Privacy Notice FOR EDO interactive, INC. services
EFFECTIVE:
July 21, 2019
This
Privacy Notice applies to this website and to other websites, applications,
services and mobile applications on or in which this Privacy Notice is posted
or referenced (collectively, the "edo Services"). The edo Services
are owned and/or operated by edo Interactive, Inc. ("edo,"
"we", "our" or "us"). We hope that this Privacy
Notice helps clarify how we collect and process your information.
This
Privacy Notice describes:
·
The information we collect on or through the edo Services and
how we collect it.
·
How we use and process the information we collect.
Please
review this Privacy Notice carefully. When you submit information to or through
the edo Services, you consent to the collection and processing of information
as described in this Privacy Notice.
If
you have not done so already, please also review our Terms of Service)
("Terms"). The Terms contain provisions that limit our liability to
you and require you to resolve any dispute with us through final and binding
arbitration on an individual basis and not as part of any class or
representative action.
IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY NOTICE, THEN
PLEASE DO NOT USE THE EDO SERVICES.
1. CHANGES
TO THIS PRIVACY NOTICE
The
Effective Date of this Privacy Notice is set forth at the top of this webpage.
Whenever possible, we will provide you with advance written notice of our
changes. We will not make retroactive changes that reduce your privacy rights
unless we are legally required to do so. Your continued use of the edo Services
after the Effective Date constitutes your acceptance of the amended Privacy
Notice. The amended Privacy Notice supersedes all previous versions.
2. INFORMATION
WE COLLECT
"Personal
Information" means information associated with or used to identify a
specific person. Personal Information includes: (1) contact data (such as your
e-mail address, telephone number and employer); (2) demographic data (and your
zip code); and (3) certain Usage Data, such as the IP address. If you
communicate with us by, for example, e-mail or letter, any information provided
in such communication may be collected as Personal Information.
"General
Information" is information about an individual's online activity
that, by itself, cannot be used to identify him or her, such as browser type,
operating system and the dates/times of Services access.
Personal
Information and General Information may be linked together. Different types of
General Information also may be linked together and, once linked, may identify
an individual person.
3. HOW WE
COLLECT INFORMATION
We
collect information that you provide to us and from your use of the edo
Services. The information that we collect and how we process it depends on how
you use and access the edo Services. Some information is collected through use
of cookies and similar tools (see section 5 below).
a.
Information that You Provide to edo: You may
provide us with your Personal Information when you contact us for help or
information, create an account to use one of the edo Services or otherwise
voluntarily supply your Personal Information to us. We may collect information,
some of which may be Personal Information, as otherwise described to you at the
point of collection or pursuant to your consent.
b.
Information that We Collect When You Use the edo Services: When
you use the edo Services, we may automatically collect Information about how
you interact with the edo Services, such as (i) IP address; (ii) domain server;
(iii) type of device(s) used to access the edo Services; (iv) web browser(s)
used to access the edo Services; (v) statistics and information associated with
the interaction between your browser or device and the edo Services; and (vi)
referring webpage or other source through which you accessed the edo Services
(collectively "Usage Data"). Depending on applicable law, some
Usage Data may be Personal Information.
c.
Information from Other Sources: Third parties that
assist us with our business operations also collect information (including
Personal Information and Usage Data) from you and share it with us. For
example, we may receive "tokenized" information (i.e., payment card
information that was replaced with a unique identifier or token) about your
credit card transaction history when you take advantage of certain offers.
4. HOW WE
PROCESS INFORMATION
a. How We
Use Information
We use
the information that we collect or that you provide to us to operate, maintain
and enhance the edo Services, including:
a.
To present the edo Services to you and to customize, improve and
develop content and functionality that helps us better serve your needs;
b.
For customer service and to troubleshoot problems;
c.
To facilitate communication between edo and you;
d.
To prevent and detect fraud and other prohibited or illegal
activities and investigate security breaches;
e.
To send emails and other communications that display content
that we think will interest you, such as news about our products, services and
promotions;
f.
To generate statistical information about how users interact
with the edo Services and conduct analyses to support, improve and enhance the
edo Services;
g.
To carry out our obligations and protect our rights arising from
any contracts entered into between you and us, including our Terms of Service;
h.
To protect the safety and security of users of the edo Services;
i.
To send you important administrative information regarding the
edo Services, such as changes to this Privacy Notice or our other policies; and
j.
To fulfill any other purpose for which you provide Information
to us or to which you consent.
We and
our business partners also may combine different types of information collected
from or about you through various sources, including Personal Information, and
use the combined information for the purposes described in this Privacy Notice.
How We
Share and Disclose Information
Unless
you have consented, we will not share or disclose your Personal Information
other than as described in this Privacy Notice. We may share and disclose
information:
.
With our affiliates and strategic business partners;
a.
With third party service providers retained to perform functions
on our behalf, such as web hosting and data analyses companies, that have
access to Personal Information needed to perform their functions;
b.
To enforce our agreements with users or other third parties;
c.
To protect the safety and security of users;
d.
With companies with which we plan to merge or an acquirer of all
or substantially all of edo's assets (we will continue to process information
consistent with this Privacy Notice and, when possible, will provide you with
notice before Personal Information is transferred or becomes subject to a
different privacy policy);
e.
To comply with a subpoena, regulation, binding order of a data
protection agency, legal process, governmental request or other legal or
regulatory process; and
f.
If we believe you have violated or are violating our Terms of Service or in
order to protect or defend edo's rights or property, even without a subpoena,
warrant or other court order.
Tracking
Tools and "Do Not Track" Information
Cookies & Other Tracking Tools: "Tracking Tools" means
technology that collects information about your use of the edo Services, such
as cookies and web beacons.
How We Respond to Browser
"Do Not Track" Signals: Some web browsers (including Safari, Internet
Explorer, Firefox and Chrome) incorporate a "Do Not Track" (DNT)
or similar feature that signals to websites that a visitor does not want to
have his/her online activity and behavior tracked. If a website that responds
to a particular DNT signal receives the DNT signal, the browser can block that
website from collecting certain Personal Information about the browser's user.
Not all browsers offer a DNT option and DNT signals are not yet uniform. For
this reason, we and many website operators do not respond to DNT signals. For
more information about DNT signals, visit http://allaboutdnt.com.
Data
Retention
We will hold your personal information on our systems for as
long as is necessary to perform the relevant processing activity, or as long as
is set out in any relevant contract you hold with us. This is a case by case
determination that depends on things like the nature of the data, why it is
collected, why it is processed, and relevant legal or operation retention
needs. For example, we may retain your data for as long as you hold a rewards
account so that we may process and fulfill your future award transactions. We
may also be legally required to hold some types of information to fulfil our
statutory obligations. We
review our retention periods for personal information on a
regular basis. When the relevant processing activity has been completed, we may
destroy your data, or alternatively anonymize the data in such a way that you
are not personally identifiable, either directly or indirectly
INFORMATION
PROTECTION
The
security of your information is our top priority. We use physical, electronic,
and procedural safeguards that comply with federal and international standards
to protect and limit access to your personal information. Augeo also actively
monitors our systems and your account for suspicious or fraudulent activity.
Managing
Employee Conduct
Augeo has
an absolute commitment to integrity, our related values and ethical standards,
and the associated business conduct we expect from all our employees. These
standards include specific guidelines about how employees must safeguard
confidential information, including our customers data.
Regulatory
Compliance
Augeo
maintains compliance with all required data protection regulations that apply
to the information systems and data we collect. Augeo regularly validates its
security, operational, and business practices, both internally and through
third party audits.
Online
Security
Augeo
uses at minimum 128-Bit Encryption each time you access your account(s) and
perform transactions on our portals. Look for website to start with https:// or
have a lock symbol.
Augeo
regularly tests the web security of our sites and products.
Fraud
Monitoring
Augeo
continuously monitors the registration, login, and activities of accounts to
detect fraudulent or unauthorized use of your account.
What Can
You Do To Help?
· Help
protect yourself by keeping your operating system, browser, and anti-virus
software up-to-date so you'll have the latest security enhancements.
·
Regularly monitor your account for suspicious activity.
· Watch
out for phishing emails. Use caution when opening links or attachments in
emails that you are not expecting.
· Used
strong passphrases and change them frequently.
· Use
safe practices when on social media.
Please
note that information you send to us electronically may not be secure when it
is transmitted to us, depending on the systems and communication channels you
use. We recommend that you do not use unsecure channels to communicate
confidential information to us.
LINKED
SERVICES
This
Privacy Notice applies solely to information collected by or through the edo Services.
As noted in the Terms, the edo Services may contain links to third-party
websites and services, including social media (collectively, "Linked
Services"). Linked Services are not under the control of edo and edo
is not responsible for Linked Services. The inclusion of a link does not imply
endorsement by edo of the Linked Services or any association with the operators
of the Linked Services. edo does not investigate, verify or monitor the Linked
Services. We provide links to Linked Sites for your convenience only. You
access Linked Services at your own risk. We encourage you to read about the
privacy practices of any website that you access.
EDO
SERVICES ARE NOT FOR USE BY CHILDREN
We do not
knowingly collect information from minors. To use the edo Services, you must be
the age of legal majority in your place of residence. By using the edo
Services, you hereby represent that you are at least the age of legal majority
in your place of residence. All information provided to edo is treated as if
provided by an adult.
If we
learn that a minor has submitted information about himself/herself to us, we
delete it as soon as possible. If you believe that we have collected Personal
Information from a minor, please contact us at privacy@augeomarketing.com.
Transferring
Your Information
Because
Edo is a US-based company, your information may be collected and processed in
the United States. If you live or are travelling outside the US and access our
online websites or platforms, any information that you provide or that we
collect may be transferred to our systems in the US. However, if we transfer
your information in this way, we will put in place appropriate protection to
make sure your personal data remains adequately protected and is treated in
line with this Policy.
California privacy law
Under
California law, website operators must offer you the option to opt out of
disclosure of Personal Information to third parties for their direct marketing
purposes. A website operator also is required to disclose to its California
customers, upon request, the identity of any third parties to whom the business
has disclosed Personal Information within the previous calendar year, along
with the type of Personal Information disclosed, for the third parties' direct
marketing purposes. If you are a California resident and would like to make
such a request, please submit your request in writing to: edo Interactive,
Attn. Legal Department, 278 Franklin Road, Suite 320, Brentwood, TN 37027.
Please note that under California law, businesses are only required to respond
to a customer request once during any calendar year.
Under
California Civil Code Section 1789.3, we are required to provide California
residents with the following specific consumer rights information:
.The edo Services are owned and/or operated in the United States
by edo Interactive, Inc., 278 Franklin Road, Suite 320, Brentwood, TN 37027
i.
Unless otherwise expressly stated, the edo Services are provided
without charge.
ii.
To file a complaint regarding any of the edo Services or to
receive further information regarding use of the edo Services, please send a
letter to edo Interactive, Inc., Attn. Legal Department, 278 Franklin Road,
Suite 320, Brentwood, TN 37027 (with "California Resident Request" as
the reference line). You also may contact the Complaint Assistance Unit of the
Division of Consumer Services of California's Department of Consumer Affairs in
writing at 400 R Street, Suite 1080, Sacramento, California 95814 or by
telephone at 916.445.1254 or 800.952.5210.
Legal
Data
protection law in Europe requires a lawful basis for collecting and retaining
personal information from residents of the European Economic Area. Our lawful
bases include:
·
Performing the contract we have with you: In certain circumstances, we need
your personal data to comply with our contractual obligation to deliver our
services, and assist with any questions you may have.
· Legal
compliance: Sometimes the law says we need to collect and use your data.
·
Legitimate interests: This is a term in data protection law that allows us to
process your personal information if we have a fair reason to use your data,
and only if we do so in ways which do not hurt your interests and rights. We sometimes
require your data to pursue our legitimate interests in running our business,
including to process your redemption and purchase transactions, maintain your
account, prevent fraud, quality assurance, and for marketing purposes, as long
as our use of your data does not materially impact your rights, freedom or
interests. This allows us to improve and develop the quality of the online
experience we offer all our users.
Know Your
Options
Users or
website visitors residing in certain countries, such as those in the EU, are
afforded certain rights regarding their personal information. Except where an
exception or exemption applies, these rights may include the ability to access,
correct, and request deletion of your personal information. While these rights
are not globally applicable, our customers are entitled to access the personal
information that we hold, if any, concerning them.
Keeping
your account information up-to-date is very important. You may review or update
certain account information by logging in and accessing your profile, depending
on the Augeo product or service portal used. If you cannot change the incorrect
information online, or you prefer to request changes offline, please contact us
as described below. Please note that we may retain and process certain
information as required by law or as necessary for our legitimate business
purposes.
Augeo has
appointed a Data Protection Officer (DPO) who is responsible for monitoring and
ensuring compliance with this Privacy Policy, acting as a point of contact for
data protection queries, managing Augeos response to privacy-related
incidents, and updating this Policy as necessary. If you have any questions
about your rights related to information Augeo possesses, or if you have any
privacy questions or concerns about how Augeo processes your personal data,
please contact our DPO by emailing privacy@augeomarketing.com.
If you
have contacted Augeo and have further questions about how to protect yourself,
or if you have any concerns about how Augeo handles or processes your personal
information, you may contact the data protection authority for your area:
· U.S.
Residents: Visit the Federal Trade Commission Consumer Information website at
www.ftc.gov. · E.U. Residents: Visit the European Commission website at
http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm,
and find the data protection authority for your country.
QUESTIONS?
If
you have questions about this Privacy Notice or to request corrections,
amendments or deletions to any Personal Information that you have provided
through the edo Services, contact us at privacy@augeomarketing.com. edo
will use reasonable efforts to supply you with requested Personal Information
and correct any factual inaccuracy or delete your Personal Information from our
databases. To honor your request, we will need the exact information you wish
to correct, amend or delete.