Engage3, Inc. (hereinafter referred to as “Engage3,” “we” or “us“) strongly believes in maintaining the privacy of information we collect about individuals. We want you to understand how and why we use and disclose the information we collect from you. This Policy describes our practices and procedures for protecting the privacy and security of nonpublic personal information that we have collected about you.
INFORMATION WE COLLECT
Information That We Obtain From You. We receive and store any information you enter or submit on or through the Site.
This includes information that can identify or contact you (“personal information“), including your first and last name; your email address; your current location, including zip code, city and state; and any other non-public information about you that is associated with or linked to any of the foregoing information.
We may also receive and store other information from you, including your recommendations, evaluations, survey responses, feedback, and forum submissions; information that you submit through our mobile application, including in-store pricing and photos of products; store-related information that you provide to us or to which you grant us access, including grocery membership information, loyalty card numbers, grocery store logons, and purchasing history; and information about your purchasing preferences, including which products you search for and purchase on a regular basis, products that you have denoted as among your favorites, your store preferences and your attribute settings (including allergens, diet preferences, etc.).
You can choose not to provide information to us, but in general some information about you is required in order for you to sign up as a user of the Engage3 service, complete a shopper profile, ask us a question, or fully utilize our services or products. You may opt out of having personal information used for secondary purposes by selecting the appropriate opt-out box online or the “unsubscribe” link on our emails to you.
Please note, we do not control communications between you and other third parties. Please refer to such third parties in order to determine their opt-out procedures.
Information That We Obtain From Other Sources. We also may periodically obtain both personal and non-personal information about you from affiliated entities, business partners and other independent third-party sources.
Automatically-Collected Information. We automatically collect some information about your computer or other device when you access or use the Site, including your IP address, Web browser software (such as Firefox, Safari, or Internet Explorer), and access times. We also may collect information about your shopping and web browsing activity, including products viewed and referring website addresses.
We may, directly or through our contractors, store information on your computer or other device in the form of a “cookie” or similar file for purposes of enhancing your experience on the Site, such as by personalizing the Site, tailoring web content to your interests, recording session information, securely storing sign in information, and tracking click stream data. If you choose not to accept our cookies, you may have to re-enter information when you revisit the Site and certain features and services of the Site may not work properly.
Our goals in collecting this automatic information include improving our products and services, customizing your user experience, and inhibiting fraud.
HOW WE USE YOUR INFORMATION
Lawful Basis for Processing Your Personal Information. If European data protection law applies and where Engage3 acts as a data controller, our lawful basis for collecting and using the personal information described in this Notice will depend on the type of personal information concerned and the specific context in which we collect or use it.
We normally collect or use personal information only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may have a legal obligation to collect or retain personal information or may need the personal information to protect your vital interests or those of another person. For example, when we:
- Use personal information to create and manage an account, we do so in order to provide you with relevant Services and perform our contract with you.
- Use names and email addresses for email marketing purposes, we do so with your consent (which you can withdraw at any time) or, where permitted under applicable law, on the basis of our legitimate interests.
- Gather usage data and analyze it to improve our Services or ensure the security of our websites, we do so based on our legitimate interest in safeguarding and improving our Services.
If you have questions about or need further information concerning the lawful basis on which we collect and use your personal information, please contact us at Privacy@engage3.com. Note that in situations where Engage3 acts as a processor, it is our customer who determines the appropriate legal basis associated with processing activities, and queries about the applicable lawful basis should be directed to them.
RETENTION OF PERSONAL INFORMATION
We keep your personal information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain personal information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws as set out in our data retention policy and information handling standards. Generally, this means we retain your personal information to comply with any retention or statutory limitations or for purposes of performing a contract with you. Where there are technical limitations that prevent deletion or anonymization, we safeguard personal information and limit active use of it.
INFORMATION WE DISCLOSE
We may share your personal information with third party vendors who provide services or functions on our behalf, including business analytics, customer service, and fraud prevention. We may also authorize third party vendors to collect information on our behalf, including as necessary to operate features of the Site or to facilitate the delivery of online advertising tailored to your interests. Our third party vendors have access to and may collect information only as needed to perform their functions and are not permitted to share or use the information for any other purpose. They are also required to follow substantially comparable security practices that we ourselves adhere to.
We also may share your loyalty card numbers and information related to coupons and offers you receive with third parties for purposes of providing you with such coupons and offers.
We also may share aggregate or anonymous information in our discretion with third parties, including advertisers, investors, manufacturers, retailers, and other business partners. For example, we may tell our advertisers the number of visitors the Site receives or the most popular products. This information does not contain any personal information and is used to develop content, products, and services we hope you will find of interest.
THE RIGHT TO VERIFY THE ACCURACY OF INFORMATION WE COLLECT
Keeping information accurate and up to date is important to us. Individuals may see and correct their personal information that we collect except for information relating to a claim or a criminal or civil proceeding. You can access and update your contact information and preferences by accessing the Site’s user profile page. For deletions, please contact us at Privacy@engage3.com
CONFIDENTIALITY AND SECURITY
We restrict access to personal information on our servers to our authorized personnel and contractors. We maintain appropriate physical, electronic, and procedural safeguards to protect the personal information we collect. Despite these measures, however, Engage3 cannot guarantee the security of personal information, including information that is transmitted wirelessly or over public networks.
Upon creating an account, you will be assigned a sign in ID and a password that will allow you to access your personal information. For security purposes, we impose guidelines, such as a minimum password length, for passwords created by you, and we may require you to update and change your password after a certain period of time. It is important for you to protect against unauthorized access to your password and to your computer or other device. Be sure to sign off and clear caches when finished using a shared computer or other device. Engage3 is not responsible for any unauthorized access to your account by an individual who has obtained your sign in ID and/or password through no fault of Engage3.
Please note that any information you post or submit to a public bulletin board, blog or chat room is available to all persons accessing that location, and your e-mail address may also be posted on these venues. The information you share, including your email address, would then be available to all persons accessing these venues, and such information may be read, collected or used by others for any purpose, including sending you unsolicited messages. Engage3 is not responsible for any information you elect to submit in these venues or the use of such information.
INTERNATIONAL DATA TRANSFERS
Engage3 complies with certain legal frameworks relating to the transfer of data from the European Economic Area, the United Kingdom, and Switzerland (collectively, “EU”) to the United States. When Engage3 engages in such transfers, Engage3 relies on Standard Contractual Clauses as the legal mechanism to help ensure your rights and protections travel with your personal information. SCCs are contractual commitments between companies transferring personal data, binding them to protect the privacy and security of such data. Engage3 adopted SCCs so that the necessary data flows can be protected when transferred outside the EU to countries which have not been deemed by the European Commission to adequately protect personal data, including protecting data transfers to the United States.
This is a general audience Site and does not offer services or products directed to children. Should a child whom we know to be under 13 send personal information to us, we will use that information only to respond directly to that child that he or she is prohibited from accessing or using the Site.
APPLYING FOR A JOB ON OUR SITE
If you apply for a job through the Engage3 website, we, or a human resources company assisting us, may ask you to provide self-identifying information (such as gender, marital status, and ethnicity) in conjunction with laws and regulations enforced by local government and regulatory agencies. Providing self-identifying information is voluntary, but if you do provide us with that information, we may submit it to the local government and regulatory agencies for business-related purposes, including responding to information requests, fulfilling regulatory reporting requirements, and defending against employment related complaints.
If you have concerns about the way Engage3 is handling your User Personal Information, please let us know immediately. We want to help. You may contact us directly at firstname.lastname@example.org with the subject line “Privacy Concerns.” We will respond promptly — within 45 days at the latest.
DISPUTE RESOLUTION PROCESS
In the unlikely event that a dispute arises between you and Engage3 regarding our handling of your User Personal Information, we will do our best to resolve it. Additionally, if you are a resident of an EU member state or the UK, you have the right to file a complaint with your local supervisory authority, and you might have more options.
COMPROMISE OF PERSONAL INFORMATION
In the event that personal information is compromised as a result of a breach of security, Engage3 will promptly notify those persons whose personal information has been compromised, in accordance with the notification procedures set forth in this Statement, or as otherwise required by applicable law.
This Privacy Notice for California Residents (“CA Privacy Notice”) supplements the information contained in our Privacy Statement and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”).
CHANGES TO THIS POLICY