE INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE THE BRIGHT BUCKS SITES AND FEATURES OR OUR SERVICES.

Bright Bucks, Inc. and its Affiliates (collectively, “Company” or “Bright Bucks”) owns and operates a number of different services (collectively, the “Bright Bucks Sites”). This privacy policy (“Privacy Policy”) applies to the Bright Bucks Sites and to all of the features, websites, mobile applications, Internet browser extensions, emails, online services and other functionalities (collectively, the “Features”) available via or related to the Bright Bucks Sites, whether accessed via a computer, mobile device, or otherwise (collectively, the “Bright Bucks Sites and Features”) and the services available on or through the Bright Bucks Sites and Features (collectively, the “Services”). This Privacy Policy only covers information collected by the Company through the Bright Bucks Sites and Features and our Services, and does not cover any information received or collected offline by the Company (unless specifically stated) or collected by any unrelated websites or companies to which we may provide links. By using any of the Bright Bucks Sites and Features or our Services, and/or clicking to “Accept” or otherwise acknowledging or consenting to this Privacy Policy where that option is made available to you, you agree to be bound by this Privacy Policy, as well as our Terms of Use; “Terms” or “Terms of Use”) . If you do not agree to this Privacy Policy or our Terms, please do not use any Bright Bucks Sites or Features or our Services. Please contact us with any questions regarding this Privacy Policy and our privacy practices. Instructions to contact us can be found in the “Contact Us” section of this Privacy Policy (below).

Personal Information We Collect

When you visit or use any of the Bright Bucks Sites and Features or our Services, you may share and/or we may automatically collect information that identifies you personally. In this Privacy Policy, “Personal Information” refers to any information that can reasonably be used to identify, contact or locate you. Examples of Personal Information may include, without limitation, your name, your precise location, your credit card number, your email address, your mailing address, and your phone number. If you are a California resident, Personal Information may also include other information about or relating to you, such as Device IDs and uniquely assigned alpha-numeric identifiers, as provided in the California Consumer Privacy Act of 2018, Civil Code §1798.100 et seq. (CCPA) and applicable regulations thereunder. Personal Information may be collected on, through or in connection with any of the Bright Bucks Sites and Features and/or our Services. If you are a California resident, starting January 1, 2020, you have a right to receive notice of our collection of consumer “personal information” (as defined in the CCPA), which provides information regarding our collection of consumer “personal information” of California residents, including a description of the categories of “personal information” that we collect, along with the business or commercial purpose for such use. We encourage California residents to visit the “Your California Privacy Rights” section of this Privacy Policy (below) for additional information.

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.

Friend Referrals

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

The Bright Bucks Sites and Features may provide you the opportunity to participate in, make available, and/or post text (e.g. questions, comments, and suggestions), images, audio, videos, or other content (collectively, “User Content”) publicly through our blogs, chat rooms, forums, interactive features, public-facing member profile, third-party social networking services or other communication functionality (“Community Features”). Please note that certain information, such as your username, Service start date, earning preferences, total rewards earned, profile picture and other profile information we believe will help motivate you and others to participate in our program may be publicly displayed on the Bright Bucks Sites and Features along with User Content. User Content may also contain metadata, which may contain information about or relating to you, that we may also collect, share and use. Anything posted through Community Features is publicly available.  This means that others will have access to that User Content and may use it or share it with third parties; this is beyond our control. If you choose to voluntarily disclose Personal Information in the User Content and/or on the Community Features, that information will be considered publicly available information as well.  The protections of this Privacy Policy will not apply to publicly available information. In addition, by posting through our Community Features, you are agreeing that we may use your User Content (and excerpts from your User Content) in connection with our Business Purposes.

Third-Party Links

The Bright Bucks Sites and Features contain links to other websites and other third-party provided goods and services that we do not own, operate nor control. In addition, because aspects of the Bright Bucks Sites and Features include third-party Offers for goods, services and the like, third parties may collect your information based on your interaction with those offers. Third-party privacy practices are not covered by this Privacy Policy, and we are not responsible for the privacy practices of such third parties. We encourage our users to be aware of and to read the privacy statements and similar disclosures of any third-party website that collects personally identifiable information before using or disclosing any personally identifiable information to such website.

Advertising Networks and Analytics Companies

We may allow other companies, commonly called third-party ad servers or advertising networks (collectively, “Ad Networks”), to display advertisements on the Bright Bucks Sites and Features. These advertisements may be based on your interests as reflected in your use of the Bright Bucks Sites and Features or our Services, as well as your use of other websites and services. Some of these Ad Networks may place a persistent cookie or other similar technology on your computer, mobile device and other devices you use (collectively, “Device(s)”), allowing them to recognize you and/or your Device each time they send you an online advertisement.  In this way, Ad Networks may compile information about where you see their advertisements online and determine which ads you click on, so that we and they may provide you with Offers believed to be of most interest to you. We do not have access to or control over the cookies or other similar technologies that may be placed by these parties on your Device, nor do we have responsibility for these parties’ privacy policies or information collection practices. You may limit or remove such cookies and similar technologies through your Device settings; for more information, visit our “Cookies and Tracking Technologies” section (below).  Likewise, we may also work with consumer data resellers that buy and/or sell information to other companies for multiple purposes including offering products and services that may interest you, and we use certain third-party analytics providers to help us understand how you use the Bright Bucks Sites and Features or our Services, and these companies may set their own cookies and similar technologies on your Device. For example, we use Google Analytics to track visitors’ activity on our website. Google Analytics and similar third-party analytics providers use web browsing data and other data analysis to improve their own products. These and other Trusted Service Providers may collect information about you, including but not limited to your online activities over time and across different websites and services, when you use the Bright Bucks Sites and Features or our Services, or other online websites and services. Each of these third parties has its own privacy policy that may differ from this Privacy Policy. We may share your Personal Information and other information with our Trusted Service Providers for the purpose of making it easier for you to sign up for their Offers, validating your communications or transactions with them, authenticating and/or validating your identification, crediting you with any earned rewards, and for our Business Purposes. Additionally, we may share information with our Trusted Service Providers to assist us in delivering Offers to you, both on the Bright Bucks Sites and Features and elsewhere, and for our Business Purposes.

Cookies and Tracking Technologies

We set and allow third parties to set and access cookies and other similar tracking technologies (referred to herein generically as “cookies”) on your Device(s), including, without limitation, web beacons and embedded scripts. Such cookies may be set alone or in combination with other cookies.  Such third parties may collect information across various channels, including offline and online, for purposes of delivering more relevant Offers to you.  As used herein, cookies are a small data file (used on or in connection with the Bright Bucks Sites and Features) which are stored on your systems. We (including our Affiliates and Trusted Service Providers) may use a variety of cookies in connection with the Business Purposes. Cookies automatically capture certain information, including, without limitation, your IP Address, operating system, screen display settings, browser type, use of Flash and Java and they detect whether your Device or software has certain capabilities such a microphone or webcam access. Cookies may also collect your Personal Information. We and our Trusted Service Providers use such information to support the Bright Bucks Sites and Features and to support our Services generally by: (i) offering you surveys, shopping, and other targeted Offers; (ii) for identity verification; (iii) for analytics; and (iv) to ensure compliance with our programs.  Cookies also help us understand or predict your interests so we can personalize your experience. Cookies are also used as follows: (a) to provide you with convenience when you access the Bright Bucks Sites and Features by remembering that you have visited us before and by remembering your username, password and other user information, and your preferences to help you avoid future re-entry of certain information; (b) to allow us and our Trusted Service Providers to customize the layout and tailor content shown to you on the Bright Bucks Sites and Features and throughout your online experience across Devices, web browsers, email, mobile and other applications. In doing so, we may link the information we collect from cookies and (from other sources referenced in this Privacy Policy) with your Personal Information and we may track your activity (including, without limitation, your web-browsing activity) in order to provide you with Offers and for Business Purposes; (c) for anonymous and also for personally identifiable analytical and statistical purposes, quality control, validation and verification purposes, and to improve the services we, our Affiliates’ and our Trusted Service Providers’ Offer; (d) Our Affiliates and Trusted Service Providers may link the information we share with them (or that they collect) to the cookie stored on your browser or Device, and they may collect information such as your IP address, browser or operating system type and version, and demographic or inferred-interest information. Our Affiliates and Trusted Service Providers use this information to recognize you across different channels and platforms, including but not limited to, computers, mobile devices, and Smart TVs, over time for advertising, analytics, attribution, and reporting purposes. For example, our Trusted Service Providers may deliver an advertisement to you in your web browser based on a purchase you made in a physical retail store, or they may send a personalized marketing email to you based on the fact that you visited a particular website. Your data may be transferred outside of the country from which it was originally collected; (e) Our mobile applications may include tracking technologies via software development kits that share your device’s precise geolocation and other details about your device (like hardware characteristics, a variety of sensor data, and a list of installed third-party applications) with our Trusted Service Providers who may use all of this information to generate Offers for you. For example, third-party tracking technologies may analyze restaurant visit trends to better serve customers’ needs or your mobile application install history to provide you Offers that may be of interest. See instructions to limit or disable such tracking in this section below; but be aware that limiting such tracking will affect some device or mobile application functionality. We use both session cookies and persistent cookies. For the session cookies, once you close your browser, the cookie terminates. A persistent cookie is a small text file stored on your hard drive for an extended period of time. Persistent cookies can be removed or disabled by following your web browser help-file directions.

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.

Social Features

Certain functionality on the Bright Bucks Sites and Features may permit interactions that you initiate between the Bright Bucks Sites and Features and a third-party website or service, such as Facebook, Pinterest, Instagram and Twitter (“Social Features”). Examples of Social Features include enabling you to “like” or “share” content from the Bright Bucks Sites and Features with other websites or services; to log-in to the Bright Bucks Sites and Features using your username and password for a third-party website or service; to transmit content to the Bright Bucks Sites and Features from your account on a third-party website or service; and to otherwise connect the Bright Bucks Sites and Features to a third-party website or service. Enabling or interacting with Social Features may also set one or more cookies on your Device(s).  Please refer to the terms of use and privacy policies of such third-party services offering such Social Features. If you choose to use Social Features, information you post or provide access to will be shared with that third-party website or service and others, and may be publicly displayed on the Bright Bucks Sites and Features or by the provider of the Social Feature that you use. Similarly, if you post information on a third-party platform that references any of the Bright Bucks Sites and Features (e.g., by using a hashtag associated with any of the Bright Bucks Sites and Features in a tweet or status update), your post may be published on the Bright Bucks Sites and Features in accordance with the terms of the third-party website or service. Also, both we and the third party may have access to certain information about you and your use of the Bright Bucks Sites and Features and the third-party website or service. In addition, we may receive information about you if other users of a third-party website give us access to their profiles and you are one of their “connections,” or information about you is otherwise accessible through your connections’ web pages, profile pages, groups you or they belong to, or similar pages on a social networking or other third-party website or service. The information we collect in connection with Social Features is subject to this Privacy Policy. The information collected and stored by the third-party website or service via Social Features remains subject to the third party’s privacy practices, including whether the third party continues to share information with us, the types of information shared, and your choices with regard to what is visible to others on that third-party website or service.

Sharing

In addition to the types of sharing described throughout this Privacy Policy, we may disclose your Personal Information (and other information related thereto) as described in this section. Residents of California should also refer to the section of this Privacy Policy titled “Your California Privacy Rights” for additional disclosures. We may disclose your Personal Information when required by law, or where we have a good-faith belief that such action is necessary to comply with a judicial or administrative proceeding, a criminal investigation, a court order, or legal process served on us. We may also share your Personal Information at the request of governmental authorities conducting an investigation, or if we in our sole discretion believe there to be a credible situation that requires us to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of our Terms of Use or Privacy Policy for any of the Bright Bucks Sites and Features or our Services. We may also use IP addresses or other Device, activity or session identifiers to identify users, and we reserve the right (in our sole discretion) to do so in cooperation with our Affiliates and Trusted Service Providers as well as copyright owners, Internet service providers, wireless service providers, or law enforcement agencies. These transfers and disclosures may occur without notice to you.

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/.

Business Transitions

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 are responsible for maintaining the accuracy of any information you submit to us, such as your contact information. If you have any questions about updating your information, privacy choices and/or opting out of certain programs, services and data activities, please visit the “Contact Us” section below for more information and instructions to contact us.   You may opt out of receiving marketing emails by either (i) following the opt-out instructions provided to you in those emails, (ii) by visiting your account settings or similar features on the relevant Bright Bucks Sites and Features, or (iii) by contacting us as provided in the “Contact Us” section below. Please note that as long as you remain registered with or a user of any of the Bright Bucks Sites and Features or our Services, even if you opt-out of marketing emails, you may still receive administrative emails, such as notices about service and status changes and changes to our Terms of Use or Privacy Policy. If you sign up to receive SMS or MMS messages from the Bright Bucks Sites and Features, you may unsubscribe from any SMS or MMS messages received by replying “STOP”. If you do not wish to receive advertisements, content, surveys, promotions, Offers, or rewards from us which would be sent to you by virtue of your having installed our Extensions, you should not install or should uninstall such Extensions.

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.

You may opt-out of providing your location information to us. If you do not want us to use your location information as described in this Privacy Policy, you may turn off the location services for your Device located in your account settings (if available) or in your Device settings. If you do not want our mobile applications to collect any information from you, you should uninstall the application using the standard uninstall procedures that may be available as part of your mobile Device or via the mobile application marketplace or network where you obtained the mobile application.

Notification of Changes

We reserve the right to make changes to this Privacy Policy from time to time. If we decide to change this Privacy Policy, we will provide notice of such changes by sending you an administrative email and/or posting those changes in places on the Bright Bucks Sites and Features deemed appropriate by us so our users are always aware of what information we collect, how we use it, and under what circumstances it may be shared with others. Your continued use of any of the Bright Bucks Sites and Features or our Services after delivery of the administrative email to you or after the changes are posted constitutes your agreement to the changes. If you do not agree to the changes, please discontinue your use of such Bright Bucks Sites and Features and our Services. To the extent that an arbitrator or court of applicable jurisdiction determines that applying any changes to this Privacy Policy to any prior events or circumstances would render this an illusory or unenforceable contract, such changes shall be applicable on a prospective basis only, with respect to events or circumstances occurring after the date of such changes, to the extent necessary to avoid this Privacy Policy being deemed illusory or unenforceable. In any event, if any Personal Information was previously submitted to or collected by us pursuant to an earlier version of this Privacy Policy that required a certain notice period prior to any changes being effective, any changes under this Privacy Policy will not be effective as to you or such previously-collected Personal Information until the previously-specified notice period has passed after the date of this Privacy Policy.

Children’s Privacy

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.

Security

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

Although we generally maintain our user data in the United States, it is possible that some of the data processing may occur outside of the United States, carried out by companies or individuals under contract with us. By using the Bright Bucks Sites and Features and our Services, you consent to this transfer of your personal data to any server used by the Company or its service providers from time to time. If you are not a resident of the United States or Canada, please be aware that data protection laws in the United States and Canada (as well as the legal procedures for courts, governmental authorities, and parties in civil litigation to obtain access to our user data) may differ substantially from the laws and procedures in your country of residence. If you are located in a country outside the United States and Canada and submit Personal Information to us, you are consenting to the transfer, processing, storage and use of that information in the United States as provided in this Privacy Policy. The interpretation and application of this Privacy Policy shall be governed by the laws of the United States and the State of California without regard to its conflict of law provisions. Your use of the Bright Bucks Sites and Features or our Services are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States.

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

If you have any questions or concerns regarding this Privacy Policy or your use of any Bright Bucks Sites and Features or our Services, you will find answers to frequently asked questions (FAQs) by visiting the Help Center of each of our Services. Generally, our Help Center or contact options are located or accessed from the applicable Bright Bucks Sites and Features footer or main menu options.   For questions relating to our privacy practices (other California residents making CCPA requests), please visit the Privacy section of the appropriate Help Center.  If your question is not answered in the Help Center, you can submit a privacy-related request by submitting a ticket to our Customer Support team for the appropriate Service. To contact us by mail, send your correspondence to the following address and specify the Service you are using along with your request, question or concern:

Bright Bucks, Inc.
17503 La Cantera Parkway Suite 104-285

San Antonio, TX 78257