PRIVACY POLICY

Aramis Interactive, LLC

Updated December 2019

1. INTRODUCTION

1.1. PURPOSE OF THIS POLICY. Aramis Interactive, LLC and its subsidiaries and affiliates, as applicable (hereafter, “Aramis,” “us,” “we,” “our” or “Company”), are committed to respecting the privacy rights of customers, visitors, and other users of our websites or mobile applications, and their features, products and services, including, but not limited to, providing samples, coupons, offers, specials, deals, and other items, delivering content, and conducting surveys, sweepstakes, contests, giveaways, and other promotions.(Our websites and mobile applications and their features, products and services are individually and collectively referred to as, the “Site”). We created this Privacy Policy (this “Policy”) to give you confidence as you visit and use the Site, knowing that you care how information about you is used and shared.

1.2. CONSENT. By visiting or browsing the Site, you consent to Company’s collection, use, storage, deletion, transfer to the United States, and disclosure of personal information relating to you as set forth in this Privacy Policy.

What information do we collect about you and how do we collect it?
What choices do you have about the collection and use of your personal information?
What security measures do we take to safeguard your personal information?

2. INFORMATION COLLECTION PRACTICES

2.1.HOW DO WE COLLECT INFORMATION?

In operating the Site, we may request or invite user registration and logins, invite participation in online surveys and promotions, and provide various other online forms that invite users to provide certain information.In addition, if you communicate with us by e-mail or other means, any information provided in such communications may be collected by us. In addition, our servers automatically collect certain types of information relating to your interactions with the Site.

2.2. WHAT INFORMATION DO WE COLLECT?

(a) PERSONAL INFORMATION.

In operating the Site, we collect information that can be used to identify or contact the user (“Personal Information”), including information that falls within the following categories: (1) “Contact Information and Identifiers,” such as a user’s first and last name, e-mail address, mailing address, shipping address, zip code, phone number, geolocational information, voice, or photograph or other likeness; (2) “Account Information,”such as a username, password, and password reminder questions and answers; (3) “Characteristics of Protected Classifications and other Demographic Information,” such as age, gender, ethnicity, religious preference, marital status, and date of birth; (4) “Commercial Information,” such as purchasing or consuming histories; (5) “Inferences Drawn from Personal Information,” such as preferences, behaviors, and predispositions; (6) Internet or Other Electronic Network Activity,” such as browsing history within the Site, including access times and length of use; and (7) “Financial Information,” such as credit or debit card information, annual income, and identity verification information.

(b) ADDITIONAL INFORMATION

(1) Traffic Data.The Site may also gather anonymous “traffic data” that does not personally identify you, but which may be helpful for marketing purposes or for improving your experience on the Site.

(2) Cookies. The Site uses the standard “cookies” feature of major browser applications that allows us to recognize your browser and store a small piece of data on your computer or device about your visit to our Site. We do not set any personally identifiable information in cookies. For information on how this information is used, please refer to Section 3.3(c) below.

If you do not wish to accept cookies, you may change the setting on your browser.However, if you choose to disable this function, your experience at the Site may be diminished, and some features may not work as they were intended. For instance, without cookies you may not be able to receive free products, samples, information, offers, specials, deals or other items that are relevant to you.

3. USE AND SHARING OF COLLECTED INFORMATION

3.1. HOW DO WE USE YOUR PERSONAL INFORMATION?

(a) BUSINESS PURPOSES. We may use your Personal Information for certain business or commercial purposes, including, but not limited to:(1) performing our services and providing customer service, including: (i) to verify your identity; (ii) to send you commercial or marketing messages and communicate offers and promotions sponsored by us, our affiliates, and other third parties; (iii) to process orders, including billing and payment processing, or to send samples, coupons, and other items; (iv) to follow up with regard to specific transactions, comments, feedback, questions or inquiries initiated on the Site; and (v) to contact you for customer or technical support; (2) auditing for quality and positioning of ad impressions; (3) monitoring use of Site to enable us to customize and tailor your experience by delivering targeted advertisements and other content specific to your interests; (4) undertaking activities to verify or maintain the quality of products or services offered though the Site; (5) detecting security incidents; and (6) debugging to identify and repair errors; and (7) internal research to help us improve use of the Site or products or services offered through the Site;

(b) WEBSITE.We may display your Personal Information in your profile page and elsewhere on the Site according to the preferences you set in your account.Any information you choose to provide should reflect how much you want others to know about you.Please consider carefully what information you disclose in your profile page and your desired level of anonymity.We may also share or disclose your information if, for example, you use a third-party application to access your account.Through certain features of the Site, you may also have the ability to make some of your information public.Public information may be broadly and quickly disseminated.

(c) SWEEPSTAKES, CONTESTS, AND PROMOTIONS. If you opt to participate in sweepstakes, contests or other promotions (any, a “Promotion”), you agree to the terms, conditions or official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your Personal Information, such as name, voice, likeness or other recognizable aspect of persona in advertising, promotions or marketing associated with the Promotion. If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list.

(d) In addition, we may use your Personal Information in the following ways:

(1) Significant Announcements. If you are a registered user of the Site, we may use your registered name and e-mail address information to inform you via e-mail message of any significant changes to the Site or Company, to any user account you may create, or other significant information that may affect your use of the Site. We may also communicate with you about privacy, security or administrative issues relating to your use of the Site. You cannot opt-out of these kinds of e-mail messages.

(2) Mobile Communications. If you choose to opt in, we may also use your mobile phone number information that you provide on the Site to send you information about various promotions and other types of offers from us.

(3) Push Communications. If you choose to opt in, we may also use browser notifications to send you information about various promotions and other types of offers from us.

If you do not wish to receive these kinds of communications from us, you can opt out by un-checking the appropriate email announcement boxes during registration, by changing your user account, or by emailing us at the address provided in this Privacy Policy. In addition, you will have regular opportunities to opt out of receiving such information from us by following the unsubscribe instructions in email messages or mobile communications we may send to you.

3.2.DISCLOSURE OF PERSONAL INFORMATION TO OTHERS

(a) PROCESSING. We may use an outside shipping company to ship orders, a credit card company or payment processor to process payments for products and services, and other business partners to perform core services (such as hosting, billing, fulfillment, or data storage and security) related to our operation of the Site. Any of these various third parties may be authorized to use your Personal Information in accordance with our contractual arrangements with such third parties and in accordance with their own privacy policies, over which we have no control, and you agree that we are not responsible or liable for any of their actions or omissions. We authorize these third parties to only access and use your Personal Information to perform their functions.

(b)PRODUCTS AND SERVICES. Company may partner with other third parties to provide specific products and services on the Site. When you sign up for such products or services, we will share your only the Personal Information that is necessary for the third party to provide these products or services. We do not authorize the third party to use Personal Information except for the purpose related to these products or services.

(c) SALE OF PERSONAL INFORMATION. [We must say what categories we sell for a business purpose and what categories we disclose for a business purpose, or state that we do not sell or disclose Personal Information for a business purpose (this does not include third parties we use for processing, etc.).]

(think needs to be link to another site for opt out)

You have the right, at any time to opt out of the sale of your Personal Information to third parties by clicking on the link posted on our Site, or the one here, labeled “Do Not Sell My Personal Information.”

(d) NO DISCRIMINATTION FOR OPT OUT. If you exercise your right to opt out of the sale of your Personal Information, we will not discriminate against you by, including, but not limited to:(1) denying you goods or services; (2) charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; (3) providing a different level or quality of goods or services to you; or (4) suggesting that you will receive a different price or rate or different level of service. However, we are not prohibited from charging a different price or rate, or providing a different level or quality of goods or services, if that difference is reasonably related to the value of the data you provide. Nor are we prohibited from offering financial incentives for the collection or sale of Personal Information.

(d) LEGAL PURPOSES. We may disclose Personal Information and information concerning your use of the Site if required to do so by law or in the good-faith belief that such action is necessary (1) to conform to the edicts of the law or comply with legal process served on Company or its parent company, subsidiaries or affiliates (for example, pursuant to a statutory demand, subpoena, warrant or court order), (2) to protect and defend the rights or property of Company or the users of the Site, (3) to protect against fraudulent, abusive or unlawful use of the Site, (4) to enforce any contract between you and Company, or (5) to act under what Company reasonably believes to be exigent circumstances to protect the safety of the public or users of the Site.

(e) BUSINESS TRANSFERS. In order to accommodate changes in our business, we may merge with companies, or sell or buy companies or assets of companies, including the information collected through the Site. If Company, a line of business of Company, or substantially all the assets of Company is acquired, customer information will be one of the assets transferred to the acquirer. Company reserves the right to disclose and transfer all information collected through the Site: (1) to a subsequent owner, co-owner or operator of the Site or applicable database; or (2) in connection with a corporate merger, consolidation, restructuring, the sale of certain of Company ownership interests, assets, or both, or other company change, including, without limitation, during the course of any due diligence process. In addition, Company may share the information collected through the Site with its parent company, subsidiaries, and affiliates, primarily for business and operational purposes.Should such an event occur, Company will use reasonable means to notify you through a prominent notice on the Site.By sharing your Personal Information with Company, you are giving Company consent to transfer your Personal Information to a third party in an asset transfer described here.

3.3 WHAT DO WE DO WITH OTHER COLLECTED INFORMATION?

(a) ANONYMOUS INFORMATION. We use anonymous information to analyze our Site traffic and usage information, record transactions, and gather demographic information, but we do not examine this information for individually identifying information. In addition, we may use anonymous IP addresses and unique identifiers to help diagnose problems with our server, to administer the Site, or to display content according to your preferences.

(b) DE-PERSONALIZATION.We may make your Personal Information non-personally identifiable by either combining it with information about other users (aggregating your Personal Information with information about other users), or by removing characteristics (such as your name or email address) that make the information personally identifiable.This process is known as de-personalizing your information.You grant us a royalty-free, worldwide, perpetual, irrevocable and fully transferable right and license to use your Personal Information in connection with the creation and development of analytical and statistical analysis tools relating to the use of the customer data we collect on the Site.

(c) COOKIES. We may use cookies (1) to deliver content specific to your interests; (2) to save your password so you don’t have to re-enter it each time you visit the Site; (3) to help us remember and process items in your shopping cart; (4) to measure the effectiveness of the Site, our various offers, products, services and advertising; (5) to keep track of promotions and advertising; (6) to improve navigation and other features of the Site; (7) to promote trust and safety on the Site; or (8) to provide features and services that are available only through the use of cookies. From time to time, some business partners and advertisers may use cookies on the Site . We do not have access to or control over information collected by use of these cookies.

(c) “DO NOT TRACK” SIGNALS.Because we do not collect user information about your online activities over time and across different websites or authorize third parties to do so, we do not respond to “Do Not Track” signals.

4. SECURITY

The Personal Information you provide to us is stored on servers that are located in secured facilities and protected by protocols and procedures designed to ensure the security of such information. In addition, Company employees and agents who have access to your Personal Information are trained in the maintenance and security of that information.However, no server, computer or communications network or system, or data transmission over the Internet can be guaranteed to be 100% secure.As a result, while we strive to protect user information, we cannot ensure or warrant the security of any information you transmit to us or through the Site and you acknowledge and agree that you provide such information and engage in such transmissions at your own risk.Once we receive a transmission from you, we will endeavor to maintain its security on our systems.

5. CONTROL OF AND ACCESS TO INFORMATION

5.1 REQUEST FOR DISCLOSURE REGARDING PERSONAL INFORMATION.You have the right to request and receive the following by contacting us at the email address provided below in this policy:

(a) categories of Personal Information collected about you

(b) categories of sources from which the Personal Information has been collected

(c) the specific pieces of Personal Information collected about you

(d) the categories of third parties to whom the Personal Information was shared or sold (by individual category of information)

(e) the categories of Personal Information we have shared or sold for a business purpose

(f) the business or commercial purposes for collecting and/or selling the Personal Information

5.2CORRECTION, UPDATE, AND DELETION OF PERSONAL INFORMATION. We maintain a procedure in order to help you confirm that your Personal Information remains correct and up-to-date. Following registration, you can sign in to your user account and visit your personal profile page, where you can deactivate your user account, or review and update your personalized preferences and registration information, such as: name, mailing address, shipping address, e-mail address, password, and e-mail notification settings and preferences.(In addition, many of the mailings Company may send you, such as newsletters, contain an “unsubscribe” feature to allow you to opt out of future mailings.)

You can also request that we correct, update or remove Personal Information from our database by contacting us as provided below in Section 6.1 . We will remove the Personal Information and direct our service providers to remove the same from their records.We may retain in our files information you have requested be removed from our active databases for certain purposes, such as to resolve disputes, troubleshoot problems and enforce our terms and conditions. Further, such prior information may never be completely removed from our databases due to technical and legal constraints, including stored “back up” systems. Therefore, you should not expect that all of your Personal Information to be completely removed from our databases in response to any request you may submit.

5.3. LOST OR STOLEN INFORMATION. If you lose control of your password, you may lose substantial control over your personally identifiable information and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised in any way, you should immediately change your password.

5.4. NO REQUIREMENT TO PROVIDE INFORMATION TO USE THE SITE. You acknowledge and agree that any information or content that you post to the Site is public, not private, and that you have no expectation of privacy with regard to such information and content. If you choose to make any of your personally identifiable or other information publicly available through or in connection with your use of the Site, you do so at your own risk. Because any information that you post to the Site may be seen and used by others, Company encourages you not to disclose any personally identifiable information through your posts to the Site.

6. CONTACT INFORMATION AND POLICY UPDATES

6.1. CONTACT US.

If you have any questions about this Policy, questions about our practices related to this Site, or if you would like to send a request for disclosures regarding your Personal Information or a request to have us correct, update or remove your information from our database, please contact us via email at ccpa@shareyourfreebies.com.

6.2. POLICY UPDATES AND CHANGES.

If we decide, at any time, to add to, change, update, or modify this Policy, we will post such change, update, or modification on this page and update the “Effective Date.” Any such change, update, or modification will be effective immediately upon posting the updated Policy. We will notify you of any material changes to the Policy by placing a notice on the Site or sending a notice to the primary email address specified in your user account. It is your responsibility to review this Policy when visiting the Site to ensure that you continue to agree with all of its terms. If at any point you do not agree to any portion of the Privacy Policy then in effect, you must immediately stop using the Site.

7. VISITORS FROM OUTSIDE THE UNITED STATES

The Site’s offices are located in the United States. If you visit the Site from another country, please be aware that information you provide to us or that we obtain as a result of your use of the Site may be processed in and transferred to the United States and will be subject to U.S. law. U.S. privacy and data protection laws may not be equivalent to the laws in your country of residence. By using the Site, you consent to the collection, transfer, storage, and processing of information to and in the United States.

8. GOVERNING LAW

This Privacy Statement is governed by, and construed under, the laws of the United States of America and the laws of the State of Texas, excluding its choice of law provisions.

Mediation. You agree that, in the event any dispute or claim arises out of or relating to this Privacy Statement, you and Company will attempt in good faith to negotiate a written resolution of the matter directly between the parties. You agree that if the matter remains unresolved for forty-five (45) days after notification (via certified mail or personal delivery) that a dispute exists, all parties shall join in mediation services in Tarrant County, Texas with a mutually agreed mediator in an attempt to resolve the dispute. Should you file any arbitration claims, or any administrative or legal actions without first having attempted to resolve the matter by mediation, then you agree that you will not be entitled to recover attorneys’ fees, even if you would otherwise be entitled to them.

9. EU-US Privacy Shield

Company participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles.

Company is subject to the investigatory and enforcement powers of the Federal Trade Commission. In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, Company is potentially liable. Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

In compliance with the Privacy Shield Principles, Company commits to resolve complaints about our collection or use of your Personal Information.EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Company at the address provided in this Privacy Policy.

Company has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.jamsadr.com/file-an-eu-us-privacy-shie... for more information or to file a complaint.The services of JAMS are provided at no cost to you.

To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

10. TERMS OF USE

Please read the Terms of Use governing the use of the Site.