Website Privacy Policy

Effective on January 1, 2020

Couponclans, LLC (hereinafter referred to as “Supplier” “we,” or “us”) operates its corporate website at http://couponclans.com (“Site”). This privacy policy describes how we collect and use personal information about you, with whom we share personal information, how we protect this information, and your rights in relation to this information.

This privacy policy does not address information collected as part of the services provided by Supplier (the “Services”), which is described in the Supplier Services Privacy Policy; however, this privacy policy representatives of entities (such as our customers and publishers participating in our network) that have signed up for our Services, and access certain information and reporting through our Site. Additional terms set forth in our commercial agreements with customers and publishers may govern your use of our Site.

Supplier is part of the Couponclans, LLC , which includes the affiliates and subsidiaries of our parent company Couponclans, LLC.

This Site is designed to comply with the DAA Self-Regulatory Principles for Online Behavioral Advertising and the NAI Code of Conduct and the Interactive Advertising Bureau (IAB) Europe Framework for OBA.  Click here if you would like further information regarding the DAA Self-Regulatory Principles or here if you would like more information regarding the NAI Code of Conduct or here if you would like further information about the IAB Europe’s OBA Framework.

If you have any questions or concerns about our use of your personal information, please contact us using the contact details provided in the ‘Contact Information’ of this Privacy Policy.

QUICK LINKS

COLLECTION OF INFORMATION

We collect certain information from you when you visit our Site. This information is further described below.

Information we collect

• Personal Identifiers and online identifiers such as your name, address, phone number, e-mail address, or credit card information (to the extent needed to pay for or receive payment as part of our Services; and browser and device information such as such as your device’s Internet protocol (“IP”) address; unique device identifiers as well as hardware or operating system device identifiers (e.g., IDFA for iOS and AAID for Android); and information about the type of Internet browser, browser language and operating system you use; connection type (wired or Wi-Fi); the region where your device is located; network to which your device is connected; geo-IP data; and the mobile carrier (if available).
• Commercial and Transaction Information such as information about payments made, received or due as part of the Services.
• Information about your behavior on our Site such as information regarding your browsing, usage, and interactions; information that allows us to identify browsers and devices we have interacted with previously; the website you came from before and visited after; and information related to the pages you are viewing on the Site.
• Information required if you are a customer or publisher such as name, address, phone number, email address, Taxpayer Identification Number (which may be an individual’s Social Security Number), VAT registration numbers or other foreign tax identification numbers (for foreign entities).

Cookie Information

In connection with certain features of our Services to customers, we may set cookies on your web browser (or use other technologies like clear gifs, web beacons or similar devices, including devices that function in the mobile environment) when you interact with websites, applications or advertisements in our network.  For detailed related to the cookies that we use as well as instructions for opting-out, click here.

USE OF INFORMATION

We use the information we collect from or about you on our Site in the following ways:

• to contact you and/or provide information requested by you, including access to our newsletters, blogs, and other marketing information about our Services;
• to respond to applications and inquiries of prospective customers and publishers;
• to provide customers and publishers access to reporting associated with our Services;
• to conduct internal analysis in order to perform and improve the effectiveness of our Site and our services and to understand the audiences for our Site and Services;
• to respond to inquiries and requests of our Site users.

To the extent permitted by applicable law, we also collect, create, process and store information that is not personal information such as sets of aggregate data and other generalized information, including information about browsing, usage and interactions and de-identified personal information that does not reveal your identity. We retain the right to use and disclose information that is not personal information in any manner permitted by law.

SHARING OF INFORMATION

We do not sell your personal information to third parties; however, we do disclose information about you and your usage of our Site as follows:

• to third parties that are providing services on our behalf;For example, (a) when you apply for participation as a publisher on our network, we may share information submitted by you with third party vendors to authenticate and/or supplement your application information; (b) we may also share customers credit card information with our third party banking and payment portal for the purposes of collecting payments due to us or to facilitate payment to a customer; (c) we may share customer personal information to publishers participating in our network to provide Services to such customers; or (c) we may share information in connection with a sweepstakes, contest or other promotions you entered for the purposes of facilitating such promotion,
• to infrastructure, technology, operational and other service providers to help support the infrastructure necessary to operate the Site; or
• to our group companies and other partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Services), or who otherwise process personal information for purposes that are described in this privacy policy, notified to you when we collect your personal information, or notified to you by the group company or partner.

We may also disclose information about you:

• if we are required to do so by law or legal process;
• to law enforcement authorities or other government officials;
• when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
• if necessary to protect the vital interests or legal of another individual;
• in connection with a corporate reorganization or a sale or transfer of all or a portion of our business or asset; or
• to any other person with your consent to the disclosure.

YOUR RIGHTS

If you wish to access, correct, update or request deletion of your personal information as required by applicable laws, filling out the form located here and providing the verification information as stated on the form. Alternatively, you can contact us using the contact details provided under the “Contact Information” heading below.

We will respond to all requests we receive from individuals wishing to exercise their rights in accordance with applicable data protection laws.

OPT-OUTS AND WITHDRAWAL OF CONSENT

Regardless of whether you are located in the EU or elsewhere, you may exercise the applicable opt-out options below.

Web Browser/Cookie-Based Opt-Out

You may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. There are also many programs that allow you to manually delete your cookies.  For more information regarding this form of cookie-based opt-outs, click here.

Mobile Application-Based Opt-Outs

Cookie-based opt-outs are not effective on mobile applications. Users may opt out of certain advertisements on mobile applications or reset advertising identifiers via their device settings.  To learn how to limit ad tracking or to reset the advertising identifier on your iOS and Android device, click on the following links:

• iOS
• Android

You may also download and set your preferences on the App Choices mobile application(s) available in Google Play or the Apple App stores.

Opt-Out

If you do not want your personal information to be used by us for marketing purposes, you may opt out of such disclosures by sending an email.

RIGHTS OF INDIVIDUALS IN THE EEA

If you are located in the European Economic Area, you have the following additional data protection rights:

• You can object to processing of your personal data,
• You can ask us to restrict processing of your personal data,
• You can request portability of your personal data or
• You can request deletion of your personal data

You can exercise these rights by please filling out the form located here and providing the verification information as stated on the form, or by contacting us using the contact details provided under the “Contact Information” heading below.

Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time.  Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. You can withdraw your consent by using the go to the data subject access request page and submitting a request or by contacting us using the contact details provided under the “Contact Information” heading below.

You have the right to complain to a data protection authority about our collection and use of your personal information.  For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area are available here.) We would, however, appreciate an opportunity to address your complaint before you approach the supervisory authority so please contact us in the first instance with any complaints you may have by sending an email.

Legal Basis For Using EEA Personal Data:

If you are located in the European Economic Area, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. Usually, we rely on the following legal bases to process your personal information:

• Legitimate interest: We may process your personal data for our legitimate interests. For example, to provide or improve our Services, manage relationships with customers, or for security purposes and fraud prevention. We will also reach out to you about our service offerings to make sure you are aware of all of the available options. When we process personal information to meet our legitimate interests, we put in place safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.
• Consent: We will rely on your consent to use your personal data (including, without limitation, technical data, cookie data, usage information, and geo-location data), for personalized or interest-based advertising purposes and to send you marketing information. When you first visit a website or application, we read cookies and similar technologies on the internet browser of your device or in connection with applications you use that allows us to identify browsers and devices that have previously interacted with our Service or customers.  This initial reading of cookies and similar technologies allows us to determine whether you or the user(s) of your device, have previously given consent to the use of personal data. You may withdraw your consent at anytime by using this Subject Access Request page or by using the tools outlined above.
• Fulfillment of Contract: We will process your business contact information you provide when registering for our Service to provide the services and manage relationships.
• Legal obligation: In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person. If we ask you to provide personal information to comply with a legal requirement, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the Contact Information section of this Privacy Policy.

RIGHTS OF CALIFORNIA RESIDENTS

This section contains disclosures required by the California Consumer Privacy Act (“CCPA”) and applies only to “personal information” that is subject to the CCPA.

Personal Information We Collect, Disclose for a Business Purpose, and Sell. 

We collect the categories of personal information about California consumers identified in the chart below.  As further set forth in the chart below, in the past 12 months, we have disclosed and sold California consumers’ personal information to third parties for business or commercial purposes.  We do not sell information collected from your use of this website.

Your Rights Regarding Personal Information. California residents have certain rights with respect to the personal information collected by businesses.  If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:

• The right to know the categories and specific pieces of personal information we collect, use, disclose, and sell about you, the categories of sources from which we collected your personal information, our purposes for collecting or selling your personal information, the categories of your personal information that we have either sold or disclosed for a business purpose, and the categories of third parties with which we have shared personal information;
• The right to request that we delete the personal information we have collected from you or maintain about you.
• The right to opt out of our sale(s) of your personal information. Please note that if you opt out of certain types of sales, we will be unable to provide you with the services that rely on such sales.
• The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

To exercise any of the above rights, please contact us using the following information and submit the required verifying information, as further described below:

• Online
• By emailing

Note that we may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled.  We will require you to provide, at a minimum the information indicated as required on the webform located here.  You may designate an authorized agent to make a request on your behalf by having the agent complete the webform located here. We do not knowingly sell personal information of minors under 16 years of age.

DURATION OF PROCESSING

Supplier may actively process your personal information for one year from the time of your last interaction with our Services or the websites or applications of our customers.  We may, however, store your information in a pseudonymized or anonymized form for up to seven (7) years after the date that you interact with our Services where we have an ongoing legitimate business need to do so (for example to respond to a query from you, provide you with a service you requested or to comply with applicable legal, tax or accounting requirements.  When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

TRANSFERS OF PERSONAL INFORMATION

Supplier and our customers or service providers may be located in various countries throughout the world.  As a result, your personal information may be transferred to, and processed in, countries other than the country in which you are resident.  These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

SECURITY

We take appropriate technical and organizational measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of personal information. This includes the necessary physical, electronic and managerial procedures designed to protect data integrity, access and use. Please note that no method of transmission over the Internet or method of electronic storage is 100% secure. As a result, we strive to protect your personal information but cannot ensure or warrant the security of your information against any possible loss or unauthorized access.

THIRD PARTY SITES AND PARTNERS

Our Site may contain links to other websites, including our advertisers’ websites. Other websites may also reference or link to our Site. Some of our advertisers or third-party website or technology partners may place their own cookies and/or other data collection tools on your Internet browser; however, we have no access to or control over these cookies and/or other data collection tools. These other domains and/or websites are not controlled by us. We encourage our users to read the privacy policies of each and every website that they interact with. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites. Visiting these other websites is at your own risk.

PUBLIC FORUMS

Our Site offers a publicly accessible blog. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog, contact us. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

CHILDREN’S INFORMATION

We believe it is important to provide added protection for children online. We encourage parents and guardians to spend time online with their children to participate in and monitor their online activity. Supplier Services are not intended to process personal information of children under the age of 16 does not knowingly collect any personal information from children under the age of 16. If a parent or guardian believes that Supplier has in its database the personal information of a child under the age of 16 please contact and we will use our best efforts to remove the information from our records.

CHANGES TO THIS PRIVACY POLICY

Supplier reserves the right to change or replace this Privacy Policy at any time to reflect any changes in our privacy practices. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make.  We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.  Any changes or replacement will be posted on our website related to this Privacy Policy and located at here. You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy. We encourage you to review our Privacy Policy on a regular basis.

CONTACT INFORMATION

We use reasonable processes to ensure compliance with this Privacy Policy and periodically verify that the Privacy Policy is accurate. We encourage you to raise any concerns using the contact information provided below and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of information.

For any questions about our privacy practices, you may contact us by email.