Transparency: We’ve provided additional clarity regarding the information we collect from Panel Participants and Clients, and how we process this information. We’ve also explained the choices and control individuals have over their information.
Data Control: We’ve described how individuals can (i) access, correct or delete their personal data from our systems; and (ii) provide or withdraw consent, as appropriate.
Last modified: March 1, 2019
Numerator, operated by Market Track, LLC, is in the business of providing online solutions to agencies, brands, manufacturers, and retailers. Also, Numerator manages a Rewards Programs to help consumers receive value back when they shop and to help brands and retailers better understand consumer behavior.
Market Track, LLC is (i) the data controller for Numerator activities involving our online products and services (“Services”) to Clients and the personal information we may collect from visitors to and users of our websites (“Sites”); and (ii) the data processor for Numerator activities arising by, through, and from your use of our Mobile Applications (“Mobile Apps”).
Please note that:
This Policy does not cover our Clients’ use of your personal information outside of our Services. We are not responsible for the privacy practices of our Clients, as such we encourage you to read their respective privacy statements. Further, as a result of your interactions with our Services, Mobile Apps, or use of the Sites, you may elect to participate in contests, sweepstakes, or other programs (such as Rewards Programs), offered or sponsored by third parties on the Site or Mobile Apps. We are not responsible for any such purchase you make, or participation you undertake, and as such any such purchase or participation will be subject to the relevant third party's terms and conditions.
EU-U.S. Privacy Shield
Market Track, LLC participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Market Track, LLC is committed to subjecting all personal data received from the European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. https://www.privacyshield.gov
Market Track, LLC is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Market Track, LLC complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Market Track, LLC is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Market Track, LLC may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
WHAT PERSONAL INFORMATION DO WE COLLECT AND WHEN, AND WHY WE USE IT ABOUT YOU
We may collect the following categories:
Information You Provide Us Directly. We collect personally identifiable and transactional information (purchase-related history) which you provide us directly, for example, in connection with a purchase, a promotion, or application for the Rewards Program.
Information We Receive from Our Clients. We may collect information from our Clients who provides your information to us so that you for the benefit of the Client is able to login to our Sites and/or Services.
Information We Receive from Other Parties. We may combine the information we receive from you with information we receive from other sources.
We will only collect, use, and share your personal information where we are satisfied that we have an appropriate legal basis to do this. The chart below summarizes when we collect personal information, the types of personal information we collect, how we use the personal information, and the legal basis for our use of such personal information.
We may use the information we collect to comply with federal, state, or other applicable laws and regulations.
HOW WE SHARE PERSONAL INFORMATION WITHIN NUMERATOR AND WITH OUR SERVICE PROVIDERS, AND OTHER THIRD PARTIES
We may share Personal Information with Rewards Program Sponsors. If you choose to participate in a Rewards Program, we may provide the Rewards Program Sponsor for that Rewards Program any Personal Information you provide us, including for example, your name, mailing address, email address, phone number, username, Account activity, including information about the Award offers you activated and redeemed. Rewards Program Sponsors are third-party companies independent of Numerator that may use the information you have consented that we provide them through your participation in the Reward Program, to evaluate, develop, offer and promote their products and services to you and others. If you do not want us to share your personal information with these companies, contact us at firstname.lastname@example.org
We may promote or offer contests, sweepstakes, similar promotional offers or surveys that may be co-sponsored by Numerator and a company not affiliated with Numerator, or may be sponsored by companies other than Numerator. Some or all of the Personal Information collected through these offers or surveys may be shared with the sponsor(s) or other companies indicated on the entry form, in the governing rules or on the survey, as applicable.
With third parties who help manage our business and deliver services, for example, IT service providers who help manage our IT and back office systems or administer our Sites, Services, and/or Mobile Apps. These third parties have agreed to confidentiality restrictions and have agreed to use any personal information we share with them, or which they collect on our behalf, solely for the purpose of providing the contracted service to us.
If you are using our Mobile App, we may:
provide information about you as part of an aggregate report to Rewards Program Sponsors, Award Providers, Participating Retailers when you elect to join our panel participant program and sign up for the Rewards Program. For example, your purchase information from receipts your upload to our Mobile App or electronic receipts which may be accessible from the Mobile App, with your consent, may be aggregated with the purchase information of other Mobile App users and analyzed to evaluate the effectiveness of certain award offers or advertisements, and the results of that analysis may be shared with Rewards Program Sponsors, Award Providers, Participating Retailers, or others; and/or
we may provide information about you to clients, partners, Rewards Program Sponsors, Award Providers, Participating Retailers, or others for creating profiles to understand shopping and spend behavior, preferences, interests, or other data related to shopping behavior.
For our individuals who are using our Services, we may share personal information as part of aggregated reports to clients, partners, or others for marketing, analysis and other purposes.
We may disclose information to third parties (with consent if required by law) such as promotional partners and others with whom we have marketing or other relationships. For further details, refer to the Direct Market section in this Policy.
With government organizations and agencies, law enforcement and regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies; in response to a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
We may share in aggregate, statistical form, non-personal information regarding the visitors to our Sites and Mobile Apps with our partners, affiliates or advertisers.
If, in future, we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may disclose/transfer the information we have collected from you to the acquiring company. In such an event, you will be notified via email and/or a prominent notice on our website of any change in ownership, incompatible new uses of your personal information, and choices you may have regarding your personal information.
In addition to the above, we may share Personal Information about you with others to the extent you consent to such sharing.
Questions about Use, Access, Deletion, and/or Correction of your Personal Data
If you have questions about use, access, deletion, and correction of your personal data, please contact us at email@example.com and/or at the contact information listed below.
You may withdraw your consent at any time by clicking the “unsubscribe” link in the email communications we send to you. You may also withdraw consent by exercising Your Rights as described below.
TRANSFERRING PERSONAL INFORMATION GLOBALLY
International data transfer
We operate on a global basis. This means that your personal information may be transferred to and stored in the United States, which may be subject to different standards of data protection than your country of residence.
We will take appropriate steps to ensure that transfers of personal information are in accordance with applicable law, are carefully managed to protect your privacy rights and interests and limited to countries which are recognized as providing an adequate level of legal protection or where alternative adequate arrangements are in place to protect your privacy rights. To this end:
we ensure transfers within Numerator will be covered by an agreement entered into by Numerator entities (an intra group agreement) which contractually obliges each such entity to ensure that personal information receives an adequate and consistent level of protection wherever it is transferred within Numerator;
where we transfer your personal information outside Numerator or to third parties who help provide our Services, we obtain contractual commitments from them to protect your personal information; or
where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any personal information are disclosed.
You have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal information when this is transferred as mentioned above.
COOKIES AND SIMILAR TECHNOLOGIES
When you visit a Numerator website or click on a banner advertisement, we and our marketing partners partners, affiliates, or analytics or service providers send one or more cookies or similar technologies to your computer or other device to collect information that helps us improve the quality of site and service and the online experience of our visitors and users. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some Numerator website features or services may not function properly without cookies.
Our websites and Cookies: We process personal information about you that we collect either directly, through forms or data entry fields on our website, or through passive collection by cookies and other data collection technologies. The types of personal data we process in each of these contexts is further explained below:
Cookies and other data collection technologies: we use browser session cookies, which are temporary cookies that are erased from your device’s memory when you close your Internet browser or turn your computer off, and persistent cookies, which are stored on your device until they expire, unless you delete them before that time. We group browser cookies on our site into three categories, which you can manage:
Required cookies: These cookies are necessary to enable the basic features of this site to function, such as allowing images to load or allowing you to select your cookie preferences.
Functional cookies: These cookies allow us to analyze your use of the site to evaluate and improve our performance. They may also be used to provide a better customer experience on this site. For example, remembering your log-in details or providing us information about how our site is used.
Advertising cookies: These cookies may be used to share data with advertisers so that the ads you see are more relevant to you, allow you to share certain pages with social networks, or allow you to post comments on our site.
Security and Retention of Your Personal Information
Please remember that you also play a valuable part in data security. You should never share your Account password, if applicable, with anyone. If you feel your password has been compromised, you should change it immediately. After you have finished using our mobile applications or website(s), you should log out of your Account and exit your browser so that no unauthorized persons can use our website under your name or Account. If you have any questions about the security of your personal information, you can contact us at firstname.lastname@example.org.
We will retain your information (and information we process on behalf of our Clients), for as long as your account is active or as needed to provide you services and to fulfill the purposes for which the data was collected. We also may keep data about you for statistical analysis or research purposes.
We may keep data longer if we have a legal obligation to keep it or to maintain necessary records for legal, financial, compliance, or other reporting obligations, and to enforce our rights and agreements.
How we use personal information you keep you up to date with our Services and/or Mobile Apps
We may use personal information to let you know about our Services that we believe will be of interest to you. We may contact you by email, post, or telephone or through other communications channels that we think you may find helpful. In all cases, we will respect your preferences for how you would like us to manage marketing activities with you.
We also work with carefully selected third parties, such as promotional partners and others with whom we have marketing or other relationships. At all times, in accordance with your marketing preferences, these third parties may contact you by email, SMS/text, social media or through other communications channels to tell you about products and services that they believe would be of interest to you.
How you can manage your marketing preferences
To protect privacy rights and to ensure you have control over how we manage marketing with you:
- We will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you;
- At any time you can update or correct your personal profile, or change your preferences for the way in which you would like us to communication with you, including how you receive details of latest offers from us;
- You can also click the “unsubscribe” link that you find on any online newsletters you receive or contact customer support team at email@example.com .
- You can ask us to stop direct marketing at any time – you can ask us to stop sending email marketing by following the unsubscribe link you will find on all the email marketing messages we send you. Alternative you can contact us firstname.lastname@example.org. Please specify whether you would like us to stop all forms of marketing or just a particular type (e.g. email);
- You can change the way your browser manages cookies, which may be used to deliver online advertising, by following the settings on your browser. We recommend you routinely review the privacy notices and preference settings that are available to you on any social media platforms as well as your preferences in your account with us. Further, if (in accordance with your marketing preferences) you receive marketing from the third parties referred to above, we recommend you review any relevant third party's privacy notice for how they use your personal information.
Be aware that if you unsubscribe from our marketing communications we may be unable to notify you of tailored services or offer to meet your needs. If you unsubscribe from marketing communications from us, you will still receive operational and service messages from us regarding the Services and/or Mobile Apps.
Please note that information you voluntarily include in bulletin boards, chat rooms and other online forums we may offer may be viewed and used by anyone with access to those forums. Numerator is unable to control any use of such information.
We may provide you the ability to log in to our websites using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you the option to share certain Personal Information with us such as your name and email address to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities on our website(s) to your profile page to share with others within your network. Facebook Connect is owned and operated by Facebook, and more information about Facebook Connect is available at https://www.facebook.com
Collection of Information from Children
None of our products or services are intended for use or purchase by children. Accordingly, Numerator does not knowingly collect, either online or offline, information from children under the age of 13. If you believe that we might have any information from a child under age 13, please contact us at email@example.com
Upon request Numerator will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by logging into your account or contacting us at firstname.lastname@example.org. We will respond to your request within a reasonable timeframe. In certain circumstances we may be required by law to retain your personal information, the verify your identify, or may need to retain your personal information in order to continue providing a service.
Legal Rights Available to EU Data Subjects:
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, if you are an EU data subject, you may have certain rights in relation to your personal information:
- whether and why we have your personal information;
- how we got your personal information;
- what we have done with your personal information;
- to whom we have communicated your personal information;
- where your personal information has been stored, processed or transferred;
- how long we will retain your personal information, or how that retention period will be determined; and
- the safeguards in place to protect your information when it is transferred to third parties or third countries.
Finally, you can ask us to request restrictions, temporarily or permanently, on our processing of personal information about you for certain purposes, or you can request transfer of personal information to you or a third party where we process the data based on your consent or a contract with you, and where our processing is automated.
If you wish to access any of the above-mentioned rights, we may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing personal information to you.
We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
You can exercise your rights by sending a request to email@example.com or to the mailing address referenced in the Contact Us section. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
On our service platform, Numerator collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes. If you are a customer or employee of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.
Numerator acknowledges that you have the right to access your personal information. Numerator has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to the Numerator’s Client (the data controller). If requested to remove data, we will respond within a reasonable timeframe.
Numerator regularly reviews its policies, procedures and practices regarding personal information and this Policy.
The primary point of contact for all issues arising from this Policy is our Data Protection Officer. Our Data Protection Officer can be contacted in the following ways:
Email: firstname.lastname@example.org Attn: Numerator Privacy Market Track, LLC 233 S. Wacker, Suite 2105 Chicago, IL 60606 Phone: +1.312.529.5102
If you have any questions, concerns or complaints regarding our compliance with this Policy, the information we hold about you or if you wish to exercise your rights, we encourage you to first contact us. We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws.
To contact your data protection supervisory authority
You have a right to lodge a complaint with your local data protection supervisory authority (i.e. your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before your local supervisory authority. Your local authority can be found here.
An “Account” is an account you establish with Numerator as a Client or end-user of our Service or a member of our Rewards Program.
“Awards” are the discounts, cash rebates, other cash Awards, points, coins, miles, and/or other awards that Award Providers offer you as a Registered User of a Rewards Program.
An “Award Provider” is a company or other entity that offers you an award if you make an eligible purchase of the entity’s products or services through one or more Rewards Programs. Award Providers can include Numerator, consumer packaged goods manufacturers, grocery stores, drug stores or other entities.
“Client” is a party (e.g., organization or legal entity) that has a direct licensing contract with Numerator for Numerator services.
“Nonpersonal Information” is any information about you that is not Personal Information.
“Participating Retailers” are retailers and other entities that sell products and services for which Award Providers offer Awards. Participating Retailers agree to provide or make available to us certain purchase information so that we may track Awards. A Participating Retailer can also be an Award Provider and/or a Rewards Program Sponsor.
“Personal Information” is information that personally identifies you to the person or entity that is in possession of such information.
A “Registered User” is an individual or entity that registers to participate in one or more Rewards Programs to earn Awards.
A “Rewards Program Sponsor” is Numerator or a company, organization or other entity on whose behalf Numerator is operating or administrating a Rewards Program. A Rewards Program Sponsor may also be an Award Provider or Participating Retailer.