Couwalla Privacy Statement
Last Updated: July 2020
TYPES OF PERSONAL DATA WE COLLECT
We collect information about you in a range of forms, including Personal Data. As used in this Policy, “Personal Data” is as defined in the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and California Consumer Privacy Act (CCPA), and this includes any information which, either alone or in combination with other information we process about you, identifies you as an individual.
We collect the following types of Personal Data:
- Contact Information that allows us to communicate with you, such as your name, postal addresses, email addresses, social media website user account names, telephone numbers, or other addresses at which you receive communications from or on behalf of Couwalla.
- Relationship Information that helps us to understand who you are and what types of coupons you might like. This includes lifestyle, preference, and interest information; location information related to your state/province, city, or neighborhood; the types of coupons that interest you; information collected from social media interactions (such as via Facebook Connect); and demographic information (e.g., birth date, age, gender).
- Device data – is information about how you interact with the Sites, such as the coupons you view and redeem and the stores you prefer; type of device, operating system, IP-addresses and advertising ID’s, your location, web and mobile network data and information, information on how long you spent on a page, access times and information about your use of and actions on the Sites.
- Location Information to help us offer you coupons for merchants nearby, if you have activated one of our mobile Sites and permitted your mobile or another location-aware device to transmit location data.
- the Personal Data that may be contained in any video, message, comment or another submission you upload or post to the website; Please note that any information and materials that you post or disclose using such functionality will become public information, and may be available for other users of the services and the general public to record, access, use, alter, manipulate or disclose to other individuals or social networking sites such as Facebook or YouTube. We are not responsible for such recording, access, use, alteration, manipulation or disclosure. We urge you to be very careful when deciding to disclose your Personal Data through the messages, comments and other submissions.
- Information from Social Networking Websites. Our website includes interfaces that allow you to connect with social networking sites (each an “SNS”). If you connect to an SNS through our website or mobile application, you authorize us to access, use and store the information that you agreed the SNS could provide to us based on your settings on that SNS. We will access, use and store that information in accordance with this Policy. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable SNS.
We do not collect any extra data but only that information that is necessary for the purpose of providing our services to you.
Please be aware that the list of information types mentioned above is not exhaustive. Additional information about you might be gathered in another way, for instance by your contacting our support hotline or taking part in surveys, etc.
SPECIAL CATEGORIES OF PERSONAL DATA
We do not intentionally collect any special categories of Personal Data, such as political opinions, religious beliefs, health information, racial or ethnic origin etc. Such information can be processed only if the law requires so or the data subject has given express consent for such processing.
HOW WE USE THE INFORMATION
We use your Personal Data for the limited purpose of providing effective and personalized experience when using our Sites and services. For example:
- to operate, maintain, and improve our Sites, products, mobile application and services;
- to keep Couwalla products, services and integrations safe and secure;
- to protect Couwalla’s or others’ rights or property;
- to provide you with location features and services, like telling you and your friends when something is going on nearby;
- to measure or understand the effectiveness of ads you and others see, including to deliver relevant ads to you;
- to make suggestions to you and other users on Couwalla, such as: suggesting that your friend use our contact importer because you found friends using it, suggesting that another user add you as a friend because the user imported the same email address as you did, or suggesting that your friend tag you in a picture they have uploaded with you in it; and
- for internal operations, including troubleshooting, data analysis, testing, research and service improvement.
- to respond to your comments and questions and to provide customer support;
- to comply with applicable laws and lawfully requests of government bodies or courts;
- with your consent, to send you marketing e-mails about upcoming promotions, and other news, including information about products and services offered by us and our affiliates. You may opt-out of receiving such information at any time: such marketing emails tell you how to “opt-out.” Please note, even if you opt-out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails administrative information about your account with us (if you have one) and our business dealings with you.
AUTOMATED DECISION MAKING AND PROFILING
We do not use your Personal Data for the purposes of automated decision-making. However, we may do so in order to fulfill obligations imposed by law, in which case we will inform you of any such processing and provide you with an opportunity to object.
HOW LONG YOUR PERSONAL DATA IS STORED
We store your Personal Data for as long as it is necessary to provide products and services to you. Typically, information associated with your account will be kept until your account is deleted. You may request deletion of your Personal Data by contacting us. We are able to consider your request and delete your data within thirty days. Nevertheless, we may retain some of your Personal Data for the purpose to comply of with technical and legal requirements related to the security, integrity and operation of our services. Please be aware that applicable law may prevent us from returning or destroying all or part of the Personal Data or require storage of the Personal Data for some period to comply with AML requirements, tax reporting or auditing. In which case we will protect the confidentiality of the Personal Data and will not actively process the Personal Data anymore after the termination of the legal relations with you.
If you wish to cancel your account or request that we no longer use your Personal Data to provide you services please contact us at firstname.lastname@example.org.
PERSONAL DATA SHARED WITH THIRD PARTIES
We will not share any Personal Data that we have collected from you except as described below. We may engage third-party service providers to work with us to administer and provide the Services. These third-party services providers have access to your Personal Data only for the purpose of performing services on our behalf and are expressly obligated not to disclose or use your Personal Data for any other purpose.
We may share aggregated information and non-identifying information with third parties for industry analysis, demographic profiling and other similar purposes. Information that we collect from our users, including Personal Data, is considered to be a business asset. As a result, if we go out of business or enter bankruptcy or if we are acquired as a result of a transaction such as a merger, acquisition or asset sale, your Personal Data may be disclosed or transferred to the third-party acquirer in connection with the transaction.
We may also transfer your Personal Data to our professional advisers (such as lawyers, accountants, auditors, it consultants, management consultants), who is under a professional obligation to maintain confidentiality and security of Personal Data.
Your personal information may be shared with third parties if so required by applicable laws, regulations, instructions we must obey or in the response of valid court order or requirement of other government bodies.
We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our website.
We use two broad categories of cookies: (1) first-party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our Sites; and (2) third party cookies, which are served by service providers on our website, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.
Our website uses the following types of cookies for the purposes set out below:
These cookies are essential to provide you with services available through our website and to enable you to use some of its features. For example, they allow you to log in to secure areas of our website and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
These cookies allow our website to remember choices you make when you use our website, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our website which you can customize. The purpose of these cookies is to provide you with more personal experience and to avoid you having to re-enter your preferences every time you visit our website.
Analytics and Performance Cookies
These cookies are used to collect information about traffic to our website and how users use our website. The information gathered does not identify any individual visitor. It includes the number of visitors to our website, the websites that referred them to our website, the pages they visited on our website, what time of day they visited our website, whether they have visited our website before, and other similar information. We use this information to help operate our website more efficiently, to gather broad demographic information and to monitor the level of activity on our website.
Google Analytics uses its own cookies. It is only used to improve how our website works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies
You can find out more about how Google protects your data here: https://policies.google.com/privacy
You can prevent the use of Google Analytics relating to your use of our website by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
Targeted and advertising cookies
These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third-party advertisers can place cookies to enable them to show adverts which we think will be relevant to your interests while you are on third party websites.
Social Media Cookies
These cookies are used when you share information using a social media sharing button or “like” button on our website or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
You can disable cookies which remember your browsing habits and target advertising at you by visiting http://www.youronlinechoices.com/uk/your-ad-choices
You can opt-out of being targeted by certain third-party advertising companies online at https://optout.networkadvertising.org/?c=1
If you choose to remove targeted or advertising cookies, you will still see adverts but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored adverts from companies that are not listed.
Please be aware that if you do not accept our cookies, you may experience some inconvenience in your use of our website. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our website.
If you access any of our Sites through a mobile device or mobile browser, you may manage how your Location Information is shared with Couwalla through the device itself. You may also manage how your mobile device or mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your mobile device and mobile browser settings.
SECURITY OF PERSONAL DATA
Couwalla has implemented an information security program that contains administrative, technical and physical controls that are designed to reasonably safeguard Personal Data. To keep your data safe we apply firewall and data encryption protection and physical authorization control system, just to name a few. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the Internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us.
We will notify you of Personal Data breaches where the breach is likely to create significant risks to your rights and freedoms (including any unauthorized or accidental access) without undue delay after becoming aware of a Personal Data breach (except otherwise provided by applicable law).
We warrant that:
- we will not sell your Personal Data; or
- we will only collect and process Personal Data which is necessary to provide our service to you.
You have the following rights as a data subjecting in regard to your Personal Data:
- to know what your Personal Data we process and in what way;
- to ask us to erase or delete all or some of your Personal Data. Note that not all Personal Data may be deleted due to security or legal reasons. Also, you must complete the authentication procedure you before we can fulfil your request.
- to ask us to change, update or fix your Personal Data if it is inaccurate.
- to ask us to stop using all or some of your Personal Data (e.g., if you believe that we have no legal right to keep using it).
- to ask us to provide a copy of your Personal Data we keep unless this adversely affects the rights and freedoms of other users.
- to object the usage of Personal Data for direct marketing purposes or automated decision-making;
- and other rights established in GDPR or CCPA and other legal acts.
If you’re not happy with how we are processing your Personal Data, please let us know by sending an email to email@example.com.
When making a request to us you should specify your name, surname, contact details, relevant information, which would indicate why you believe that your Personal Data must be deleted, changed or it’s processing be limited. After examining your request, we will report the results within a reasonable time and, if the decision is positive, state the actions were taken to satisfy your request.
Processing of Personal Data is permitted only under the several legal bases provided by GDPR and CCPA.
By providing you with our services, we process your Personal Data based on:
- Contract: We can process Personal Data to fulfil our contractual obligations (e.g. if you and we enter into terms and conditions when you creating an account on our Sites).
- Legitimate interest: We can rely on this legal basis when we carry out procedures which are the part of our Services or which are transparent, expectable and are the stable business practice.
- Consent: We can request from you consent for data processing when we process the sensitive Personal Data or if so required by law.
This list is not exhaustive and we may use other ground provided by applicable law if none of the above-mentioned basis can be applied.
DISCLAIMER OF CERTAIN LIABILITIES
The information available via the website may include typographical errors or inaccuracies. The Company shall not be liable for these inaccuracies and errors.
The Company makes no representations about the availability, accuracy, reliability, suitability, and timeliness of the Content contained on and services available on the website. To the maximum extent allowed by the applicable law, all such Content and services are provided on the “as is” basis. The Company disclaims all warranties and conditions regarding this Content and services, including warranties and provisions of merchantability, fitness for a certain purpose.
To the maximum extent permitted by the applicable law, in no event shall the Company be liable for any direct, indirect, incidental, consequential, special, punitive damages including, but not limited to, damages for loss of enjoyment, data or profits, in the connection with the enjoyment or execution of the website in the context of the inability or delay to enjoy the website or its services, or for any Content of the website, or otherwise arising out of the enjoyment of the website, based on contract and non-contract liability or other reason.
NOTICE TO RESIDENTS OUTSIDE THE USA
Couwalla does not intend that any portion of the Sites will be accessed or used by children under the age of thirteen, and such use is prohibited. By using the Sites, you represent that you are at least thirteen years old and understand that you must be at least thirteen years old in order to create an account and purchase the goods or services advertised through the Sites. We will promptly delete information associated with any account for which we obtain actual knowledge that the registered user associated with the account is not at least thirteen years old.
276 Fifth Avenue, Suite 704-375
New York, NY 10001