Privacy Policy

Updated: [August 24, 2018]

This Privacy Policy describes how Frenzy Labs Inc. (“we,” “us,” “our,” “Company”) collect, use, share, and protect information in connection with the Company websites, mobile websites, mobile applications, browser applications, and any related services that refer or link to this Privacy Policy (“Services”).

1. COLLECTION OF INFORMATION.

User-provided information

We collect, process, and use your information when you:

  • Register for our Services or sign in to an existing account
  • Visit our website(s)
  • Access our Services through our application(s)
  • Connect to our Services using third-party accounts, such as your email, social media, or payment account(s)
  • Contact us for support
  • Participate in our shopping or influencer programs
  • Enter a sweepstakes, contest, promotion, survey, or poll

Automatically collected information

We and our service providers automatically collect certain information about you through:

  • Interaction with our Services
  • Cookies and other tracking technologies
  • Location-identifying technologies
  • Monitoring and analyzing trends, usage, and activities

The types of information you provide may include Personal Information. “Personal Information” means information that can be used to identify you (whether alone or in combination). The Personal Information you may provide to us includes:

  • First and last name
  • Email address
  • Mailing address
  • Phone number
  • Website URL
  • Website Name
  • Payment information (such as payment account name, payment account number, payment card expiration date, and billing address)

We may also collect Personal Information and other information based on your use of the Services:

  • The nature of the product or service requested or purchased
  • How you connect to our Services, such as your IP address, unique device identifiers, device or session IDs, and information regarding the network and connected hardware (e.g., computer or mobile device)
  • Browsing, shopping, and purchase history
  • Your geolocation
  • Click-stream data (the page-by-page paths you take as you browse through our Services)

2. USE OF INFORMATION WE COLLECT. WE MAY USE INFORMATION ABOUT YOU IN THE FOLLOWING WAYS:

Manage Your Account

If you provide us with Personal Information, we may use it to: (i) process your registration with our Services, including verifying whether your email address is active and valid and enrolling you into our programs; (ii) monitor and manage your account; (iii) track your shopping, deliver you any rewards or payments, and identify opportunities for rewards and/or offers; (iv) send you technical notices, updates, security alerts, and administrative messages; (v) provide you customer service regarding your account and reply to your questions, comments and requests; (vi) and (vi) comply with legal and regulatory provisions in force and with the competent judicial authorities in each geographical jurisdiction that the Company operates in. We may also use your information to assess risk and prevent fraud.

Improve Our Services

We may process information through analyzing and monitoring usages and trends and performing statistical analyses to improve our Services and the websites, applications, marketing efforts, and the products and services of our affiliates to provide a better service to you in the future. We may also use this information to adapt Service content to be more likely to be of interest to you.

Provide You Marketing Information

To provide you more personalized offers and/or special offers, discounts and similar information, Company may send you newsletters, rewards, discounts, promotion codes, events, and general information about the Service if you consent. To match your profile and interest, we may create a profile of your preferences and provide advertisements, content or features. You can manage these communications in accordance with Section 4 (Your Choices) below.

Administer Contests, Sweepstakes, and Promotions

From time to time, Company may invite you to enter various contests, sweepstakes, surveys or promotions. If you choose to participate in a contest or promotion, your Personal Information may be used to administer the contest, such as to determine your eligibility for the contest or to award a prize.

3. SHARING OF INFORMATION.

We may share the information we collect, including your Personal Information, with third parties under the following circumstances.

Service Providers and Business Partner

We do not sell your Personal Information and only share it with third parties to operate our Services. We may share your Personal Information with our service providers that perform marketing services and other business operations on our behalf, under our instructions and in compliance with appropriate technical and organizational security measures to protect your data. For example, we may partner with other companies to provide you support services, authentication services, prevent fraud on our Services, administer our promotions, referral programs, sweepstakes, and surveys, perform analytics, maintain the accuracy of our databases, fulfill your product purchases, and administer your rewards or payments. We will not sell your Personal Information, but we may rent, sell, and share other information that cannot be used to identify you with merchant partners, third parties, or affiliates. Information that we may rent or sell will not include your Personal Information and will not include payment information.

Protection of Rights and Other Legal Purposes

We may share the information we collect, including Personal Information, to the extent permitted by applicable law, (i) in response to subpoenas or other legal process or if in our good faith opinion such disclosure is required or permitted by law; (ii) at the request of governmental authorities conducting an investigation, including, but not limited to, meeting law enforcement requirements; (iii) to defend our terms and conditions or other policies applicable to our Services; and (iv) to protect the rights, property, life, health, security and safety of us or any third party.

Business Transfers

We may share the information we collect, including Personal Information, with any third party in connection with, or during negotiations of, any proposed or actual merger, purchase, sale (including a liquidation, realization, foreclosure, or repossession), or any other type of acquisition of all or any portion of Company assets, conveyance or transfer of all or a portion of our business to another company.

4. YOUR CHOICES

You may in some cases have the option to decline providing us information. However, your choice to not provide information may impact your use of certain features or services. You may unsubscribe or opt out of receiving marketing emails from us by using the unsubscribe link on the footer of our marketing emails or by contacting us. Upon written request, we will provide you with information on whether we hold any Personal Information. We encourage you to maintain the accuracy of the information you submit to us, such as the information you provide us to register for your account. The Services may allow you to access, review, correct, update, and remove or make inaccessible Personal Information you have provided through your account settings. You may provide account updates and changes by contacting us. We will make good-faith efforts to make requested changes in our then-active databases as soon as reasonably practicable. We will respond to your requests within a reasonable timeframe.

5. RIGHTS APPLICABLE TO EU USERS

Data Transfers

If you are visiting from the European Union (“EU”) or other regions with laws governing data collection and use that may differ from EU or United States law, please note that you may be transferring your Personal Information to Frenzy Labs Inc. in the United States and in other countries around the world for the purposes described under this Privacy Policy. We take great care in protecting your Personal Information and have put in mechanisms to protect it when it is transferred internationally.

Legal basis for using your Personal Information

If you are a visitor from 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. For the European Economic Area, there are different legal bases that we rely on to use your Personal Information, namely:

  • Performance of a contract. The use of your Personal Information may be necessary to perform the terms and conditions or other policies under which we provide our Services.
  • Consent. We will rely on your consent to use (i) technical information such as cookie data and geolocation data; and (ii) your Personal Information for marketing purposes. You may withdraw your consent at any time by contacting us using the information at the end of this Privacy Policy or by following an unsubscribe link in any marketing communication you receive from us.
  • Legitimate interests. We may use your Personal Information for our legitimate interests to improve our Services, security purposes, and fraud prevention, and to share information with our affiliates for internal administration. In such circumstances it is for us to ensure that these interests are not overridden by your data protection interests or fundamental rights and freedoms. If we collect and use your Personal Information in reliance on our legitimate interests (or those of any third party), this interest will normally be for to operate our platform and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

Choices under EU law

If your Personal Information is subject to the protections offered by EU law, you may:

  • Access, correct, update or request deletion of your Personal Information, at any time by contacting us;
  • Object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information;
  • Withdraw your consent at any time if we have collected and process your Personal Information with your consent;
  • 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, Switzerland and certain non-European countries (including US and Canada) are available here.)

To exercise any of these rights please contact us in accordance with the contact details set forth below in Section 14 below. Please note that if you are not subject to EU law, these rights do not apply to you.

6. DATA SECURITY AND RETENTION.

We take reasonable measures to protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Although Company uses reasonable efforts to help protect your information, transmission via the Internet is not completely secure and Company cannot guarantee the security of your information collected through our Services. Except as otherwise set forth under applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our control. We retain the information collected via our Services until such time as you choose to close your account. After that time, we may aggregate the data and retain it for analytical purposes. We may also retain your information on backup media to comply with applicable law, to support financial audits, to resolve disputes, to maintain compliance efforts, and for other legitimate business reasons.

7. PROMOTIONAL COMMUNICATIONS.

By signing up for an account, you may receive periodic emails from Company. If you consented to receiving promotional email communications, you can opt out of receiving such communications from us at any time by (i) following the instructions provided in those communications; or (ii) contacting us through the Services. Please note that even if you opt out of receiving promotional communications, we may continue to send you non-promotional emails and other types of communications, as permitted by law, such as service emails relating to our ongoing business relationship. Service emails contain service-related announcements that affect your account, such as product order confirmations, reward or payment updates, and responses to your comments and feedback submitted to us.

  1. COOKIES.

We and our partners use cookies and similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. We use cookies for many purposes, including, without limitation, authentication, tracking user preferences or web pages visited while using our Services. You may control the use of cookies at the browser level. If you choose to disable cookies, it may limit your use of certain features or functions on the Service.

9. ANALYTICS, TARGETING, TRACKING.

We, and third parties with which we partner, may also use cookies, pixels, and other technologies to automatically collect information about your use of the Services, such as your click-stream data, browsing history, IP address, web browser, pages viewed, time spent on pages, links clicked, and conversion information. Data collected from a particular browser or device may be used with another computer or device that is linked to the browser or device on which such data was collected (also known as cross-linking).

  1. THIRD-PARTY DATA.

The Services contain hyperlinks to websites of merchants and retailers and other websites or locations that we do not control and are operated and controlled by third parties (“Third-Party Websites”). Our Privacy Policy does not apply to these Third-Party Websites and we make no representations regarding the policies or business practices of any such Third-Party Websites.

11. SOCIAL FEATURES.

Certain functionalities on the Services are specifically designed to permit interactions that you initiate between the Services and third-party websites or services, including third-party social networks (“Social Features”). Examples of Social Features include features that enable you to transmit your account content from a third-party website or service to our Services; to “like” or “share” our Services’ content on other websites or services; to sign in to the Services using your username and password from a third-party site or service; and to connect our Services with a third-party website or service. If you choose to use Social Features, the information you post or provide access to may be used by us and/or publicly displayed on our Services or by the provider of the Social Feature that you use. Similarly, if you post information on a third-party platform that references our Services (e.g., by using a hashtag associated with Company in a tweet or status update), your post may be published on our Services in accordance with the terms of the third-party website or service. When you use our Services with a third-party site or service, both Company and the third party may have access to certain information about you and your use of our Services and the third-party site or service. In addition, we may receive information about you if other users of a third-party website give us access to their profiles and you are one of their “connections,” or information about you is otherwise accessible through your connections’ web pages, profile pages, or similar pages on a social-networking or other third-party website or interactive service. The information we collect in connection with Social Features is subject to this Privacy Policy. The information collected and stored by the third parties remains subject to those third parties’ privacy policies, including whether the third parties continue to share information with us, the types of information shared, and your choices with regard to what is visible to others on those third party websites or services.

12. REFERRAL PROGRAMS.

Company may offer features which allow you to inform an individual about our Services. If you choose to use our referral features, we will ask you for your referral’s email address to send them an electronic communication inviting them to join our Services. Company will store this information for the sole purpose of sending this email and tracking the success of our referral program. If you choose to participate in our referral programs, you represent and warrant that you have a personal relationship with your referral and that you are authorized to share their information with Company for the purpose of sending this communication to invite them to join the Services. If you believe that one of your contacts has provided us with your Personal Information and you would like to request that it be removed from our database, please contact us at info@frenzy.ai.

13. CHANGES TO PRIVACY POLICY.

This Privacy Policy is current as of the date set forth above. Company reserves the right to change this privacy policy from time to time consistent with applicable privacy laws and principles. If we make changes to this Privacy Policy we will notify you by revising the date at the top of this Privacy Policy, and where such changes will impact you as a data subject, we will provide you with additional notice (such as adding a statement to the homepages of our Services or sending you an email notification).

14. CONTACT US.

If you have any questions regarding this Privacy Policy, please feel free to contact us by email at info@frenzy.ai or by mail at 3670 Trousdale Pkwy, Los Angeles, CA 90089-0057 USA ATTN: Frenzy Labs, Inc.