Global Marketing Partners LLC (“we,” “us,” “our”) work hard to build and maintain a relationship of trust with you. This Privacy Policy (the “Privacy Policy”) governs our collection, use, and disclosure of your Personal Information (as defined below) in connection with your use of our website(s) (“Site”) and any services, transactions, or other engagements you might have with us or with the companies on whose behalf we perform work (“Clients”) (collectively, the services we perform are referred to as “Services”).
This Privacy Policy explains what information we collect about you, how we use or disclose that information, how to exercise any rights you may have with respect to your Personal Information (defined below), and the safeguards we have in place to reduce the risk of unauthorized access and use.
Please carefully read this Privacy Policy, which is part of our Terms of Use, before using our Site and/or Services. If you do not agree with the Terms of Use and/or this Privacy Policy, you must refrain from using our Site and/or Services. By Accessing or using our Site and/or Services you agree to our use of your information consistent with the Terms of Use and this Privacy Policy.
TABLE OF CONTENTS
PRIVACY POLICY CHANGES
This Privacy Policy is subject to change. We encourage you to review this Privacy Policy frequently for any revisions or amendments. Changes to this Privacy Policy will be posted on this Site and will be effective immediately upon posting. You will be deemed to have been made aware of and have accepted the changes by your continued use of our Site or Services. If we determine that a change to this Privacy Policy will result in using your Personal Information acquired before the change in a materially new way, we will provide you notice before using your Personal Information in the new way.
CONFLICT BETWEEN THIS POLICY AND LOCAL LAWS AND REGULATIONS
When federal, state, and local laws and regulations require a higher level of protection for your Personal Information, they take precedence over this Privacy Policy. In addition, the specific requirements of this Privacy Policy apply only when local laws and regulations permit.
INFORMATION WE COLLECT AS A BUSINESS
Personal Information
We collect information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”), including:
The types of Personal Information we collect about you may vary based on how you use the Site and/or Services and your relationship with us.
Business Information
We also collect information about businesses and their representatives that engage with us such as EIN, TIN, address, phone number, email address, bank account information (collectively, “Business Information”). This information is generally not considered Personal Information because it relates to a business or a business contact.
Usage Data and Site Activity
We, or our third party providers automatically collect information in connection with the actions you take on the Site (“Usage Data”). For example, each time you use the Site, we automatically collect the type of web browser you use, the type of device you use, your operating system, your Internet Service Provider, the pages you view, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within the Site, and the duration of your visits to the Site. If this information is capable of being associated with you, directly or indirectly, we treat it as Personal Information. If this information is not capable of being individually associated with you, we treat it as Usage Data.
Communication Recordings
We may record calls and retain the content of text messages or other written/electronic communications between you and us. By communicating with us, you consent to our recording and retention of communications.
HOW WE COLLECT INFORMATION
Voluntary Disclosure
We may ask you to provide us with Personal Information when you communicate with us (online or offline), make a purchase from us, and at other times. You are not required to provide us your Personal Information; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of the Site or Services or we may not be able to fulfill your requested transaction.
Third-Party Data Sources
We may collect Personal Information from third-party data sources such as data brokerages, marketing/advertising agencies, analytics firms, telecommunications providers, Clients, and government agencies.
Cookies & Other Automated Tools
We use cookies (a small text file placed on your computer to identify your computer and browser) and other automated tools such as tracking pixels to improve the experience of the Site and Services, such as saving your preferences from visit to visit to present you with a customized version of the Website. Many web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. Instructions for how to manage cookies in popular browsers are available at: Internet Explorer, Edge, Firefox, Chrome, Safari (iOS), Safari (Mac), and Opera. However, certain features of the Site and Services may not work if you delete or disable cookies.
We use the following types of cookies:
We employ software technology that enables us to track certain aspects of a user’s visit to the Site. This technology helps us better manage content on the Site by informing us what content is effective, how consumers engage with the Site, and how consumers arrive at and/or depart from the Site. The software typically uses two methods to track user activity: (1) “tracking pixels” and (2) “clear gifs.” Tracking pixels are pieces of executable code that are embedded in a web page that track usage activity including which pages are viewed, when they are viewed, and how long the pages are viewed. Clear gifs are tiny graphics with unique identifiers which are embedded in web pages and email messages that track whether or not a user has viewed a particular web page or email message. User activity information may be associated with additional information about a user’s session and Personal Information, if provided by the user.
If you arrive at the Site by “clicking through” from another website, then certain information about you that you provided to that other website, such as the terms you were searching on that led you to the Site, may be transmitted to us and we may use it. You should review the Privacy Policy of any website from which you reached the Site to determine what information was collected by that website and for what purpose(s) you agreed that website could use that information. We may retain information about you provided to us by other websites and will only use it in accordance with this Privacy Policy. Such information may be associated with other Usage Data or Personal Information.
Interest-Based Advertising
We may work with third-party advertisers, search providers, and ad networks (“Advertisers”) to learn more about you and show you ads or other content that we believe would be relevant to you. Advertisers may collect and use information about your use of the Site or Services as well as other websites and services. These companies may use cookies and other online tracking technologies to collect and use your information. We and/or Advertisers may also append other data to the data collected by Advertisers to create an interest profile of individual users. Our Privacy Policy does not cover any use of information that an Advertiser may collect from you. Advertisements may be shown via the Site or on third-party websites. If you do not want to receive interest-based advertising, please visit the Digital Advertising Alliance (DAA) Consumer Choice Page. The DAA website allows you to opt-out of one or more interest-based advertising networks. Opt-outs are device and browser specific; therefore, you will need to set your opt-out preferences for each device and browser. Deleting browser cookies can remove your opt-out preferences; however, the DAA offers browser extensions that help preserve the opt-out preferences you set on the DAA's Consumer Choice Page. Please note that opt-outs only apply to interest-based advertising. You may still receive other types of online advertising.
Information from Advertisements
If you arrive at the Site via an advertisement (e.g., banner ad), we may collect information regarding the advertisement with which you interacted and your interactions (e.g., item clicked, date and time).
Surveys
From time to time we may request Personal Information from consumers via surveys. Participation in these surveys is completely voluntary and you have a choice whether or not to disclose Personal Information. The requested information typically includes personal identifiers and contact information.
Sweepstakes and Contests
We may offer opportunities for consumers to participate in sweepstakes or contests. Participation in these sweepstakes or contests is completely voluntary but participation usually requires providing certain Personal Information. The requested Personal Information typically includes unique identifiers and contact information.
Social Media Widgets
The Site may include social media features, such as the Facebook and Twitter widgets. These features may collect information about your IP address and the pages you visit on our Site as well as other Personal Information. A cookie may be set to ensure that a feature properly functions. Your interactions with features are governed by the privacy policies of the companies that provide them.
THIRD-PARTY PERSONAL INFORMATION COLLECTION ON SITE
Certain third parties collect Personal Information and/or Usage Data from users of our Site using automatic information collection tools such as cookies and tracking pixels. The collection, use, and disclosure of Personal Information and/or Usage Data by these third parties is governed by their privacy policies. The following third parties may collect Personal Information via our Site:
| Third Party | Privacy Policy |
|---|---|
| https://www.facebook.com/privacy/explanation | |
| https://policies.google.com/privacy?fg=1 | |
| Microsoft | https://privacy.microsoft.com/en-us/privacystatement |
| https://twitter.com/en/privacy |
HOW WE USE AND SHARE INFORMATION AS A BUSINESS
Generally
We use Personal Information for internal purposes, such as to:
Testimonials
If you provide a testimonial, we may post it publicly on the Site or in other advertising material. By providing a testimonial, you give us permission to use it in any manner and for any purpose, including in marketing and advertising communications.
Service Providers
We may provide your Personal Information to other businesses (“Service Providers”) to provide services to us or on our behalf. Categories of Service Providers we use include:
Each Service Provider is expected to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified by us.
We may share the following categories of Personal Information with one or more Service Providers: unique Identifiers; contact information; banking and financial information; commercial information; Internet & network information; inferences drawn from the foregoing categories of Personal Information.
Third-Party Sharing & Selling
We do not sell your Personal Information to other companies who do not provide services to us (“Third Parties”).
If you supply Personal Information to us in connection with the Savings Depot program, we may share your unique identifiers, contact information, and commercial information with United Marketing Group LLC to facilitate your participation in Savings Depot.
PERSONAL INFORMATION WE COLLECT AS A SERVICE PROVIDER FOR OUR CLIENTS
When acting on behalf of our Clients as a service provider, we may collect, use, and disclose Personal Information for the purpose of servicing those Clients. The specific categories of Personal Information collected and how that Personal Information is used or disclosed is determined by our Clients and will vary, and may include without limitation:
The Personal Information collected, used, and disclosed on our Clients’ behalf is governed by their privacy policies. When acting on behalf of a Client, we supply that Client with all information requested by them or consistent with their contract. This information is usually what is required to facilitate a specific transaction or operate a loyalty program but can vary depending on the Client. If you request information about the Personal Information we collect, use, and disclose on our Clients’ behalf, we will direct you to contact the Client(s).
SECURITY
We recognize the importance of safeguarding the confidentiality of Personal Information from loss, misuse, or alteration. Accordingly, we employ commercially reasonable administrative, technical, and physical safeguards to protect Personal Information from unauthorized access, disclosure, and use. Even with these safeguards, no data transmission over the Internet or other network can be guaranteed 100% secure. As a result, while we strive to protect information transmitted on or through our Site or Services, you do so at your own risk.
OTHER WEBSITES
Please be aware that third-party websites accessible through the Site or recommended through our Services may have their own privacy and data collection policies and practices. We are not responsible for any actions, content of websites, or privacy policies of such third parties. You should check the applicable privacy policies of those third parties when providing information.
COMPLIANCE WITH LAWS AND LAW ENFORCEMENT
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate to respond to legal requests (including court orders, investigative demands and subpoenas), to protect the safety, property, or rights of ourselves, consumers, or any other third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with law.
OTHER TRANSFERS
We may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with us. If we are merged, acquired or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction.
HOW LONG WE RETAIN YOUR DATA
We retain your Personal Information for as long as we have a relationship with you. We also retain your Personal Information for a period of time after our relationship with you has ended where there is an ongoing business need to retain it. This includes retention to comply with our legal, regulatory, tax, and/or accounting obligations. Generally, we retain Personal Information for approximately seven (7) years after our relationship with you has ended, but the term for which we retain your Personal Information may be longer or shorter. We do so in accordance with our data retention policies and applicable law.
CHILDREN’S PRIVACY
The Site and Services are not intended for children under the age of 16 and we do not knowingly collect Personal Information from children under the age of 16. If we become aware that we have inadvertently received Personal Information from a child under the age of 16, we will delete such information from our records.
ADDITIONAL CALIFORNIA CONSUMER RIGHTS
If you are a resident of California, you have additional rights to access and control your Personal Information, including a right to request that we disclose the Personal Information we collect, use, disclose, and sell, under the California Consumer Privacy Act. Because we act as a Service Provider to our Clients and may collect Personal Information in our capacity as a Service Provider to them, if your request relates to Personal Information that we collect or process on our Client(s)’ behalf, you must submit your request to exercise your rights to the relevant Client(s). If you submit a request to us, we will provide you with information about how to submit a request to the relevant Client(s).
Right to Know (Access)
You have the right to request twice per 12-month period that we provide you (i) the categories or specific pieces of Personal Information we collected about you; (ii) the categories of sources from which your Personal Information was collected; (iii) the business or commercial purpose for which we collected your Personal Information; (iv) the categories of Third Parties with whom we shared your Personal Information; and (v) the categories of Third Parties to whom we sold your Personal Information. We are not permitted to provide access to specific pieces of Personal Information if the Personal Information is sensitive or creates a high risk of potential harm from disclosure to an unauthorized person such as financial information, social security numbers, and driver’s license numbers.
To request access to your Personal Information and the information listed above, you may submit a request by emailing us at globalmembersvc@spotcheck.today or by calling us toll-free at 800-646-6072. If you submit your request via email, please include at least your name, mailing address, email address, and a description of your request. We will confirm receipt of your request within 5 business days.
After you submit your request, we may contact you to obtain additional information necessary to verify your identity. For example, we may require you to verify certain information in our files or submit a signed declaration under penalty of perjury verifying your identity. We will not process your request without verifying your identity, so please respond promptly. If you do not timely respond to our requests for information, we may deny your request.
We will process verified requests within 45 days of receipt, subject to any applicable exemptions and extensions permitted by law up to 90 days. If you request specific Personal Information and that information creates a high risk of potential harm from disclosure to an unauthorized person, we will withhold that information and replace it with a category identifier. For example, if we withhold a social security number, we will inform you that we have a social security number on file. If you have an online account with us, we will provide the response to your request via the online account, otherwise, we will give you the option to choose between mail and electronic delivery.
Right to Deletion
You have the right to request that we delete any Personal Information we have collected about you. Please understand that we are not required to honor a deletion request if a legal exemption applies such as if we need the information to complete a requested or reasonably anticipated transaction, prevent security incidents or fraud, enable internal uses that are reasonably aligned with your expectations, or comply with legal obligations.
To request deletion of your Personal Information, you may submit a request by calling us toll-free at 800-646-6072 or emailing us at globalmembersvc@spotcheck.today If you submit your request via email, please include at least your name, mailing address, email address, and a description of your request.
After you submit your request, we may contact you to obtain additional information necessary to verify your identity. For example, we may require you to verify certain information in our files or submit a signed declaration under penalty of perjury verifying your identity. We will not process your request without verifying your identity, so please respond promptly. If you do not timely respond to our requests for information, we may deny your request.
We will process verified requests within 45 days of receipt, subject to any applicable exemptions and extensions permitted by law up to 90 days. If you have an online account with us, we will provide the response to your request via the online account, otherwise, we will give you the option to choose between mail and electronic delivery. We will retain a copy of your deletion request for at least two years as required by law.
Right to Opt-Out from the Sale of Personal Information
We do not sell Personal Information to Third Parties. If our policy regarding the sale of Personal Information to Third Parties changes in the future, we will update this Privacy Policy as required by law.
Authorized Agent
If you are an authorized agent submitting a request on behalf of a California resident, you must provide a copy of a lawful power of attorney or a written signed authorization from the consumer along with proof your identity. You may provide this documentation via email to globalmembersvc@spotcheck.today after submitting the request. We may contact you and/or the consumer on whose behalf you claim to act to verify your authorization.
Non-Discrimination Notice
We will not discriminate against any consumer for exercising their privacy rights under law or this Privacy Policy.
California “Do Not Track” Disclosure
Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting that a user’s activity not be tracked. At this time, our Site and Services do not respond to “do not track” signals.
CONTACT US
If you have any questions about our Site, Services, or this Privacy Policy, please email us at globalmembersvc@spotcheck.today, call us toll-free at 1-800-646-6072, or send us a letter to the following address:
Global Membership Services
300 W Spring St - UNIT 702
Columbus, OH 43215
Attn: Privacy Manager