TheSmartyShopper, LLC (“TheSmartyShopper,” “we,” “our,” or “us”) manages this website along with other affiliated websites (collectively referred to as “Website” or “Websites”), which provide content related to personal finance. This content may include samples, surveys, sweepstakes, coupons, freebies, jobs, and other general topics of interest (collectively referred to as “Content”). The Content is made available to users through our Websites by our advertising clients and marketing partners (collectively, “Trading Partners”). This Privacy Policy (“Privacy Policy” or “Policy”) outlines how we collect, use, disclose, and share or sell personally identifiable information (“Information”) of users. Additionally, this Privacy Policy explains consumers’ data privacy rights under U.S. state privacy laws, including the California Consumer Privacy Act, as amended (“CCPA”), as well as other states’ privacy laws that have been enacted or may be adopted, and how users can exercise these rights. California Consumers: Please review the California Notice at Collection provided within this Privacy Policy below. Any capitalized terms used but not defined here will have the meanings assigned to them in the Website’s Terms and Conditions, which are fully incorporated by reference.

ACCEPTANCE OF PRIVACY POLICY

By accessing and using any of our Websites, you acknowledge your acceptance of this Privacy Policy and agree to the collection, use, disclosure, and sharing or sale of your Information as described within. If you do not agree to the terms outlined in this Privacy Policy, DO NOT use the Website.

PRIVACY POLICY UPDATES

This Privacy Policy may be revised periodically. Your continued use of a Website after changes are posted will constitute your acceptance of any modifications. Should we expand or change the Information we collect or how it is used, we will notify users by either: (a) sending the updated Policy via email or (b) any other reasonable method permitted by applicable state and federal law.

FOR U.S. RESIDENTS ONLY

If you are not a resident of the United States, you are not allowed to use the Website or participate in any sweepstakes we may offer.

CATEGORIES OF INFORMATION WE COLLECT

We may collect the following types and categories of Information from users (see below for additional descriptions provided to California residents):

• Identifiers (such as name, email, IP address, phone numbers, and gender)
• Personal Information (such as the Identifiers above, which may include details that are considered protected characteristics under state or federal law)
• Commercial Information (e.g., preferences, products or services purchased, obtained, or considered)
• Customer Support Information (e.g., inquiries and Content-related emails)
• Internet or Similar Network Activity (e.g., browsing and search history, user interactions with websites, apps, or advertisements)
• Cookies Information (e.g., user visits to our Websites or email interactions)
• Consent Information (related to consent for receiving SMS messages, commercial email, or other communications)
• Inferences (e.g., user profiles based on preferences, characteristics, trends, and behaviors)

HOW WE COLLECT INFORMATION

We collect Information through various methods, including:

• Directly from users via registration forms, surveys, emails, text messages, and customer service communications
• From publicly available sources, such as search engines
• By accessing Information held by Related Parties and third parties to verify the data we collect
• Through our hosting servers, which gather data when users interact with the Website
• Via our service providers and contractors who assist in hosting, customer support, and sending SMS messages
• From entities under common control with us (collectively, “Related Parties”)
• From our Trading Partners
• Using Cookies (small text files placed on browsers to track online behavior), web beacons, and other technologies
• By combining Information from the above sources, including Related Parties, Trading Partners, and service providers to enhance and verify the data collected

HOW WE MAY USE INFORMATION

We may use Information in the following ways:

• To provide you with Content and information about products and services
• To improve Website operations, conduct research, test features, and develop new products
• To respond to customer inquiries and provide support
• To send users email alerts, SMS/text messages, and other communications that they have requested or consented to receive, or that we are required to send (e.g., regarding registrations, sweepstakes, prizes, etc.)
• To enforce contractual obligations and rights (e.g., in accordance with our Arbitration Agreement or TCPA Consent)
• To detect, investigate, and address any fraudulent, malicious, or illegal activities, or any violations of our Terms and Conditions, this Policy, or applicable laws
• To protect our rights, property, and safety, as well as those of our Trading Partners, Related Parties, service providers, and other third-party contractual partners
• To maintain opt-out lists and ensure users who have opted out of communications are not contacted
• To enhance Information by using other data sources from our Trading Partners, Related Parties, and service providers to gain insights into our users
• To comply with legal processes, such as subpoenas or court orders, or to exercise or defend legal claims

HOW WE MAY SHARE INFORMATION

We do not sell Information or share it for cross-contextual advertising purposes. However, we may share Information in the following ways:

• With service providers for the purpose of delivering email, SMS/text messages, and push notifications (provided we have obtained TCPA Consent)
• With our service providers and Trading Partners who assist in delivering email messages
• To enable our Information verification and fraud detection vendors to perform their contracted services
• With Related Parties to verify Information and improve or enhance products and services

When we share Information, we have agreements in place that define the purpose of the Information sharing, restrict its use to that purpose, and ensure confidentiality.

As mentioned below, we do not sell users’ Personal Information as defined by the CCPA.

MINORS

Our Websites comply with the Children’s Online Privacy Protection Act (COPPA) and other laws that protect children’s privacy. We do not knowingly collect or store Information from children under the age of 13. Minors under 13 are not permitted to claim Rewards. If you are a parent or guardian and believe that your child under 13 has provided us with Information, you may contact us at help@myprivacyrequest.com. In accordance with the CCPA, we also do not knowingly sell or share Information of users under the age of 16 for any commercial purpose.

COOKIES, INTEREST-BASED ADVERTISING, AND THIRD-PARTY ANALYTICS

While we don’t use Cookies for other purposes, some of our third-party Trading Partners may place Cookies on our Websites to track users’ behavior both during and after their visit. These Cookies may facilitate interest-based advertising, where advertisements are delivered based on your browsing activity. Additionally, our Trading Partners may use the Information gathered to recognize you across various platforms, including computers, mobile devices, and Smart TVs, for advertising, analytics, and reporting purposes.

We may also use Google Analytics and similar tools to analyze how users interact with our Website and to display customized ads and content. This analysis does not involve the collection of additional Information beyond what is mentioned above.

You may disable Cookies through your browser settings, but doing so may impair certain features of the Website, such as remembering Information previously supplied to us. We may retain Cookie data indefinitely.

Users may opt out of interest-based advertising delivered to their browsers through programs like the Digital Advertising Alliance or the Network Advertising Initiative. You can also opt out of interest-based advertising on mobile devices. For more information, click here.

Opting out of interest-based advertising does not mean you will no longer see ads, but rather that those ads will not be tailored to your interests.

As required by certain state laws, we must inform users that we generally do not alter our behavior in response to “do-not-track” settings on browsers. The exception to this is California residents, for whom we will honor opt-out preference signals in compliance with the CCPA.

OTHER WEBSITES

Our Website may contain links to other websites or services. When you click on these links, you are subject to the privacy policies and terms of those sites, not this Privacy Policy. We are not responsible for the privacy practices, content, or security of third-party sites, including those of our Trading Partners. You should review the applicable policies of any third-party website before providing them with Information.

OPTING OUT OF MARKETING

You can opt out of future communications from us through the following methods:

• Email: Click the “Unsubscribe” link at the bottom of any marketing email, or click here.
• TCPA Consent Opt-Out (SMS/Text Messaging): You are not required to provide TCPA Consent to access Content on our Website. Users who previously provided TCPA Consent but wish to revoke it may opt out by replying STOP to any SMS/text messages or by contacting customer service here.
• Cookies: To opt out of Cookies, interest-based advertising, and third-party analytics, please refer to the instructions in the Cookies section above.

ACCESSING, CORRECTING, AND DELETING YOUR INFORMATION

Since we do not sell or share your Information for cross-contextual advertising purposes, we do not provide a “Do Not Share My Personal Info” link on our Website. You may, however, contact us at privacy@thesmartyshopper.com to correct, delete, or access the Information we have collected, processed, or shared. We will respond to your request within 45 days. If you request deletion, your Information will be suppressed from further use as outlined in this Policy.

Please note that we may retain your Information as necessary to comply with legal obligations, resolve disputes, or enforce agreements.

When you request access to, correction of, or deletion of your Information, we may ask you to verify your identity before processing the request. We reserve the right to decline requests that are unverified, repetitive, or otherwise unreasonable.

SECURITY OF YOUR INFORMATION

We implement commercially reasonable measures to prevent unauthorized access, disclosure, or destruction of your Information. Access to your Information is restricted to those individuals and third-party service providers who require it to perform their duties. We also encrypt your Information using advanced Transport Layer Security (TLS) when it is collected, stored, or transmitted.

Despite these efforts, we cannot eliminate all risks associated with data transmission over the Internet, and we cannot guarantee that our security measures or those of third parties will prevent your Information from being improperly accessed or altered. If we experience a data breach, we will notify you and any applicable regulatory bodies as required by law.

U.S. STATE LAW RIGHTS AND DISCLOSURES

California was the first state to enact a comprehensive data privacy law in the U.S. Since the adoption of the California Consumer Privacy Act (CCPA), approximately a dozen other states have passed similar data privacy laws, with over fifteen additional states currently considering such legislation. Each of these laws provides statutory rights to consumers in their respective states.

In general, the CCPA provides the most comprehensive rights to California consumers compared to other state data privacy laws. We currently extend the same rights to all U.S. users, as provided to California residents under the CCPA. Additionally, we describe any additional rights available under other states’ data privacy laws.

NOTICE AT COLLECTION

This Privacy Policy provides timely notification to all users, including those classified as “consumers” under the CCPA, that we collect Information at or before the point of collection.

Below is a summary of the categories of Information we collect from users and the categories we may share. We collect this Information for the following purposes: to provide you with Content and details about additional products and services; for Website operations, including improvements, testing, research, analysis, and product development; to offer customer service and respond to inquiries; to send users email alerts, SMS/text messages, or other communications that they have requested or consented to receive, or that we are required to send (e.g., concerning user registrations, sweepstakes entries, prizes, products, or services); to detect, investigate, and address fraudulent or malicious activity or any other behavior we deem a violation of our Terms and Conditions, this Privacy Policy, or applicable laws and regulations; to protect the rights, property, or safety of ourselves, our Trading Partners, Related Parties, service providers, and other third parties with whom we have business relationships; to maintain suppression or opt-out lists for users who have requested not to be contacted; to enhance Information using additional data sources provided by our Trading Partners, Related Parties, and service providers to gain deeper insights into our users; and to respond to legal requests (e.g., subpoenas, court orders) or defend against legal claims. We will retain your Information for as long as necessary to protect against claims related to your interactions with us, unless you exercise your data privacy rights. We do not knowingly sell or share Information of users under the age of sixteen (16) for any commercial purposes.