The CARROT pass Privacy Statement
Last updated: November 19, 2015
CARROT pass, LLC, is a subsidiary of Marvel Apps, LLC and are referred to in this Privacy Statement as "CARROT pass", "we", "us", or similar terms. We at CARROT pass have clear objectives regarding privacy and have created this Privacy Statement/policy to demonstrate our commitment to your privacy and adherence to industry standards for the protection of your personal information. This policy governs how CARROT pass treats personally identifiable information that is collected while you access or use any CARROT pass application (an “Application”) or any CARROT pass website, including but not limited to www.CARROTpass.com (collectively the “Site”). For purposes of this Privacy Statement, “Merchant” means any third party merchant that has registered with us for the services we provide and has also signed a Merchant Subscription Agreement.
Your personally identifiable information will be collected, used, and shared as outlined in this Privacy Statement. This Privacy Statement includes information about the following:
• What personally identifiable information is collected by CARROT pass or by any third party through an Application or the Site;
• How CARROT pass uses this information;
• With whom CARROT pass may share this information;
• What choices are available to you as a user of an Application or the Site with respect to collection, use and distribution of the information;
• What types of security procedures are in place to protect the loss, misuse or alteration of information under our control; and
• How you can correct any inaccuracies in the information.
How We Protect Your Information
CARROT pass has security measures in place to help protect against the loss, misuse, and alteration of the personal information and data under our control. The Site and our services use industry standard measures to protect the security of your information. This is not a guarantee that your information may not be accessed or disclosed by a breach of our systems, as no form of security is ever 100% secure. We take reasonable steps, such as requesting a unique password, to verify your identity before granting you access to your account; however, you are responsible for maintaining the secrecy of your unique password and account information at all times. Also, remember to sign out of any Application or the Site and close your browser window when you have finished. This helps to ensure that others cannot access your personal information and correspondence when accessing your computer or other mobile devices.
Your Choices About Your Information
You may choose not to submit personal information through CARROT pass, in which case CARROT pass may not be able to provide certain services to you. You can review and correct the information about you that CARROT pass keeps on file by contacting us directly as described in the Questions section below.
Information Practices: Fair Processing Notice
CARROT pass is committed to protecting your privacy both online and within our company. CARROT pass collects, holds and processes personal information relating to consumers who use CARROT pass Applications and the Site, as well as data related to the Merchants that subscribe to the CARROT pass services. It is essential for CARROT pass to do so in order to manage its operations effectively and in order to provide such interactive marketing services for the benefit of both the Merchant and the consumer users of our services.
During registration or account creation, you give your consent for CARROT pass to process your personal information. CARROT pass provides this fair processing notice, which informs you of how your personal data will be processed and provides the purposes for which the data has been collected. It also explains how you can opt out of some aspects of the processing, where applicable.
Information That We Collect and How We Use It
The information held by CARROT pass is mainly taken from the details provided during the registration or account-creation process, however, it also includes information that accumulates during an individual's ongoing use of the CARROT pass services. This information may include personal data such as your name, birthday and email address, transaction history, and could include a photograph or payment card and related payment information if you choose to use the payment functionality. Geographic location details are used to assist in participating in an individual Merchant program, as well as to provide relevant and appropriate offers.
We collect information about consumers in order to:
• Maintain status and preferences with each selected Merchant program
• Facilitate and account for purchases made at each selected Merchant
• Enable in-app mobile payments to selected Merchants
• Provide desirable and relevant messages or offers from selected Merchants
• Verify any discount or deal you may have earned
• Make consumers known to selected Merchants
• Administer and support the account for the consumer’s benefit
We collect information about Merchants in order to:
• Make the CARROT pass services available to their customers
• Moderate how employees have access to product features
• Provide marketing services on behalf of the Merchant
We may also use information we hold about you to:
• Compare it to other information to help combat fraud
• Assist in the authentication of your identity for customer service
• Deliver relevant messages and account service notices
• Perform analytics and other product and service development functions
Your personal information will be used within the CARROT pass system to provide you with CARROT pass services, such as participation in selected Merchant programs; and a limited amount of information will be shared with Merchants that you select, including your name and photograph. Any personal information shared in these ways will not be excessive. For example, a Merchant will see your name and photograph, and recent transaction history only from their business, in order to provide you with customer service and to make updates to your account.
Mobile Geolocation Data
The Applications and Site use geolocation data to provide our services. When you use the Applications, we may use GPS, Wi-Fi, Bluetooth, or other similar technologies to determine your current location in order to identify which Merchant you are visiting, to check you in to that location, and/or to provide you with relevant advertisements or other messages. We will not share your current location with other users or partners. If you do not want us to use your location for the purposes identified above, you should turn off the "location services" for CARROT pass located in your mobile phone settings. You may revoke your consent for access to geolocation data at any time, but parts of the services may not then work.
Third Party Advertisers
We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Site and other websites, based on information relating to your access to and use of the Site and other websites. To do so, these companies may place or recognize a unique cookie on your browser (including through the use of pixel tags). For more information about this practice, or simply to learn more about what choices may be available to you, please visit http://www.aboutads.info/ or http://www.networkadvertising.org/managing/opt_out.asp
When you select to register an account within an Application or on our Site, we request that you provide information, such as your name, email address, user name, password, and zip code or postal code, to register your account. CARROT pass uses this information to provide services to you, and, except for making your name and profile photo available to Merchants that you have authorized and third parties as needed to provide services to you, it is not shared with any third parties for their promotional purposes.
In addition, if you choose to opt-in to Merchant loyalty programs, CARROT pass will deliver push notifications on behalf of such Merchants to your mobile device. CARROT pass is not responsible for the content of such push notifications.
From Your Web Browser or Mobile Device
When you use an Application or the Site, we record and maintain a log of requests sent by your browser to our web servers. This log includes information such as the URL that was used to view the Site, your computer’s Internet Protocol address, and the time of the request. It does not include personal information such as your name or email address. We may use different types of technologies to collect this information, such as log files and GIFs. The information we collect is used to improve the quality of our services—for example, by diagnosing service or technology problems, or assessing and maintaining security. We may also conduct research on information we collect to determine user demographics, interests, and behavior.
CARROT pass reserves the right to utilize your Application or Site usage and location data to identify, generate and show you content-targeted promotions. This will be done through a secure, automated process. Examples of such content-targeted promotions could include using your general location data to determine which Merchant you are visiting so that the Merchant’s special offers can be made available to you during that visit and using your specific location data to determine where in the Merchant’s store you are so the Merchant can provide you offers specific to what you’re browsing. This use of location data is a necessary part of your use of the Application or Site. If you are uncomfortable with such collection or use of location data at any point then, as described above in Mobile Geolocation Data, you may turn off the location services or otherwise discontinue your use of the Application or Site. None of your content or personal information will be shared with any party beyond the terms specified in this Privacy Statement.
CARROT pass will not rent or sell your personal information to third parties for their promotional purposes. CARROT pass may share your personal information with entities outside of CARROT pass as described in this Privacy Statement, such as in the following limited circumstances:
• If we need to share your information to provide the products or services you have requested.
• If we have your consent. We would require opt-in consent for the sharing of any sensitive personal information.
• With a Merchant with whom you have established a history of transactions, we will share that transaction history with that Merchant only, which may include time and date of purchases, quantity, visit history, response to promotions, and personal preferences related to the services of that specific Merchant.
• To our subsidiaries, affiliated companies or other trusted businesses or persons acting as a service provider, authorized reseller or distributor on behalf of CARROT pass in order to provide the products or services you have requested.
We may share non-personal information with interested third parties in order to help them understand usage of the CARROT pass service. We may also provide your non-personal information to contractors so that they can perform services for us such as assisting us in improving our Site. Such information does not identify you individually.
Transfers to the United States and Other Global Locations
Because CARROT pass is headquartered in the United States (as is its parent company, Marvel Apps, LLC), we may transfer information collected from you on our Site or through our Application to the United States. Because CARROT pass operates, and Marvel Apps, LLC is headquartered in Royal Oak Michigan. To obtain further information about our policies and practices with respect to service providers outside of the country you are currently located in, please contact us directly as described in the Questions section below.
This Website May Be Linked to Other Websites
As you navigate the Site, you may click to websites of affiliated companies or other third parties. Those websites may have their own privacy statements/policies. This Privacy Statement will not apply when you move to one of these other websites because their privacy practices and policies are tailored to the products and services offered by them rather than by us. If you visit their websites please be sure to review the privacy policies applicable to those websites.
We may create links to third-party websites (for example, the “All About Do Not Track” website linked below). CARROT pass is not responsible for the privacy practices employed by any such third-party websites. The CARROT pass privacy policies and practices do not apply to these websites. CARROT pass does not guarantee, approve, or endorse any information, material, services, or products contained on or available through any linked websites. CARROT pass is not responsible for any content on websites linked from or to the Site. CARROT pass is providing links to those websites as a convenience and your connection to and use of any linked website are at your own risk.
Some browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a single website. For these purposes tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time.
How browsers communicate the Do Not Track signal is not yet uniform. As a result neither the Application nor the Site are set up to interpret or respond to Do Not Track signals communicated by your browser. Even so, as described more fully throughout this Privacy Statement, we limit our use and collection of your personal information.
For a description of Do Not Track protocols for browsers and mobile devices, or simply to learn more about the choices available to you, you can visit the “All About Do Not Track” website: http://allaboutdnt.com
CARROT pass complies with the requirements of the Children’s Online Privacy Protection Act (COPPA) and the FTC’s Rule interpreting COPPA (16 CFR § 512) and does not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to register. If you are under 13, please do not send any information about yourself to us. No one under age 13 is allowed to provide any personal information to or on CARROT pass. In the event that we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us as described in the Questions section below.
Changes to Our Privacy Statement
If we change our policies and procedures, we will post those changes on the Site to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it. You are bound by changes to the Privacy Statement when you use any Application or the Site after those changes have been posted. In the event of a material change to our information practices, we shall notify you via email, via a prominent notice on the Site, or via in-app messaging.
CARROT pass reserves the right to send you certain communications related to servicing your account, such as service announcements and administrative messages that are considered part of your account. You can opt-out of news and announcements when you sign up for CARROT pass or you can use the unsubscribe link at the bottom of applicable emails we send you. If you change your mind about receiving promotional information from us after registering to receive it, please send us a request specifying your new choice at email@example.com and we will honor your request or you can select the "Unsubscribe" link in an applicable email we send.
CARROT pass uses third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run CARROT pass. CARROT pass owns or has rights to the code, databases and Applications and this Privacy Statement governs all information on the Site. You retain all rights to your information data. Third party vendors and hosting partners are not allowed to use your personal information for any promotional purposes.
If you use a bulletin board, forum or blog, on the Site or linked from the Site, you should be aware that any personal information you submit there can be read, collected, and used by other users of these forums, and could be used to send you unsolicited messages or for other purposes. We are not responsible for the information that you submit in these forums or the consequences of doing so. We use a third party service to host the blog on the Site.
We sometimes post customer testimonials on our Site, which may contain personal information such as the customer's name. We always obtain the customer's consent prior to posting the testimonial to post their name and likeness along with their testimonial. We are not responsible for any personal information a user elects to submit on the Site within their testimonial.
Individuals Located in Australia
If you are located in Australia, by using this Site, you acknowledge and agree that your personal information will be disclosed to CARROT pass, Inc., an entity based in the United States. You declare that you have read the Privacy Statement available on www.CARROTpass.com and you have been informed that if you consent to the disclosure of your personal information in the manner set out in the Privacy Statement, the Australian Privacy Principle 8 will not apply to the disclosure. As such, you acknowledge that by consenting to your personal information being disclosed to CARROT pass LLC. you will not be able to seek redress under the Privacy Act 1988 (Cth).
If you have any questions, please contact the CARROT pass LLC Privacy Office at firstname.lastname@example.org or (248) 980-7858.