Fevo Privacy Policy

This Privacy Policy describes how FEVO, Inc. (“FEVO”, “we”, "our” or “us”) collects, uses and discloses your information when: (1) you interact and use www.fevo.com, www.offer.fevo.com, www.myfevo.com, and any other digital platform where this Privacy Policy appears (the “Sites”); (2) you interact and use our services, features, content or applications (collectively with the Sites, the “Services”); (3) you communicate with us in any way (“Communications”); and (4) we interact with certain third-party providers and organizations (“ThirdParties”).

Please note, this Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any third-party websites, services and applications that you access through the Services, including websites of companies offering goods, services, events, or other offerings in partnership with FEVO (“Offer Provider”). While we attempt to facilitate access only to those third-party services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those third-party services. We encourage you to carefully review the privacy policies of any third-party services you access.

ACKNOWLEDGMENT

BY ACCESSING AND/OR USING OUR SITES, SERVICES, AND/OR BY COMMUNICATING WITH US IN ANY MANNER, YOU REPRESENT THAT YOU HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY.

WHAT INFORMATION DOES FEVO COLLECT?

The information we gather enables us to personalize, improve, and operate the Services. In connection with certain aspects of the Services, we may request, collect, and/or display some of your information, including:

Account and Purchase Information

When you create an Account for our Services, including third-party websites or applications, such as Offer Provider website or applications, you will provide information such as your name, email address, phone number, address, payment information, and/or password. We may also ask for demographic information or other information relevant to the offer, event, or prizes that the Offer Provider may provide. Please note, when you provide us with your email address and/or telephone number, we will be creating an Account on your behalf to identify and catalogue your purchases through Fevo.

Your Communications With Us

We collect information from you such as email address, phone number, or mailing address when you request information about our Services, register for our marketing communications or loyalty program, request customer or technical support, apply for a job, or otherwise communicate with us.

Surveys

We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information.

Social Media Content

We may offer forums, blogs, or social media pages. Any content you provide on these channels will be considered “public”.

Sweepstakes or Contests

We may run sweepstakes and contests. Contact information you provide may be used to reach you about the sweepstakes or contest and for other promotional, marketing and business purposes, if permitted by law. In some jurisdictions, we are required to publicly share the information of winners with Third Parties.

‍User Content

Some features of the Services may allow you to provide content to the Services. All content submitted by you to the Services may be retained by us indefinitely, even after you terminate your Account. We may continue to disclose such content to Third Parties in a manner that does not reveal your identity, where appropriate.

‍Location Information

Some of our Services may include features based on your actual locations and may report your current locations (“Location-BasedServices”). To the extent you use any Location-Based Services, we will collect and store information about your location at the time you use thoseLocation-Based Services. This information can come from a variety of sources depending on the client and device you use to access the Services; for example, a mobile phone may report its GPS location or IP address at the timeLocation-Based Services are used. You can opt out of Located-Based Services by changing the settings directly on your device.

‍Financial Information

If you make purchases through the Services, your financial information, such as your payment method (valid credit card number, type, expiration date or other financial information), is collected and stored by our third-party payment processing company (the “Payment Processor"), and use and storage of that information is governed by the Payment Processor's applicable terms of service and privacy policy. We currently use Stripe as ourPayment Processor (www.stripe.com). In order to facilitate your order transactions, we collect and store your billing zip code, credit card type and the last four digits of your credit card number, but no other financial information.

‍Shipping Information

We may collect your shipping information in connection with certain purchases through the Services. We may pass this information to ourPayment Processor, Offer Providers, partners, and other Third Parties for purposes of customer service, fulfillment, shipping and returns. The use of your information by such parties is subject to their respective privacy policies and terms where applicable.

IP Address Information and Other Information Collected Automatically

We automatically receive and record information from your web browser or device when you interact with the Services, including your IP address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services.Information we collect may be associated with accounts and other devices.

Generally, the Services automatically collect usage information, such as the number and frequency of visitors to the Sites. We may use this data in aggregate form, that is, as a statistical measure, but not in a manner that would identify you personally. This type of aggregate data enables us and Third Parties authorized by us to figure out how often individuals use parts of the Services so that we can analyze and improve them.

COOKIES, PIXEL TAGS/WEB BEACONS, ANALYTICS INFORMATION, AND INTEREST-BASED ADVERTISING TECHNOLOGIES

We, as well as Third Parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services.

‍Cookies

Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.

‍Pixel Tags/Web Beacons

A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

Analytics

We may also use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on our Services. For more information about Google Analytics, please visitpolicies.google.com/technologies/partner-sites. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to tools.google.com/dlpage/gaoptout.

‍Information from Other Sources

We may obtain information about you from other sources, including through Third Party services and organizations to supplement information provided by you.

If you access our Services through a Third Party website or application, such as an Offer Provider, app store, a Third Party login service, or a social networking site (such as Facebook), we may collect information about you from that Third Party. Information we collect through these services may include your name, your user identification number, your username, location, gender, birth date, email, profile picture, and your contacts stored in that service. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.

AGGREGATE INFORMATION

We collect statistical information about how both unregistered and registered users, collectively, use the Services (“AggregateInformation”). Some of this information is derived from your information. This statistical information is not identifiable to you.

HOW WILL MY INFORMATION BE USED?

We use your information for a variety of business purposes, including to:

Fulfill our contract with you and provide you with ourServices, such as:

- Managing your information and Accounts;

- Providing access to certain areas, functionalities, and features of our Services; Communicating with you about your Account, activities on our Services and policy changes;

- Undertaking activities to verify or maintain the quality or safety of a service or device;

- Processing your financial information and other payment methods for products or Services purchased;

- Providing advertising, analytics and marketing services;

- Providing Services on behalf of our customers, such as maintaining or servicing accounts, providing customer service, and verifying customer information;

- Processing applications and transactions; and

- Allowing you to register for offers.

Analyze and improve our Services pursuant to our legitimate interest, such as:

- Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;

- Measuring interest and engagement in our Services and short-term, transient use, such as contextual customization of ads;

- Undertaking research for technological development and demonstration;

- Researching and developing products, services, marketing or security procedures to improve their performance, resilience, reliability or efficiency;

- Improving, upgrading or enhancing our Services or device or those of our Providers;

- Developing new products and Services; Ensuring internal quality control;

- Verifying your identity and preventing fraud;

- Debugging to identify and repair errors that impair existing intended functionality;

- Enforcing our terms and policies; and

- Complying with our legal obligations, protecting your vital interest, or as may be required for the public good.

Provide you with additional content and Services, such as:

- Furnishing you with customized materials about offers, products, and Services that may be of interest, including new content orServices;

- Auditing relating to interactions, transactions and other compliance activities; and

- Other purposes you consent to, are notified of, or are disclosed when you provide personal information.

USE DE-IDENTIFIED AND AGGREGATED INFORMATION

We may use information and other data about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create.

SHARE CONTENT WITH FRIENDS OR COLLEAGUES

Our Services may offer various tools and functionalities.For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services.

PROCESS INFORMATION ON BEHALF OF OUR CUSTOMERS

Our customers may choose to use our Services to process certain data of their own, which may contain personal information. The data that we process through our Services is processed by us on behalf of our customer, and our privacy practices will be governed by the contracts that we have in place with our customers.

If you have any questions or concerns about how such data is handled or would like to exercise your rights, you should contact the person or entity who has contracted with us to use the Service to process this data.

HOW WE USE AUTOMATIC COLLECTION TECHNOLOGIES

We, as well as Third Parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other Technologies to automatically collect information through the Services. Our uses of these Technologies fall into the following general categories:

‍Operationally Necessary

This includes Technologies that allow you access to ourServices, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality.

‍Performance Related

We may use Technologies to assess the performance of ourServices, including as part of our analytic practices to help us understand how our visitors use the Services.

‍Functionality Related

We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed.

‍Advertising or Targeting Related

We may use first party or Third Party Technologies to deliver content, including ads relevant to your interests, on our Services or on Third Party Sites.

CROSS-DEVICE TRACKING

Your browsing activity may be tracked across different websites and different devices or apps. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop. To do this our technology partners may share data, such as your browsing patterns, geo-location and device identifiers, and will match the information of the browser and devices that appear to be used by the same person.

NOTICE REGARDING THIRD PARTY WEBSITES, SOCIAL MEDIA PLATFORMS AND SOFTWARE DEVELOPMENT KITS

The Services may contain links to other websites, and other websites may reference or link to our website or other Services. These other websites are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

Our Services may include publicly accessible blogs, forums, social media pages, and private messaging features. By using such Services, you assume the risk that the information provided by you may be viewed and used byThird Parties for any number of purposes. In addition, social media buttons such as Facebook, Twitter, Instagram, and LinkedIn (that might include widgets such as the “share this” button or other interactive mini-programs) may be through our Services. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a third party or hosted directly on our site. Your interactions with these features apart from your visit to our site are governed by the privacy policy of the company providing it.

We may use third party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including analytics and advertising partners to collect your personal information for various purposes including to provide analytics services and content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below.

HOW, AND WITH WHOM, IS YOUR INFORMATION SHARED?

Certain of the Services are designed to help you share information with others. As a result, some of the information generated through the Services is shared publicly or with Third Parties.

‍Service Providers

We may share any information we collect about you with ourThird Party service providers. The categories of service providers to whom we entrust your information include IT and related services; payment processors; customer service providers; and vendors to support the provision of theServices.

‍Business Partners

We may provide your information to our business partners with whom we jointly offer products or services, including Third Party websites and applications, such as Offer Providers. In such cases, our business partner’s name will appear along with ours.

‍Affiliates

We may share your information with our affiliated companies.‍

Advertising Partners

Through our Services, we may allow Third Party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit Third Party websites within their networks. This practice is commonly referred to as “interest-based advertising”or “online behavioral advertising. We may allow access to other data collected by the Services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your information withThird Party advertising partners, you may follow the instructions below.

Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information maybe sold or transferred as part of such a transaction, as permitted by law and/or contract.

‍International Data Transfers

Information we collect may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We take commercially reasonable steps to protect your personal information as it relates to any transfer that may take place.

‍IS INFORMATION ABOUT ME SECURE?

We take all commercially reasonable steps to ensure your information is secured in accordance with applicable law.

WHAT ARE MY CHOICES?

You have certain choices about your information.

You can use some of the features of the Services without registering, thereby limiting the type of information that we collect. You can always opt not to disclose certain information to us, even though it may be needed to take advantage of some of our features.

‍Account Deactivation

Should you ever decide to deactivate your Account, you may do so by emailing support@fevo.com. If you deactivate your Account, any association between your Account and information we store will no longer be accessible through your Account. However, given the nature of sharing on theServices, any public activity on your Account prior to deactivation will remain stored on our servers and will remain accessible to the public in accordance with applicable law.

Email and Telephone Communications

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services (e.g.,communications regarding the Services or updates to our Terms or this PrivacyPolicy). We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists as required by applicable law.

‍“Do Not Track”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers unless otherwise required by law.

Cookies and Interest-Based Advertising

You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at optout.networkadvertising.org, youronlinechoices.com, youradchoices.ca/en/tools, and optout.aboutads.info. To separately make choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store. Alternatively, for some devices you may use your device’s platform controls in your settings to exercise choice. Please note you must separately opt out in each browser and on each device.Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.

HOW IS DATA RETAINED?

We store the information we receive as described in thisPrivacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

CALIFORNIA RESIDENTS

California Consumer Privacy Act (CCPA)

The following disclosures and rights apply to you if you area California resident. All capitalized terms used in this section have the same meaning as those terms are defined under the California Consumer Privacy Act of2018 and its implementing regulations, as amended (“CCPA”):  

·      Notice of Financial Incentive. From time to time, we may offer a discount orFinancial Incentive in exchange for you providing certain Personal Information o us, such as your contact information. Any discount we provide will be based upon our reasonable but sole determination of the estimated value of your Personal Information, taking into consideration, without limitation, estimates regarding anticipated revenue generated from such information, the anticipated expenses which might be incurred in the collection, storage, and use of such information in the operation of our business, and other relevant factors related to the estimated value of such information to our business, as permitted under applicable law. By providing your information in response to any Financial Incentive, you are affirmatively opting-in to the discount program. If you wish to opt-out, do not submit your information. If you wish to withdraw your consent at any time, you may submit a request to support@fevo.com.

 

·      Notice of Collection. To learn more about the categories of PersonalInformation we have collected about California residents in the 12 months since this Privacy Policy was last updated, including the categories of sources from which we collected the information, the purposes for which we use the information, and the categories of third parties with whom we’ve shared the information, please see What Information Does FEVO Collect?, How Will My Information Be Used?, and How, And With Whom, Will Your Information Be Shared?

 

·      Notice of Disclosure for Business Purposes. To learn more about the categories of Personal Information we have disclosed about California residents for aBusiness Purpose to third parties in the 12 months since this Privacy Policy was last updated, including the categories of third parties with whom we’ve disclosed the information, please see What Information Does Fevo Collect?, and How, And With Whom, Will Your Information Be Shared?

 

·      Notice of Sale. We do not Sell the Personal Information of California residents in the traditional sense of the word. However, because the definition of Sell under the CCPA is broad enough to potentially include the sharing of your information with advertising and marketing partners, we provide California residents the right to opt-out of this type of sharing of their Personal Information. The categories of Personal Information we have shared with advertising and marketing partners in the 12 months before this Privacy Policy was last updated include direct identifiers, such as name, contact information, and IP address, as well as purchase history and interaction history with the Services. Much of this information is transmitted through certain Technologies. We do not knowingly Sell the Personal information of anyone 16 years or younger.

 

·      Right to Know. You have a right to ask that we disclose up to two times per year a list of: (1) the categories of Personal Information we’ve collected about you in 12 months prior to the date of your request; (2) the categories of sources from which we have collected that information; (3) the categories of Personal Information we have Sold, shared, or disclosed for a Business Purpose about you in the 12 months prior to the date of your request; (4) the categories of third parties with whom we have Sold, shared, or disclosed for a Business purpose your Personal Information; and (5) the specific pieces of yourPersonal Information. To submit such a request, please Contact Us.

 

·      Right to Delete.  You have a right to ask that we delete certain information we have about you, subject to certain exceptions such as to comply with a legal obligation, complete a transaction, or prevent against fraud or other unlawful activity. To submit a request to delete, please Contact Us.

 

·      Right to Opt-Out. You have a right to opt-out of the Sale of your PersonalInformation. As described above, we may share your Personal Information with advertising and marketing partners that could be considered a Sale of PersonalInformation under the CCPA. To opt-out of this sharing, please visit our CookieManager Tool and de-select the Advertising and Analytical cookies. To learn more, please visit Do Not Sell My Personal Information. If you have any questions about this right, please Contact Us.

 

·      Right to Anti-Discrimination. We will not discriminate against you in any way if you exercise any of the rights above.

 

·      Verification. In order to ensure we do not disclose your information to someone else, and to prevent an inadvertent deletion of your information based on a fraudulent request, we will verify your identity before responding to your request. To verify your identity, we will generally match the information you provide in your request with the information we have on file about you. Depending on the sensitivity of the information and request, we may request additional information from you, including a declaration signed under penalty of perjury.

California Minors

Persons under the age of 18 are not permitted to access or use our Services. If you are a California resident under the age of 18 and have nonetheless accessed and used our Services in violation of applicable laws and company policy, California Business and Professions Code § 22581 permits you to request and obtain removal of content or information you have publicly posted on any of our Services. To make such a request, please send an email with a detailed description of the specific content or information to support@fevo.com with the subject line,"CALIFORNIA MINOR CONTENT REMOVAL REQUEST." Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and there may be circumstances in which the law does not require or allow removal even if requested.

‍Accessibility

This Privacy Policy uses industry-standard technologies and was developed to align with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this policy, please do so from your web browser or by saving the page as a PDF.

CHILDREN’S INFORMATION

The Services are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.

WHAT HAPPENS WHEN THERE ARE CHANGES TO THIS PRIVACY POLICY?

We may amend this Privacy Policy from time to time. If we make material changes in the way we collect or use information, we will notify you by posting an announcement on the Services or sending you an email.

CONTACT US

If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to support@fevo.com. We will make every effort to resolve your concerns.

FEVO, Inc.
12 Little W. 12th Street
New York, NY 10014

 

Last Updated: October 18, 2021