Linkable Networks, Inc. U.S.
    Privacy Policy

    Effective Date: November 11, 2016

    Notice to Linkable Customers and Users signed up as of November 10, 2016: On November 11, 2016, this Privacy Policy was changed. By agreeing to our Privacy Policy and continuing to use our Services, you are opting in to this change. As of November 11, 2016, we may disclose your email address and product detail information for an Offer (as defined below) redeemed by you to the applicable Sponsor (as defined below) for the purpose of such Sponsor verifying your redemption of its Offer, verifying your purchase of their products, goods and/or services, and/or assessing the performance of their Offers. Details on the disclosure of your email address and other uses that may be made of it other than as specified above for a particular Offer can be found in the Offer's terms and conditions. You are responsible for reviewing the Offer's terms before accepting or linking any Offer to your Payment Card (as defined below) or your Account (as defined below). This new use applies to all new users as of November 11, 2016.

    This Linkable Networks' privacy policy ("Privacy Policy") applies to (1) Linkable's use of the personal information we collect on our website www.mylinkables.com ("Site" or "MyLinkables") or via the iPhone or Android MyLinkables App, and (2) our "Services," which include implementing third party Offers, as described below and in our Terms of Service.

    By using the Site and/or the Service, you agree to the terms of this Privacy Policy. If you do not agree to these terms, please do not use the Site or the Service.

    Our Privacy Policy describes the types of personal information we collect when you use the Site or the Services, how we use this information and to whom and under what circumstances we may disclose it.

    Our Privacy Policy has 15 sections. You can go directly to any section by clicking on its link below.

    1. TRUSTe Program
    2. How our services work
    3. Information we collect
    4. How we use your information
    5. When and with whom we share your information
    6. Transaction monitoring
    7. Reviewing and updating your information
    8. Protecting your information
    9. Electronic communications
    10. Protecting children's privacy
    11. Your California Privacy Rights; California Do Not Track Disclosures
    12. International users
    13. Deactivating your account
    14. Changes to our Privacy Policy
    15. Links to other websites
    16. Contact us

    1. TRUSTe Program

    TRUSTe online privacy certification

    Linkable Networks has been awarded TRUSTe's Privacy Seal signifying that our Privacy Policy and practices have been reviewed by TRUSTe for compliance with TRUSTe's program requirements including transparency, accountability and choice regarding the collection and use of your personal information. TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions. If you have questions or complaints regarding our Privacy Policy or practices, please contact us at support@mylinkables.com. If you are not satisfied with our response you can contact TRUSTe here. The TRUSTe program covers only information that is collected through this Web site.


    2. How Our Services Work

    Linkable Networks is the underlying technology that implements Offers that reward consumers with loyalty points or cash back rebates (e.g., credits to a registered Payment Card) for shopping at specific retailers or purchasing specific products (collectively, "Offers" and each, an "Offer"). As used herein, "Payment Card" means your debit or credit card that you register with Linkable Networks. There are four types of Offers that are or may be supported by our platform, as more specifically set forth in our Terms of Service: (a) "Card Linked Offers", which are Offers that reward you with cash back rebates when you shop at specific retailers or purchase specific products, and for which we track your purchases automatically when you use your registered Payment Card, (b) "Scannable Offers", which are Offers that reward you with cash back rebates when you shop at specific retailers or purchase specific products, except that, your purchases are not tracked automatically; rather, you must submit your receipt to our platform as set forth in our Terms of Service, (c) "Loyalty Program Offers" which provide loyalty points for a particular loyalty program ("Loyalty Program") when you shop at specific retailers or purchase specific products, and for which we track your purchases automatically when you use your registered Payment Card , and (d) "Scannable Loyalty Program Offers", which are the same as Loyalty Program Offers in that they provide loyalty points when you shop at participating retailers or purchase specific products, except that, your purchases are not tracked automatically; rather, you must submit your receipt containing the products or services outlined in such applicable Offer in order to confirm your purchase to our platform as set forth in our Terms of Service. When you sign up with our platform and register your Payment Card, you will be able to participate in all types of the above Offers as you choose.

    A. Card Linked Offers and Loyalty Program Offers

    Once you sign up with Linkable Networks and register your Payment Card, you may select one or more Card Linked Offer(s) and/or a Loyalty Program Offer(s). When you select such Offers, we will detect that you are registered with the Linkable Network and ask if you want to register for such Offer using the same card on file. If you agree, then we will link your registered Payment Card to such Offers. This will allow you to shop at participating retailers and automatically earn towards your cash back rebate or earn loyalty points for doing so.

    For the Card Linked Offers and Loyalty Program Offers you have selected, we will share your Payment Card information and the pertinent terms of your selected Offer(s) with financial institutions or Payment Card networks that process your Payment Card transactions and/or other third parties aggregating Payment Card data and/or processing cash back rebates ("Payment Card Networks"). We share Payment Card information with Payment Card Networks via a PCI-compliant encrypted method as specified by the applicable Payment Card Network(s).

    B. Scannable Offers and Scannable Loyalty Program Offers

    Once you sign up with Linkable Networks and shop at retailers or purchase products specified in a Scannable Offer or Scannable Loyalty Program Offer, you will need to electronically submit your receipt containing the products or services outlined in such applicable Offer in order to confirm your purchase. "Scanned Receipt Purchase Data" means the information contained on your submitted receipt. We will accumulate in your Linkable Network account ("Account") the Scanned Receipt Purchase Data to allow you to earn toward your reward (e.g., your cash back rebate for Scannable Offers or loyalty points for Scannable Loyalty Programs (to be converted by or on behalf of the Sponsor of the Scannable Loyalty Program as set forth in the terms and conditions for the Scannable Loyalty Program). The applicable Loyalty Provider or Loyalty Program specifies what reward you will earn with such loyalty points in accordance with their Offer. If such reward is a cash award, once you qualify for redemption, we will send you an email notifying you thereof and asking you to register your Payment Card so that we may provide such reward to you.


    3. Information we collect

    A. Information that you provide to us

    We collect from you personal information (information that can be used to identify you as an individual) such as ZIP code, mobile phone number, name, email and/or payment information (such as account or Payment Card number and expiration date) when you register for the Services. We may also collect from you details of your transactions when you use your registered Payment Card at a participating retailer. You may also provide us with Scanned Receipt Purchase Data as set forth above.

    When you use our Services, we may provide you with the option to supply us with additional demographic information such as your age, gender, and zip code. We tie this demographic information to the personal information you submit to us. We do this to provide you with other Offers that may be relevant to you.

    B. Information we automatically collect

    When you use the Site or open one of our emails, we automatically record information about you using automated tracking technology such as clear gifs or web beacons, cookies, and IP addresses. These terms are described in more detail below.

    We automatically collect the following information:

    • Offers you link to in your account
    • Offers you redeem
    • web browser type
    • the website that referred you to us
    • the web pages you viewed on the Site
    • the dates and times you visited the Site
    • your response to messages the Service sends

    A cookie is a small text file that is stored on a user's computer for record-keeping purposes. We use cookies on this Site. We link the information we store in cookies to any personally identifiable information you submit while on our Site.

    We use both session cookies and persistent cookies. We use session cookies to make it easier and safer for you to navigate our Site. We set a session scoped authentication cookie that allows a user into the Site. We set a session scoped security context cookie that is used to control the behavior of the security software we use. A session cookie will expire when you close your browser, you click the log out button, or if you have been inactive on our Site for longer than 20 minutes.

    A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser's "help" file.

    We set an encrypted persistent cookie to identify you and gives you the ability to link an Offer to your default account without logging in.

    If you reject cookies, you may still use our Site, but your ability to use most areas of our Site and the Service will be limited. For example, you will not be able to log into your account if you reject cookies.

    We employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user's computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We do not tie the information gathered by clear gifs to our customers' personally identifiable information.

    We use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If you would like to opt-out of these emails, please see Electronic Communications.

    As is true of most Web sites, we use a third party tracking service to gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.

    Technologies such as: cookies, beacons, tags and scripts are used by Linkable Networks, Inc. and our marketing partners, affiliates, or analytics service providers. These technologies are used in analyzing trends, administering the site, tracking users' movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

    We use this information that we automatically collect, which does not identify individual users, to analyze trends, to administer the site, to track users' movements around the site and to gather demographic information about our user base as a whole.

    C. Direct communications with us

    When you send email or other communications to us, we may retain those communications in order to process your inquiries, respond to your requests and improve our services.

    D. Single Sign-On

    You can log in to our site 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. When you sign in with Facebook, we will receive only information in your public profile, your friends list and your email address. Services like Facebook Connect give you the option to post information about your activities on this Web site to your profile page to share with others within your network.

    E. Blogs

    Our Web site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at support@mylinkables.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

    F. Social Media Widgets

    Our Web site includes Social Media Features, such as the Facebook Like and Twitter button, and Widgets, such as the Share this button or interactive mini-programs that run on our site. 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. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

    G. Information about you provided to us by Payment Card Networks and Retailers

    For Card Linked Offers and Loyalty Program Offers, we also collect details of your transactions from the applicable Payment Card Network(s) ("Purchase Data") and/or from participating retailers ("Retailer SKU Data") when you use your registered Payment Card at a participating retailer in order for us to process the cash back rebate or loyalty points information necessary to process your redemption of the Offer. Purchase Data and Retailer SKU Data is sent to us with a unique identifier such as user token along with the details of your transaction.

    H. Information about you collected by our network advertising partners

    We partner with third party ad networks to display Offers on other sites ("Ad Network Partners"). Our Ad Network Partners use cookies and Web beacons to collect non-personally identifiable information about your activities on such sites to deliver Offers based upon your interests. This information is not shared with us. If you do not want this information used for the purpose of delivering targeted advertisements, you may opt-out with TRUSTe by clicking here or with the Network Advertising Initiative (NAI) by clicking here. Please note that if you elect to opt-out of receiving targeted advertisements, you will continue to receive generic non-targeted ads.

    I. Information about you provided by Loyalty Providers

    Linkable Networks powers third party-branded Loyalty Programs that distribute and implement their own and/or third party Loyalty Programs and/or Scannable Loyalty Programs ("Loyalty Providers"). If you choose to join the Loyalty Program or Scannable Loyalty Program of, or distributed by, a Loyalty Provider, any information that you provide to such Loyalty Provider may be shared with Linkable Networks to the extent necessary to implement your participation in such Loyalty Program.


    4. How we use your information

    A. We may use your personal and other information for any of the following purposes:

    • to provide our Services to you, including the display of personalized content, opportunities for savings and new offers sent by email or text message, and advertising;
    • to help address problems with and the functioning of our Site and our Services;
    • to monitor and conduct internal reviews of our Site our Services;
    • to help us better understand and improve the use of our Site and the Service, and to develop new services;
    • to protect the security and integrity of the Site and our Services; and
    • to contact you, if necessary or at your request.

    B. Specific Uses of Data

    Notwithstanding anything else in the Linkable Networks Terms of Service or this Privacy Policy, we will use your Payment Card and other information you provide to us, the Purchase Data provided by Payment Card Networks, the Retailer SKU Data provided by retailers and/or the Scanned Receipt Purchase Data provided by you to enable your participation in the applicable Services. Specifically:

    • Linkable Networks will use your Purchase Data, Retailer SKU Data and/or Scanned Receipt Purchase Data to confirm a qualifying purchase or return in order to match transactions to confirm whether you qualify for redemption of an Offer.
    • Linkable Networks may use your Purchase Data, Retailer SKU Data and/or Scanned Receipt Purchase Data to identify other Offers that you may be interested in that are part of a Linkable Networks program, including by creating a profile of your transactions and interests, and sending you such Offers by text or email.
    • As set forth in Section 5 (When and with whom we share your personal information), Linkable Networks shares your personal information with business partners to help them understand the performance of their Offers and to confirm redemptions and with other third parties as set forth in Section 5.

    5. When and with whom we share your personal information

    A. We may share aggregated, non-personal information with our related companies, consultants, advertising clients, Sponsors and their advertising agencies, service providers, advertising agencies and other third parties for various purposes, such as delivering and improving our Services and for Site analytics and performance reporting. As used herein, "Sponsor" means a manufacturer, retailer or other entity making an Offer.

    B. We may share your personal information in our possession with other parties under the following circumstances:

    • Service Providers. To service providers to enable such service providers to enable us to provide the Services to you, including but not limited to: (a) providing us with your Purchase Data and/or Scanned Receipt Purchase Data, (b) delivering Offer redemptions and savings to your Payment Card(s), Account and loyalty accounts, and/or (c) collecting your feedback and administering technical support to provide customer support to you. These companies work with us under confidentiality agreements and are prohibited from making any other use or disclosure of your personal information (unless they otherwise independently possess or have lawful access to such information).
    • Payment Card Networks. We share your Payment Card number and expiration date with Payment Card Networks via a PCI-compliant encrypted method as specified by the Payment Card Networks in order for such Payment Card Networks to track your transactions at participating retailers and to return Purchase Data to us.
    • Purchase Data. Except as provided above, Personal information combined with your Purchase Data will not be disclosed to any third party.
    • Retailer SKU Data. Except as otherwise provided in this Section 5.B, personal information combined with or included in your Retailer SKU Data will not be disclosed to any third party.
    • Scanned Receipt Purchase Data. Except as otherwise provided in this Section 5.B, your personal information, including personal information included in your Scanned Receipt Purchase Data, will not be disclosed to any third party.
    • Email. If you authorize us to disclose your email address to a Sponsor of an Offer, once you redeem such Offer, we may disclose (a) your email address and your Purchase Data (or portions thereof) with such Sponsor, but these will be provided to such Sponsor separately and not in a combined form, (b) your email address and your Retailer SKU Data (or portions thereof) with such Sponsor, but these may be provided to such Sponsor together or in a combined form, and/or (c) your email address and your Scanned Receipt Purchase Data (or portions thereof) with such Sponsor, but these may be provided to such Sponsor separately, together or in a combined form. We share such email address with Sponsors for the purposes of such Sponsors verifying the redemption of their Offers, verifying your purchase of their products, goods and/or services and/or to assess the performance of their Offers. You may provide us such authorization by accepting the terms of an Offer containing such authorization.
    • To applicable third parties, if we determine that there has been a violation of our Terms of Service, Privacy Policy or other posted policies.
    • To applicable third parties, if we have reason to believe that such disclosure is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference (either intentionally or unintentionally) with our rights or property, other users of the Services or anyone else that could be harmed by such activities.
    • To respond to judicial process and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, cyber security, as permitted by law, or otherwise as required by law.
    • Linkable Networks and/or its Payment Card Networks may provide your personal information, Purchase Data, Retailer SKU Data and/or Scanned Receipt Purchase Data or other information associated with your purchases, in response to a request from a government authority or a payment organization involved in a transaction with you or a retailer.
    • In the event we file for bankruptcy and another party purchases our company or assets in whole or part or we are purchased or merged into another entity.

    C. You are responsible for reviewing the Offer's terms before accepting or linking any Offer to your Payment Card.


    6. Transaction Monitoring

    By registering a Payment Card in connection with transaction monitoring, you authorize Linkable Networks to share your Payment Card information with the applicable payment network(s) (such as MasterCard, VISA, and American Express) so they know you enrolled. You authorize the applicable Payment Card Network(s) and Linkable Networks to monitor transactions on your registered Payment Card(s) to identify qualifying purchases in order to determine whether you have qualified for or earned an Offer linked to your Payment Card, and for the above Payment Card Networks to share such transaction details with Linkable Networks to enable your Offer(s). You may opt-out of transaction monitoring on specific Payment Card(s) you have registered by deleting your card from within the "My Account" page.


    7. Reviewing and updating your information

    You may view and modify all your information within your "My Account" settings at www.mylinkables.com. We encourage you to promptly update or delete your information if it changes. Additionally, you may file a request for us to make updates to your information via the feedback form that is integrated within our Site or by emailing us at support@mylinkables.com. Please indicate what information you would like to update or delete when you contact us.


    8. Protecting your information

    We take security seriously and take numerous precautions that are intended to protect the security of your information. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee it's absolute security. We encrypt the transmission of information using secure socket layer technology (SSL).


    9. Electronic communications

    We will send you Administrative Communications and Promotional Communications. "Administrative Communications" are emails and/or text messages related to your activity on the Site, and include messages regarding your account, requests or inquiries. For example, if you register on the MyLinkables.com then we will send you an Administrative Communication to confirm that you successfully linked an Offer to your account and when you have successfully redeemed an Offer and when the earned reward is settled back to your Payment Card.

    "Promotional Communications" are emails and/or text messages that advertise our products and services, including exclusive Offers, and/or the products and services of our Sponsors and affiliates.

    You can opt-out of such electronic communications by texting "STOP" to text messaging and by clicking "unsubscribe" on emails.


    10. Protecting Children's Privacy

    Protecting the privacy of children is especially important to Linkable Networks. Our Services are not directed to or intended for use by children under the age of 18. As such, we do not knowingly or intentionally collect personal information from children under 18 on our Site. If you believe we have inadvertently collected information from a child under 18, please contact us using the contact information listed.


    11. Your California Privacy Rights; California Do Not Track Disclosures

    If you are a resident of the State of California, under California Civil Code sections 1798.83-1798.84, you have the right to ask us for a notice identifying the categories of personal information that we share with our affiliates and/or third parties for direct marketing purposes. Since we do not share personal information with affiliates or third parties for direct marketing purposes, we are exempt from this requirement. We currently do honor Do Not Track signals.


    12. International Users; Transfer of Information to the U.S.

    Our Site and Services are provided and hosted in the United States. If you access our Site or use our Services from outside the United States, your personal information will be transferred and processed in the United States in accordance with this Privacy Policy. Please note that the U.S. has not been recognized as providing an adequate level of protection according to EU data protection requirements, but we will take all steps reasonably necessary to ensure that personal information is treated securely as described in this Privacy. By accessing the Site, using our Services or providing personal information, you expressly and unambiguously consent to such transfer, processing, storage and disclosure in the U.S.


    13. Deactivating your account

    If you wish to cancel your account or request that we no longer use your information to provide you Services, you may delete your account by using the "Close my account" option on the "My Account" page or by contacting us at support@mylinkables.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.


    14. Changes to our Privacy Policy

    We may make periodic changes to this Privacy Policy, so please review it frequently. The date last revised will always appear at the top of the Privacy Policy. If we change our Privacy Policy in a material way, we will notify you via email and post a prominent notice on our Site before using your information in a materially different manner than claimed when your information was collected by us.


    15. Links to Other Web Sites

    Our Site includes links to other Web sites whose privacy practices may differ from those of Linkable Networks. If you submit personal information to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any Web site you visit.


    16. Contact us

    Linkable Networks values your privacy. We encourage you to contact us if you have any questions, comments, or concerns about this policy. You may contact us by e-mail at support@mylinkables.com or by U.S. Mail at:

    Linkable Networks Privacy
    Attn: Privacy Officer
    51 Melcher Street
    1st Floor
    Boston, MA 02210