GOAL NUGGET PRIVACY POLICY

Effective date: August 1, 2019

This Privacy Policy sets forth how Goal Nugget (“we”, “us”, “our”) collects, uses, shares, processes, and protects information about you. By accessing the app, you agree that we may use and process the information we collect about you as outlined below. Please read this privacy policy carefully as it will help you make informed how we collect, use, process, and share your personal information.

Applicability. This Privacy Policy applies only to Goal Nugget and does not apply to any third-party apps or websites that you may access from this app or other online service.

Information We Collect.  When you access and use this app we collect information about you, how you use the app, and information about your internet browsing, as described in more detail below. Some of the information we collect is information that identifies you, either directly or indirectly, and information that can reasonably be linked to such identifying information. This type of information is referred to as “personal information”. Not all the information we collect is personal information, we collect certain information in aggregate or deidentified format, this type of information does not constitute personal information.   The types of personal information we collect about you include the following:

Identifiers. We collect information that can directly identify you such as your name, email address, postal address, survey responses, account or user name, account information, a cookie or device ID, and IP address.

Commercial Information. We may collect information from third parties such as service providers or data brokers about products you’ve purchased or considered purchasing and information about your purchasing history or patterns in general.

Internet or Other Electronic Network Activity. We collect information about your browser, your browsing history, your interaction with and use of this app, your interaction with other websites or apps, your interaction with advertisements on this and other apps and websites and similar user and usage data. We also collect analytics information through first and third-party analytics tools to analyze traffic and usage trends, log-file information which is automatically reported to us from your browser and includes information such as your browser type, which webpages you visit and how you interact with this and other apps and websites. We use cookies, web beacons, pixel tags, clear-gifs and similar technologies to collect information about page views and other internet or electronic network activity. If we send you email newsletters or marketing emails we will also collect information about your interaction with those emails, which may include whether or not you open them and the links you click on.

Geolocation Data. We collect IP address and postal address.

Inferences Drawn from the Information Listed Directly Above. We derive inferences about your preferences, interests and behaviors from the types of personal information we collect about you. We use these inferences to target you with specific advertisements that we think match your preferences and interests. More information about this type of targeted advertising, also called interest-based advertising, and how to opt-out of certain types of targeted advertising, can be found below.

how we Obtain your Information. We collect your personal information from a variety of sources. We collect identifiers such as your name, email address, postal address, and account information from you when you provide it to us, and unique identifiers such as cookie ID or device ID directly from your browser or the device you use to access this app. We collect commercial information form service providers or data brokers. Internet or other electronic network information and any geolocation data is collected automatically from your browser. When you access or use the app, log file information including your IP address, browser type, device type, clickstream information, pages you viewed, and how you interact with the app is automatically collected.  We may also collect similar information from emails sent to you which then help us track which emails are opened and which links are clicked by recipients.

How We use your Information. We collect your personal information for a number of business and commercial purposes. We use your information for operating the app, maintaining your account information, paying you for taking our surveys, communicating with you, delivering advertisements to you, and for other purposes as described in more detail below.

App and Website Analytics. We use primary and third-party analytic tools to help us analyze traffic and usage trends for our app. These tools collect information sent by your device to our app, which may include log file information such as referring or exit pages; number of clicks; how you interact with the app to help us improve, test, and monitor the effectiveness of our app; test new products and features; monitor metrics such as total number of visitors and traffic; diagnose and fix technology problems; and improve the app and to deliver more relevant marketing.

Advertising. We use cookies, web beacons, pixel tags, clear gifs and similar technologies to identify your browser and device to deliver advertising to you. We collect your unique device ID and cookie ID to collect information about how you use this app and track your use of, and interaction with, other apps or websites so that we may infer your preferences and interests from such use and interaction for the purpose of delivering targeted advertisements to your devices on apps you access, websites you view, and by email. To learn more about targeted advertising (also called interest-based advertising), analytics services and your choices, including how to opt-out of some third-party ads, advertising networks and ad servers, you may visit the DAA: WebChoices tool; AppChoices Tool.    

Provide you with the Services. We use your personal information to enable you to create and access your account, to participate in the surveys, to pay you for your participation, and to provide you with customer service and support.

Other Business Purpose. We may use your personal information for other business purposes including to detect security incidents and to protect against fraudulent or illegal activity.

How we Disclose Your Information. We may disclose your personal information to service providers who may only process your personal information to help us fulfill a business purpose. We may also share your information with other businesses for their own purposes, such as delivering their own marketing or providing marketing services to other parties in return for which we may receive some sort of value such as a share of ad revenue. For purposes of this privacy policy we refer to this type of sharing, in exchange for which we receive a monetary value, “sell[ing]” your personal information. We may also combine your information with other users’ personal information in a way that makes the personal information no longer associated with any unique user and instead relates only to a category or group, making it “aggregate” information, and we may share that aggregated information. Details about the personal information we “sell” and disclose for a business purpose, or how we may otherwise share your personal information is set forth directly below.

Information we “Sell”. We may “sell” your personal information, as the term is defined above, including information we have collected from cookies, web beacons, pixel tags, clear gifs and similar technologies including the inferences we have made about your interests and preferences, and, for example, any grouping we have placed you in as a result of those inferences, with third-party advertising partners and ad networks for their own use including, but not limited to, delivering interest-based advertising to you across the internet and across devices. The types of personal information we sell includes:

  • Identifiers, which may include a cookie ID, device ID, advertising ID, or other unique identifier.
  • Internet or Other Electronic Network Activity, which may include information linked to an identifier such as log file information, browsing history, apps or pages viewed, advertisements you’ve clicked.
  • Commercial Information, which may include information about past purchase history.
  • Inferences Drawn from the Personal Information we collect, which may include inferences we have made about your characteristic, interests, preferences, and categories we have included you in.

Information we Share for a Business Purpose. We may share your information with service providers and other third parties so that they may help us perform a business purpose such as, website analytics to help us understand how you use this app and how to improve the app; providing you with customer service; maintaining your account information; and processing transactions. We may also share your personal information such as information from cookie IDs, device IDs, log files, and location data, with service providers we engage to help us perform or deploy advertisements to you, including targeted advertising via display and email channels on our behalf. Our service providers will be given access to your information as is reasonably necessary to provide the business purpose under reasonable confidentiality terms. The types of information we share with service providers or other third parties for business purposes include:  

  • Identifiers, which may include a cookie ID, device ID, advertising ID, hashed email address, or other unique identifier.
  • Internet or Other Electronic Network Activity, which may include information linked to an identifier such as log file information, browsing history, apps or pages viewed, advertisements you’ve clicked.
  • Commercial Information, which may include information about past purchase history.
  • Inferences Drawn from the Personal Information we collect, which may include inferences we have made about your characteristic, interests, preferences, and categories we have included you in.

Other Ways we Share your Personal Information. We may share your personal information with law enforcement or as otherwise necessary to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to a third party as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all of part of our business, provided that the third party has agreed only to use your personal information in accordance with this privacy policy and for the purpose for which it was collected hereunder.

Your Choices. You have choices regarding the collection of your information, including:

Cookies.  You may refuse the use of cookies by selecting the appropriate settings in your browser. Note that opting out of cookies is specific to browsers and devices which means that if you use this app on different devices and from different browsers, you will need to opt-out of cookies on each such browser and device.  You should also be aware that you may not be able to opt-out of all cookies and continue to use the app because some cookies may be necessary to the functionality of the app.

Do Not Track. This app does not respond to “do not track” or similar signals.

Opting Out of Promotional Emails. If you receive promotional or marketing emails from us, you may opt-out of (or unsubscribe from) receiving further promotional or marketing emails by using the opt-out mechanism contained in such emails. Please allow 10 business days for us to process your opt-out request.

Opt-Out of Collection and Processing Geolocation Information. If you no longer want us to collect information about where you are located when you use the app, you may opt-out of collection, use, and sharing of any such information by sending an email to optout@goalnugget.com.

California Consumer Privacy Rights.  The California Consumer Privacy Act (“CCPA”) provides consumers (California residents) with specific rights regarding their personal information. You will be able to exercise these right beginning on January 1, 2020. This section describes your CCPA rights and explains how to submit a verifiable consumer request.

Right to Access and Data Portability. Consumers have the right to information about the categories of personal information we collect, where we collect it from, with whom we share and sell it, and to the specific pieces of personal information we have collected about you in the past 12 months (also known as a right to data portability). These rights include you right to have us disclose to you the following:

  • The categories of personal information we collect about you.
  • The categories of sources for the personal information we collect about you.
  • Our business or commercial purpose for collecting or selling your personal information.
  • The specific pieces of personal information we have collected about you.
  • The categories of third parties to whom your personal information is sold. If we sold your information, we will disclose to you a, in a separate list, the categories of third parties to which we have sold your personal information, and which categories of personal information we sold to each category of third party.
  • The categories of third parties with whom we share your personal information. If we share your personal information for a business purpose, we will disclose to you, in a separate list, the categories of third parties to whom we disclosed your personal information for a business purpose, and which categories of personal information we disclosed for each category of third party.

Right to Request Deletion. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies and we may deny your deletion request.

We may deny your deletion request if retaining the information is necessary for us or our service providers to provide you with the services and you continue to want us to provide you with such services; to exercise free speech, or ensure the right of another consumer to exercise free speech;  to identify and repair errors that impair existing functionality; to detect security incidents, protect against malicious, deceptive, fraudulent activity, or prosecute those responsible for such illegal activity; to comply with laws or a legal obligation; to make other internal and lawful uses of that information that are compatible with the context in which you provided it; to enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; or comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).

Right not to be discriminated. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not deny you goods or services; charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; provide you a different level or quality of goods or services; suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Opt-Out from the Sale of your Personal Information. As of January 1, 2020 you have the right to opt-out from our sale of your personal information. This privacy policy will be updated prior to January 1, 2020 to include a link to a web form through which you can easily exercise your right to deletion.

Exercising You Consumer Rights. As of January 1, 2020, you will be able to exercise your access, data portability, and deletion rights described above by submiting a verifiable consumer request to us through an electronic web portal, a link to which will be inserted in this section.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

CHILDRENS PRIVACY. Our app is intended for general audiences 16 years of age or older. We do not knowingly collect data from or market to children under 16 years of age.  By using the Site, you represent that you are at least 16 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Site. If we learn that personal information from users less than 16 years of age has been inadvertently collected, we will delete the data.

DATA RETENTION. We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).When there is no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

DATA SECURITY. We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process and to prevent its unauthorized use, disclosure, or access by third parties. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Apps is at your own risk. You should only access the services within a secure environment.

PRIVACY POLICY UPDATES. We reserve the right to change this Privacy Policy at any time by posting an updated Privacy Policy on our Site without advance notice to you. Any updated Privacy Policy will be effective immediately upon posting.