Privacy Policy
Effective date: August 25, 2023
This coupmaster Privacy Policy (“Privacy Policy”) describes our policies and procedures on the collection, use, disclosure, and sharing of your personal information when you use the coupmaster Platform. This Privacy Policy applies to activities by coupmaster, Inc. and its affiliates and subsidiaries (collectively “coupmaster,” “we” or “us”). Capitalized terms that are not defined in this Privacy Policy have the meaning given to them in our Terms of Service. coupmaster Inc. is the data controller of your personal information and is responsible for providing you with this Privacy Policy.
Overview
Information We Collect
We collect information directly from you, from third parties, and automatically through your use of the coupmaster Platform.
·Account and Profile Data. When you create an account and profile on the coupmaster Platform, we collect your name, email address, and other information you provide, such as topics that you know about or find interesting. You can choose to add your photo, country of residence, place of employment, education history, and any other information to your public-facing profile. Once you create a profile, others will be able to see certain information about your activity on the coupmaster Platform, such as the questions and answers you post, your followers and who you follow, topics of interest to you, and your credentials.
·Your Content. We collect the information and content that you post to the coupmaster Platform, including your questions, answers, comments, photos, and the edit history to your content. Unless you have posted certain content anonymously, your content, date and time stamps, and all associated comments are publicly viewable on the coupmaster Platform. Your content may be indexed by search engines and be republished elsewhere on the Internet in accordance with our Terms of Service.
·Communication Records. We maintain a record when you communicate with us via email, through the coupmaster Platform, or otherwise. The coupmaster Platform also provides a “Messages” feature that allows you to send direct messages through the coupmaster Platform to other users. We store these communications and information related to these messages, such as the date of the communication and to whom it was sent.
·Third Party Application Login. You can log into your coupmaster account using third party applications (e.g., Facebook, Google, and Apple). When you log in using this method, you allow us to we collect and process your name and email address associated with that third party application for authentication and identity verification purposes. You can also choose to import your contacts to your coupmaster account to connect with your friends on the coupmaster Platform. Note that your use of any third party application and the personal data you provide them is governed by their terms of use, privacy policies, and other policies.
·Cookies and Similar Technologies. We and our third party providers use cookies, log files, pixel tags, local storage objects, and other similar technologies to automatically collect information about your activities, such as your searches, page views, date and time of your visit, and other information about your use of the coupmaster Platform. We also collect information about your web browser or mobile device in connection with your use of the coupmaster Platform such as your browser type, type of computer or mobile device, browser language, IP address, mobile carrier, unique device identifier, and requested and referring URLs. We also receive information when you view content on or otherwise interact with the coupmaster Platform, even if you have not created an account. For more detailed information about these mechanisms refer to our Cookie Policy.
·Billing and Payment Data. We collect billing information if you subscribe to the coupmaster + Platform, and we collect payment information if you are a paid coupmaster creator via the coupmaster Partner Program. Depending on your location, this information may include your billing address, social security number, last four digits of your credit card or debit card, phone number, and email address.
·Platform Engagement Data. We collect platform engagement and browsing information, such as IP address, date and time stamp, user agent, coupmaster cookie ID, URLs visited, unique advertising identifiers (including mobile device advertising identifiers) or content identifiers (if applicable), time zone, and other information about your activity on the coupmaster Platform. We also collect this information from third-party sites and services that have embedded our coupmaster Ppixels (“Pixels”), widgets, plug-ins, buttons, or related technologies. Please visit our coupmaster Pixel Privacy Terms to learn more, including how to opt out. We may also receive these types of information about you from third parties, such as our partners (including ad partners) or coupmaster affiliates.
·Data From Advertisers. Third party advertisers who use our Ad Services may also provide us with information about you as part of their ad campaigns (e.g., email addresses) to create custom audiences for personalizing their ad campaigns or for measuring the effectiveness of their ads. To learn more, including about how to opt -out of certain Ad Services, refer to our Cookie Policy.
How We Use Your Information and Legal Basis for Processing
We process the information we collect for the following purposes, and under the following legal basis. You may decline to submit personal information through the coupmaster Platform, in which case we may not be able to provide certain services to you.
·Provide our Services. To provide you the services we offer on the coupmaster Platform and make the coupmaster Platform available to the public, communicate with you about your use of the coupmaster Platform, respond to your inquiries, provide troubleshooting, and for other customer service purposes. This is so we can comply with our contractual obligations to you.
·Personalization. To tailor the content and information that we or our third party content publishers or advertisers may send or display to you in the coupmaster Platform. We also use your information to suggest followers and content, to help others find your profile, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the coupmaster Platform. It is in our legitimate business interests to provide you with a customized experience.
·Billing and Payment. To collect payments (for example, if you are a coupmaster+ subscriber) and pay our service providers and content creators. This information is collected so that we can comply with our contractual obligations to you.
·Advertising. To display interest-based, retargeted, contextual, and behavioral advertising to you in the coupmaster Platform. We also may use your information, to improve our advertising and measurement systems so we can show you relevant ads and to measure the effectiveness and reach of ads and services. It is in our legitimate business interests to provide advertising. Where necessary, we will obtain your consent before engaging in this processing.
·Marketing and Promotions. For marketing and promotional purposes, such as to send you news, special offers, promotions, or to otherwise contact you about products or information we think may interest you, including information about third-party products and services. It is in our legitimate interest to provide more relevant and interesting marketing and promotions messages. Where applicable, we obtain your consent before sending such marketing communications and you can unsubscribe anytime.
·Enable Communications. To facilitate communications you send to us or to other users on the coupmaster Platform. We process information about who you have communicated with to better understand the use of our services. This processing is necessary to comply with our contractual obligations to you.
·Analytics. To gather analytics and metrics to better understand how users use the coupmaster Platform. We also use analytics data to evaluate and improve the coupmaster Platform, including the Ad Services and personalization, and to develop new products and services. It is in our legitimate business interests to make informed decisions about product development.
·Comply with Law. To comply with legal obligations, as part of our general business operations, and for other business administration purposes. This processing is necessary to comply with legal obligations and to serve our legitimate business interests in complying with the laws to which we are subject.
·Prevent Fraud and Misuse. To investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms of Service or this Privacy Policy. This processing is necessary to comply with legal obligations and to serve our legitimate interest in preventing misuse of the coupmaster platform, including through illegal activities and fraud.
·User Research. We may ask you to help us test new features or participate in surveys to help enhance your coupmaster experience. Your participation is voluntary, and we may use your personal information to communicate with you to seek your feedback.
How We Share Your Information
We share your information as outlined below, and where users have asked us to do so or otherwise consented:
Service Providers. We share your information with third-party service providers who use this information to perform services for us, such as payment processors, hosting providers, auditors, advisors, consultants, customer service providers, as well as service providers who assist us in providing the Ad Services. Key service providers we use include Amazon Web Services, Stripe, Zendesk, and Google.
coupmaster Affiliates. The information collected about you may be accessed by or shared with affiliates of coupmaster, Inc., whose use and disclosure of your personal information is subject to this Privacy Policy.
Business Transfers. We may disclose or transfer your information as part of any merger, sale, and transfer of our assets, acquisition or restructuring of all or part of our business, bankruptcy, or similar event.
Protection of Rights and When Legally Required. We may disclose information where we are required to do so by law, where we believe it necessary to respond to claims asserted against us or, comply with legal process (e.g., subpoenas or warrants), enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation, and protect the rights, property, or safety of coupmaster, its users, or others.
Your Content and Public Information. Your content, including your name, profile picture, profile information, and certain associated activity information is available to other users of the coupmaster Platform and may also be viewed publicly by non users. Public viewing includes availability to non-registered visitors and users may share your content across other sites. In addition, your content may be indexed by search engines. See the section below about Your Choices and Settings for information about how to control what information is shared or viewed by others.
Platform Engagement Information. We share with our advertisers and publishers aggregate statistics, metrics, and reports about the performance of their ads in the coupmaster Platform. This aggregated data may include the number of unique user views, demographics about the users who saw their ads or content, and conversion rates. Certain features allow you to share your personal information with advertisers on our platform if you choose to do so.
Research. We share aggregated or anonymized information with third parties for market research, reporting, and analytics. The information we share in this context cannot be used to identify individual users.
Do-Not-Track Signals. Please note we do not change system behavior within the coupmaster Platform in response to browser requests not to be tracked. You may, however, disable certain tracking by third parties as discussed in our Cookie Policy.
How We Secure and Store Your Information
Security. coupmaster maintains appropriate technical, administrative, and physical safeguards to protect the information we collect from unauthorized access, use, disclosure, destruction, and altercation.
Retention. We keep your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of time that enables us to maintain business records for audit purposes, comply with record retention requirements under the law, and defend or bring any existing or potential legal claims.
How We Transfer Your Information
coupmaster Inc. is headquartered in the United States, and has operations, entities, and service providers in the United States and throughout the world. As such, we and our service providers may transfer your personal information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it. Where we transfer your personal information outside of the European Economic Area or the United Kingdom, we rely on transfer mechanisms such as the European-Commission approved Standard Contractual Clauses. For more information on our transfer mechanisms, please contact us at the details below.
Your Privacy Rights
Depending on where you live and the local laws, you may have certain rights regarding your personal information. These may include rights to:
·Access your personal information
·Rectify the personal information we hold about you
·Erase your personal information
·Restrict our use of your personal information
·Object to our use of your personal information
·Opt out of targeted advertising
·Data portability
·Withdraw consent you have given at any time
·Lodge a complaint with your local data protection authority
If you would like to exercise your rights, please contact us at [email protected] or complete this form. You will need access to the email account associated with your coupmaster account in order to verify your identity and complete this process. You may update your account information anytime by adjusting the settings in your coupmaster account.Where applicable, you may also contact us using the contact details above to appeal any decision we make relating to your request to exercise your rights.
Your Choices and Settings
You can update your privacy settings, control the types of notifications and communications we send, and limit the information shared within the coupmaster Platform anytime. Here is further information about your choices and settings.
Your Content. You may edit or delete the answers that you post at any time. Any questions you have posted may remain on the coupmaster Platform. Other coupmaster users will be able to see the history of your content edits in your profile activity. Any deleted content will be removed from third-party sites from which it has been shared via coupmaster’s standard sharing features. However, we have no control over deletions or changes to your content if it has been shared manually by others.
Emails and Notifications. When you create a coupmaster profile you will receive email digests containing content from the coupmaster Platform that we believe may match your interests. You may also receive notices about other content from the coupmaster Platform that may be of interest to you, such as Spaces that you follow. In addition, users may be able to send communications and invites to their imported contacts through their coupmaster account, by email, text, or phone. You can opt out of receiving emails or other notifications from us by configuring your Emails and Notifications settings, but we will still send you transactional emails about your account.
Interactions with Other Users. You can adjust your settings to restrict who can send you messages on the coupmaster Platform or comment on your answers and posts.
Profile Discoverability. You can adjust your settings to block others from discovering your account by searching for your name or using your contact information.
Topics and Spaces. You can change Topics and Spaces that you are affiliated with within your profile.
Credentials. You can change your credentials (e.g., education history, place of employment) that are displayed in your profile or in connection with a specific answer.
Indexed Search. You can control whether your profile is indexed by search engines.
Deleted Account. If you choose to “Delete Account” in your profile settings, then all your content will be removed from public visibility on the coupmaster Platform, and it may not be restored by us. It may take coupmaster up to 14 days to process your account deletion request, and if you log back into your account during that time, your account may be reactivated.
Deactivated Account. If you choose “Delete Account” in your profile’s settings, then all your content will be removed from public visibility on the coupmaster Platform, and it may not be restored by us. If you choose to “Deactivate Account,” in your profile settings, then you will no longer receive any communications from us, and users will not be able to interact with you; however, your content will remain on the coupmaster Platform. You can reactivate your account at any time by logging in.
Opt out of Training LLMs. You can opt out of having your content on coupmaster (i.e. your answers, posts, and comments) used for Large Language Model (LLM) training purposes via your privacy settings.
Opt out of Targeted Advertising. Depending on your location you may have the right to opt out of having your personal information shared or used for targeted advertising. Please visit the “Your Privacy Choices” link on our site to learn more.
Children’s Privacy
We do not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to create a coupmaster account. If we become aware that we have collected personal information from a child under 13 we take steps to delete that account.
Additional Information for California Residents
This section provides information organized in accordance with the California Consumer Privacy Act, as amended by the California Privacy Rights Act, (“CCPA”) for residents of California about how we handle personal information. This Privacy Policy discloses the categories of personal information that we collect, use, and disclose in order to operate our business over the past 12 months.
·Collect. As we describe in more detail in the section above titled The Information We Collect, we collect personal information directly from consumers, automatically when consumers use the coupmaster Platform, and from other sources (such as from other users, partners, including ad partners, or our affiliated companies) and have collected the following categories of personal information in the past 12 months:
oIdentifiers, such as your name, email address, or IP address
oInternet or other similar network activity, such as browsing or search history related to your use of the coupmaster Platform
oPhotos or visual Information, such as your profile photo
oGeolocation data, such as approximate location data (we don’t collect precise geolocation, but can infer general location from your IP address)
oEmployment information, such as employment details you add to your profile
oEducation information, such as education details you add to your profile
oInferences drawn from other personal information
oCommercial Information, such as billing address and purchase history
·Use. The section above titled How We Use Your Information discloses that the categories of personal information we collect are used to provide our services, for personalization, for billing and payment, to provide advertising, to promote our services to you, to enable communications with other users, to analyze how our services are used, to comply with law, and to prevent misuse of the coupmaster Platform.
·Disclose. As we describe in more detail in the section above titled How We Share Your Information, we may disclose the following categories of personal information for business purposes with service providers, affiliates, law enforcement authorities, in the context of a merger or acquisition, as required by law, for the protection of rights, and as directed by you: (1) identifiers, (2) protected classification characteristics, (3) Internet or other similar network activity, (4) geolocation data, (5) photos or visual information, (6) employment information, (7) education information, and (8) inferences.
·We Do Not Sell Your Personal Information. We do not sell your personal information to third parties, nor do we sell personal information from users under 16 years old. For more information, please refer to the How We Share Your Information section above.
·Retention. We keep your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of time that enables us to maintain business records for audit purposes, comply with record retention requirements under the law, and defend or bring any existing or potential legal claims.
California Privacy Rights
California consumers have the right to make the following requests:
·Deletion. You have the right to request deletion of personal information that we have collected about you.
·Copy and Right to Know. You have the right to request a copy of the specific pieces of personal information that we have collected about you over the past 12 months. You also have a right to request a disclosure about the categories of information, sources, and purposes of collection, as well as categories of third parties we have shared it with over the past 12 months.
·Correction. You have the right to request that we correct inaccurate personal information that we maintain about you.
·Designated Agent. You may designate an agent to make a request on your behalf. That agent must have access to your coupmaster account for us to verify the request. The agent must also provide proof that you gave the agent signed permission to submit the request on your behalf.
·Opt out of having your personal information shared for targeted advertising. You can exercise this right by visiting the “Your Privacy Choices” link on our site.
You may exercise your CCPA rights through the online form here or by emailing us at [email protected]. You will need access to the email account associated with your coupmaster account in order to verify your identity and complete this process. Because we only collect limited data about individuals without an account, we are unable to verify requests from non-account holders to the standard required by the CCPA.
Non-Discrimination. coupmaster will not discriminate against you, including by denying or providing a different level or quality of services if you choose to exercise your privacy rights.
Privacy Request Metrics. To learn more about the volume and types of global privacy requests we received in the past 12 months, refer to our Privacy Requests Metrics page.
Contact Us
If you have any questions about our practices or this Privacy Policy, please contact our Data Protection Officer at [email protected] or send mail to:
coupmaster, Inc.
Privacy Policy Updates
We may occasionally update this Privacy Policy to reflect changes in our privacy practices or relevant data protection laws. We will notify you if we make any material changes and will revise the “Last Updated” date at the top of this Privacy Policy.