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The personal information we collect and obtain depends on how you interact with us, the Services you use, and the choices you make. We collect information about you from different sources and in various ways when you use our Services, including information you provide directly, information collected automatically, information from third-party data sources, and data we infer or generate from other data. The types of personal information we may collect about you includes:
Identifiers such as name, Social Security number, date of birth, postal and email address, and phone number;
Government-issued photo ID, such as a driver's license or passport, photograph, proof of address documentation (such as a utility bill) and proof of identity documentation (such as a marriage document);
Login credentials for your Coupon System account;
Financial information, including your account number from our Bank Partners, Coupon System account transaction history, information about your linked non-Coupon System accounts (such as transaction information and balances, payroll account information, etc.), and payment card information;
Direct deposit status (whether you electronically deposit a portion of your regular paycheck or benefit payment above a minimum threshold);
Information included on a tax return you provide;
Credit score and other credit history data from a credit reporting agency, if you enroll in certain features of the Services;
Employment information, including occupation, information about your employer, employee email address, and income details (such as source of income, approximate or expected income and how frequently you are paid);
Physical characteristics, demographic information and similar details (such as sex, gender, race, color, marital or family status, citizenship status, military or veteran status, signature, language preference and national origin) present in documents (e.g., IDs, tax returns) you provide;
Commercial information, including interest in a product or service, purchasing or consuming tendencies, and receipts or records of purchase or enrollment in products or Services;
Voice recordings (such as when you call Coupon System's member services);
Social media handles;
Lease or rent information you provide us, such as lease details and documents, rent amount, landlord/property manager name and contact details;
Information you provide through member services interactions and that you provide about your experience with Coupon System, including via questionnaires, surveys, participation in user research or other feedback;
Information provided by identity verification and fraud prevention platforms;
Information provided by marketers and other websites on which Coupon System advertises;
Information you provide through contacts integration, including a list of contacts from your phone's operating system;
Profile photos and other information you choose to provide for your Coupon System profile;
Other information you choose to provide, such as through our "Contact Us" feature, emails or other communications (such as with member services), referrals, chatbots, surveys, research participation, on social media pages, or in registrations and sign-up forms;
Inferences, including new information from other data we collect, including using automated means to generate information about your likely preferences or other characteristics ("inferences"). For example, we may infer your general geographic location (such as city, state, and country) based on your IP address;
The types of personal information we may collect about you also include types that may be classified as sensitive personal information, including:
Biometric Data: We or our identity verification partners may collect documents that contain your photograph or require you to provide a photo of yourself. This information and data derived from these images may be considered biometric data and may be used to verify your identity or meet regulatory obligations. We will retain biometric data for as long as necessary to satisfy the purpose of collection or no more than 3 years after your account is closed, unless otherwise required by law;
Precise geolocation data derived from a device and that is used or intended to be used to locate you within a geographic area that is equal to or less than the area of a circle with a radius of 1,750 feet; and
Demographic data such as racial or ethnic origin, or religious or philosophical beliefs.
We may use automated technologies on our Services to collect information about your equipment, browsing actions and usage patterns. These technologies help us (1) remember your information so you do not have to re-enter it; (2) track and understand how you use and interact with our Services, including our online forms, tools or content; (3) tailor the Services around your preferences; (4) measure the usability of our Services and the effectiveness of our communications; and (5) otherwise manage and enhance our products and Services, and help ensure they are working properly. Information collected by automated means may include:
Site Visitor information: When you visit our Site, we may obtain certain information by automated means, such as cookies, web beacons, web server logs and other technologies. A "cookie" is a text file that websites send to a visitor's computer or other internet-connected device to uniquely identify the visitor's browser or to store information or settings in the browser. A "web beacon," also known as an internet tag, pixel tag or clear GIF, links web pages to web servers and cookies and may be used to transmit information collected through cookies back to a web server. The information we collect in this manner may include your device IP address, unique device identifier, web browser characteristics, device characteristics, operating system, language preferences, referring URLs, clickstream data, and dates and times of website visits. Your browser may tell you how to be notified about certain types of automated collection technologies and how to restrict or disable them. Please note, however, that without these technologies, you may not be able to use all the features of our Services.
App User Information: When you use our App, we also may collect certain information by automated means, such as through device logs, server logs and other technologies. The information we collect in this manner may include the device type used, the mobile operating system, device identifiers and similar unique identifiers, device settings and configurations, IP addresses, battery and signal strength, usage statistics, referring emails and web addresses, dates and times of usage, actions taken on the App, and other information regarding use of the App. In addition, we may collect your device's geolocation information. Your device's operating platform may provide you with a notification when the App attempts to collect your precise geolocation. Please note that if you decline to allow the App to collect your precise geolocation, you may not be able to use all the App's features. Your device may tell you how to be notified about certain types of automated collection technologies and how to restrict or disable them. Please note, however, that without these technologies, you may not be able to use all the features of our Services. You can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device.
We use the personal information we collect for purposes described in this privacy notice or as otherwise disclosed to you. For example, we use personal information for the following purposes:
• Provide the Services;
• Process and fulfill transactions;
• Establish and manage Coupon System accounts;
• Personalize your experience on our Services;
• Remember you and the information you share with the Services including on forms and applications;
• Facilitate payroll or other direct deposits (including tax refunds) to your Coupon System account;
• Facilitate transfers or API connections between external bank accounts and Coupon System accounts;
• Verify your identity, including to facilitate a name change request;
• Respond to inquiries, provide member support and resolve disputes;
• Send you communications, including emails, text messages, and App push notifications, that you request or that we are permitted to send;
• Determine your eligibility for, and administer your participation in, certain features of the Services, including, but not limited to, surveys, contests, sweepstakes, promotions and rewards;
• Facilitate and manage referrals from business partners and third-parties;
• Advertise and market our products and Services, and to send you information about third-party products and Services;
• Provide you targeted offers and notify you of third-party locations where you may use our products and Services;
• Provide member support and quality assurance, and conduct customer service training;
• Collect fees and other amounts owed in connection with your Coupon System account;
• Operate, evaluate and improve our business (including researching and developing new products and Services; enhancing, improving, debugging and analyzing our products and Services; managing our communications; establishing and managing our business relationships; and performing accounting, auditing and other internal functions);
• Maintain and enhance the safety and security of our products and services and prevent misuse;
• Protect against, identify and prevent fraud and other criminal activity, claims and other liabilities;
• Exercise our rights and remedies and defend against legal claims;
• Comply with and enforce applicable legal requirements, relevant industry standards and Coupon System policies;
• Develop, maintain, and improve our services by using machine learning, AI, and risk modeling;
• To provide our services using privacy preserving de-identified data. Coupon System will not attempt to re-identify de-identified data provided to us if that was not the intended purpose for the data or without providing proper notice to you.
We may share the personal information we obtain about you with our affiliates and subsidiaries; our Bank Partners; other companies in connection with co-branded products, services or programs; joint marketing partners; research study partners; and consumer reporting agencies.
We also may share the information we obtain about you with vendors and other entities we engage to perform services on our behalf, such as payment and check deposit processors, fraud and risk detection and mitigation tools, and modeling and analytics tools.
We may share personal information you provide with other Coupon System members (including whether you are a Coupon System member, whether you accept payments or direct deposits via Coupon System, your profile picture, name, or other information you provide as part of our public Coupon System Profile).
We also may disclose personal information and sensitive personal information (1) if we are required to do so by law or legal process (such as a court order or subpoena); (2) in response to requests by government agencies, such as law enforcement authorities; (3) to establish, exercise or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (5) in connection with an investigation of suspected or actual illegal activity; (6) to defend our decisions related to a member dispute; (7) in connection with the sale, transfer, merger, acquisition, joint venture, reorganization, divestiture, dissolution, or liquidation of our business or asset; or (8) otherwise with your consent.
We offer you certain choices in connection with the personal information we collect from you.
Communications preferences: You can choose to not receive certain promotional communications from us by following the "unsubscribe" hyperlink at the bottom of promotional emails or by replying "STOP" to promotional texts. These choices do not apply to certain informational communications, including certain surveys and mandatory service communications. If you decide you do not want to receive push notifications from Coupon System, you can use the settings on your mobile device to turn them off. We also offer push notifications on certain web browsers, which can also be turned off on your browser's settings.
Submitting an opt-out or privacy request: Different states offer different opt-out rights and Coupon System makes it easy for you to submit an opt-out or privacy request. You can also email us at privacy@couponsystem.com. If you designate an authorized agent to make an access or deletion request on your behalf, we may require you to provide proof that you've authorized the agent to do so and to verify your own identity directly with us.
We maintain administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized access, destruction, loss, alteration, disclosure or use. To help us protect personal information, use a strong password and never share your password with anyone or use the same password with other sites or accounts.
Our Services are not directed to children and you must be 18 or older to open an account with us. In connection with the Services, we do not knowingly solicit or collect personal information from children under the age of 13 without parental consent. If you believe that a child under age 13 may have provided us with personal information without parental consent, please contact us as specified in the How To Contact Us section of this Privacy Notice.
We may update this Privacy Notice from time to time and without prior notice to you to reflect changes in our personal information practices or applicable law. We will indicate at the top of the Notice when it was most recently updated.
You can submit a request or ask us questions about this Privacy Notice by writing to us at privacy@couponsystem.com.
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