INFORMATION YOU PROVIDE TO US
To maximize your Platform user experience, we may ask you to provide information about yourself including information that could be used to personally identify or contact you (such as your name, telephone number, email address, or home address) (“Personal Information”). We may collect Personal Information at various times over the course of your use of the Platform, including but not limited to, when you create an Account, register with a Brand as a fan, post on the Platform or other social media sites, redeem rewards, access content, participate in a survey, promotion or other feature of the Platform, request information, submit comments, or otherwise use the Platform. “Non-Personal Information” means data that is not associated with or linked to your Personal Information; Non-Personal Information does not, by itself, permit the identification of individual persons and, therefore, this policy does not limit or restrict in any way our ability to use or disclose Non-Personal Information. If you do not consent to our unrestricted use of Non-Personal Information, please delete your Account immediately.
The Platform includes functionality for processing payments and transactions in SUGAR Tokens between Sweet Wallets on the Platform. We may collect and maintain financial information required to execute these transactions including any information that might be necessary to comply with Anti-Money Laundering and local, state and Federal tax laws.
When you make an On-Platform Purchase (“OPP”) via a third party form of payment such a credit card, debit card, Paypal account or other approved payment, you will need to submit your financial and other billing information for secure processing directly to a third party payment service who will be clearly identified to you prior to the transaction. Sweet will not capture, record or in any way store or process your payment account details for the form of payment used in these transactions. However, our third-party processor may share non-sensitive financial or billing information (e.g. records and receipts) with us in order for us to verify and complete transactions and track and process payments for any fees collected by such third parties.
INFORMATION RECEIVED FROM THIRD PARTIES
You can navigate and post to many of your own social media and other application accounts on third party services through the Platform. To enable Platform features that require access these accounts, you may be asked to provide us your access credentials for that third party service. Sweet may store your access credentials and/or an access token or similar Oauth credentials obtained from the third party service for any such account (collectively, “Connected Accounts”), so that you are able to access those third party services without entering your access credentials again. You are solely responsible for deciding which of your accounts on third party services you connect to the Platform. If you do not wish to provide Sweet access to any given account, you must cancel the access in your Sweet Account and not reconnect by declining to enter your credentials when prompted.
If you choose to enable any Connected Accounts, you allow us to monitor any Connected Account and collect (or the third party to share) data about you and your activity through using your account credentials which you have provided to Sweet (collectively, “Connected Account Data”). Connected Account Data may include any data made available through the third-party service’s application programming interface (API) or publically available on their service, such as your public identity on their service, the content of your social posts, play lists, lists of your friends and followers, “likes”, location and other activity and usage data.
The information we collect about you through the Platform may also be supplemented with information from third parties.
INFORMATION WE COLLECT AUTOMATICALLY
HOW WE USE INFORMATION WE COLLECT
We use the information we collect from and about you for a variety of business purposes, including to verify that you have completed actions to earn rewards; to facilitate SUGAR transactions on the Platform; to personalize and enhance your experience such as tailoring content, recommendations, advertisements or the Reward shopping experience; to provide access to certain features of the Platform; to communicate with you about your account and changes to any of our policies; to comply with various local, state and Federal laws; and to help us understand how we can improve the Platform and other internal business purposes. In addition, we may use your Personal Information for other purposes for which you otherwise provide your consent.
SHARING OF PERSONAL AND NON-PERSONAL INFORMATION
We may share non-Personal Information, such as aggregate user statistics, demographic information, anonymized Usage Information or Connected Account Data, with third parties (including Brands, Affiliates, and other partners, service providers and advertising partners) without your consent.
In addition, we may share your information in the following circumstances:
Third Parties Providing Services On Our Behalf: In order to make various features, services and materials available to you through the Platform, and to respond to your request, User Actions, Reward transactions, and inquiries, we may share your Personal Information with third parties that perform functions on our behalf (or on behalf of our Brands or Affiliates). These may include Brands and their Affiliates, companies or individuals that host or operate the Platform, execute transactions or fulfil orders, analyze data or provide customer service, third-parties services associated with your Connected Accounts, and advertisers.
Your Feedback. Any non-personal information you provide to us, either publicly or privately, as feedback or in response to other user’s feedback, including, but not limited to, feedback, data, answers, questions, comments, suggestions, plans, ideas or the like (collectively “Feedback”), shall be deemed to be non-confidential and we assume no obligation to protect such Feedback from disclosure. You understand, acknowledge, and agree that if you submit any such Feedback to us, it shall in no way prevent Sweet, Brands, the Platform and our Affiliates, from using such Feedback for any purpose whatever, and we shall be free to reproduce, use, disclose and distribute such Feedback without restriction.
YOUR CHOICE AND ACCESS
E-mail and mobile phone numbers are important communication channels for the Platform. By creating an Account you consent to receive communications from us and our Brands and Affiliates via phone, e-mail, SMS texts (“External Communications”) or by posting notices on the Platform (“Platform Communications”) (collectively “Communications”). You may opt-out of any External Communications from the Platform that are not Account or Service related. To do so, either modify your account settings, send us an email at firstname.lastname@example.org, or follow the removal instructions in the specific communication that you receive. Your opt-out request will be processed within 10 business days of the date on which we receive it. To be removed from Platform Communications or Account and Service related Communications, you may request deletion of your Account and discontinue use of the Services. To delete your Account please submit this request via the Contact Us area and follow the procedures provided. We are not responsible for Communications sent by a Brand or Affiliate except when sent using the Platform.
You may at any time request that we remove a Brand from Your Joined Brands and end sharing of your information with that Brand as described above by modifying your account Settings or sending us an email at email@example.com. If a Brand is removed from Your Joined Brands, you will no longer be able to access the Platform functionality on that Brand’s website or otherwise receive Reward Tokens from that Brand for User Actions.
You may at any time request that we not share your Personal Information with third parties other than Your Joined Brands.
To modify, verify or delete any of your Personal Information that we have collected including the User Profile which is shared with Your Joined Brands, you may edit your account user information or contact us at the above email address.
In accordance with our routine record keeping, we may delete certain records that contain Personal Information you have submitted to us. We are under no obligation to store your Personal Information indefinitely, and we disclaim any liability arising out of, or related to, the destruction of your Personal Information. Please note that it is not always possible to completely remove or delete all of your information from our databases without retaining some residual data because of backups and other reasons.
Finally, please be aware that we do not control any privacy settings and preferences maintained by third parties. If you wish to make changes to those settings and preferences, you must do so through the options provided by the third party.
ADVERTISING/BEHAVIORAL TARGETING; HOW TO OPT OUT
If we deploy targeted advertising on our Platform and you do not want to receive the benefits of targeted advertising, you may opt out of some network advertising programs that use your information by visiting the NAI Opt-Out Page at http://www.networkadvertising.org. Please note that even if you choose to opt out through the NAI Opt-Out Page, you may still see advertisements while you’re browsing online. However, the advertisements you see may be less relevant to you and your interests. Additionally, many network advertising programs allow you to view and manage the interest categories they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. The NAI Opt-Out Page provides a tool that identifies its member companies that have cookies on your browser and provides links to those companies.
SECURITY OF YOUR INFORMATION
Sweet follows industry-standard security measures (e.g. firewalls, encryption tools) on Platform and our technical infrastructure to protect against the loss, misuse and unauthorized alteration of Personal Information in our possession and control.
Please be aware that, although we endeavor to provide security for information in our possession and control, no security system can prevent against all potential security breaches, and we bear no liability for uses or disclosures of Personal Information or Non-Personal Information arising in connection with the theft thereof. Likewise, Platform users are responsible for safeguarding the confidentiality of passwords (including those to access Facebook, Instagram, Spotify and Twitter), and we bear no liability for access to, or use or disclosure of, Personal Information, if such access, use or disclosure arises in connection with the theft or disclosure (whether intentional or negligent) of a password. Please note, however, that we cannot ensure the security of any information you transmit to us or that we store. You use the Platform and provide us with your information at your own risk.
The Platform is not intended for use by users under the age of 13. Sweet will not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to create an Account on the Platform with or without parental consent. In the event that we learn that we have collected Personal Information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us immediately at firstname.lastname@example.org.
CONSENT TO PROCESSING AND TRANSFER OF INFORMATION
We operate the Platform in the United States and Brands may be in the United States or other countries. Our use of your information may involve the transmission of data on an international basis. If you are located outside of the United States, please be aware that information we collect may be transferred to and processed in the United States. By using the Platform, or providing us with any information, you consent to the collection, processing, maintenance and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside and/or are a citizen.
Any non-personal content you provide through the Platform by e-mail, including, but not limited to, feedback, data, answers, questions, comments, suggestions, plans, ideas or the like (collectively “Feedback”), shall be deemed to be non-confidential and we assume no obligation to protect such Feedback from disclosure. You understand, acknowledge, and agree that if you submit any such Feedback to us, it shall in no way prevent Sweet, Brands, the Platform and our Affiliates, from using such Feedback for any purpose whatever, and we shall be free to reproduce, use, disclose and distribute such Feedback without restriction.