YOUR PRIVACY IS
IMPORTANT TO US

teamDigital Promotions, Inc. Privacy Policy
Last Revised: January 1, 2020

teamDigital Promotions, Inc. (“teamDigital”) is a company that helps other businesses operate sweepstakes, contests, promotions, loyalty programs, and digital marketing campaigns (“Promotions”). Such Promotions gather personally identifiable information from individuals who choose to enter a particular Promotion and anonymous data regarding the Promotion itself. Please read below and learn how we protect, share and use the information we collect about and from you on our websites, teamDigital mailboxes, and points of entry offline (“Platforms”).

What Information Do We Collect?

Personal Information
When you enter into one of our client’s Promotions, we collect the personal information you give us or permit us to access. The information may include, but is not limited to, your name, image, birth date, email and physical address, telephone number, gender, contact lists, social media information and profile, and location (GPS) information (“PII”). PII collected by us on our client’s behalf will be used by the client in accordance with their privacy policy.

Usage Information (Non-PII)
teamDigital, on behalf of our clients and for our own purposes, may also collect information about your computer or device configuration such as, but not limited to, your browser type, operating system, or ISP domain name. teamDigital may collect information about the site you last visited prior to visiting our Platforms or about your activity during your visit to one of our Platforms as well as information collected by website visitor tracking tools such as “cookies,” “web beacons,” “pixels,” Internet tags and other navigational data. More information about our online activity tracking tools is provided below.

Cookies
teamDigital uses browser cookies in order to improve your user experience by enabling our Platforms to ‘remember’ you or your preferences, either for the duration of your single visit to a website (using “session cookies”) or during additional visits (“persistent cookies”). A cookie is a small text file that is stored on your computer or device by a website. Every cookie is unique to your web browser and contains anonymous information such as a unique identifier, the site name, and some digits and numbers. Cookies allow for efficient navigation between pages, storage of preferences or settings, and overall improvement of the promotions experience. Cookies make the interaction between you and teamDigital Promotions faster and easier.

Some of our promotions will also use cookies or web analytics tracking methods to enable them to target messages based on your location and/or browsing habits. Cookies may be set by the website domain you are visiting (“first party cookies”) or they may be set by other website domains that run content on the page you are viewing (“third party cookies”).

To learn how you may be able to reduce the number of cookies you receive from us, or delete cookies that have already been installed in your browser’s cookie folder, please refer to your browser’s help menu or other instructions related to your browser. If you do disable or opt out of receiving cookies, please be aware that our Platforms may not be able to recognize you or remember your log-in details. You can also learn more about cookies by visiting www.allaboutcookies.org, which includes additional, useful information on cookies and how to block cookies using different types of browsers.

Information We Receive From Third Parties
teamDigital may also offer social sign-on services that allow you to register for a promotion using a third-party social networking site such as Facebook, Instagram, Tumblr, or Twitter. By using these services you allow teamDigital to access the publicly available information from your third-party social network profile such as your name, age, gender, location, email address, and list of friends.

How Do We Use Your Information?

Operate Promotions and Personalize Your Experience
We use information about you to operate the Promotions, including to process transactions with you, authenticate you when you log in, provide customer support, and operate and maintain the Promotions. Our Promotions may also include features that personalize your experience. We may use your email domain to ensure your eligibility or your affiliation with a particular organization or industry to personalize the content and experience you receive. Where you use multiple Promotion platforms (website, mobile website, mobile app), we combine information about you and your activities to provide an integrated experience, such as to allow you to engage from the various platforms we make available.

For Development and Improvement of our Promotions and Services
We continually make our Promotions more engaging, secure, rewarding, and useful to you and our clients. We use collective learnings about how users engage with our Promotions and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns and areas for improvement.

To Communicate With You About The Services
We use your contact information to send transactional communications to you by email, text message, mobile app messaging, and other means to access a Promotion. We remind you of Promotion deadlines, respond to your comments, questions and requests, provide customer support, and may send you notices, updates, and administrative messages. We also provide personalized communications based on your activity and interactions with a Promotion. For example, certain actions you take in a Promotion may automatically trigger communications related to the Promotion engagement, such as loyalty points in your account. Transactional communications are part of the Promotion and in most cases, you cannot opt out of them and continue to participate. If an opt out is available, you will find that option within the communication itself. Importantly, if you do enter into a Promotion and opt out of transactional communications, we will have no way to reach you if you are a potential winner or otherwise eligible for something of value. If you opt out of such communications, you will no longer be eligible as an entrant.

To Market, Promote, and Drive Engagement With The Services
If you opted in to receive such communications from us, we will use your contact information and information about how you engage with Promotions to send communications that may be of specific interest to you, including by email and by displaying our ads on other companies' websites and applications, as well as on platforms like Facebook and Google. These communications are aimed at driving engagement with our Promotions, and may include information about new programs and sites we think may be of interest to you. We may also communicate with you about new product and service offers, promotions and contests. You can control whether you receive these communications as described below under "Opt-out of communications."

Customer Support
We use your information to resolve technical issues you encounter, to respond to your requests for assistance, to analyze crash information, and to repair and improve the Promotions.

For Safety and Security
We use information about you and your Promotion participation to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of the Promotion rules or the policies of teamDigital or our clients.

To Protect our Legitimate Business Interests and Legal Rights
Where required by law or where we believe it is necessary to protect the legal rights and interests of teamDigital, our clients, or others, we may use information about you in connection with legal claims, compliance, regulatory, and audit matters.

With Your Consent: We use information about you where you have provided consent for us and our client to do so for a specific purpose not listed above. For example, with your consent and on behalf of our clients, we may post contest entries or other user generated content to social media platforms.

Legal Bases for Processing (for EEA Users)
If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the Promotions you enter, how they operate, and how you use them. This means we collect and use your information only where:

  • We need it to operate the Promotion, provide customer support and personalized features, and to protect the safety and security of our platforms and Promotion services;
  • It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for our internal development of improved services, to market and promote the Promotions, and to protect our legal rights and interests;
  • You give us consent to do so for a specific purpose; or
  • We need to process your data to comply with a legal obligation or where the processing is necessary to the establishment, exercise or defense of legal claims.

If you consented to use of information about you for a specific purpose, you have the right to change your mind at any time but this will not affect processing that has already taken place.

Where teamDigital is using your information because our client or if we have a legitimate interest to do so, you have the right to object to that use although this may mean no longer participating in a Promotion. If we are unable to manage your participation in a Promotion without the personal data provided (such as registration information), you will no longer be able to participate in the applicable Promotion.

Who Do We Share Your Information With?
Except as described in this policy, teamDigital does not provide your personal information to third parties without your consent. We may share non-personal information, such as aggregate data or usage information with third parties. We may also share your information as disclosed at the time you provide your information, and in the following circumstances:

Disclosure to Clients
teamDigital may share your personal information with our clients in connection with their Promotions, as well as the third parties working with those clients. Personally identifiable information collected by teamDigital on behalf of a client belongs solely to the client and will be used solely in accordance with that client’s privacy policy.

Legal Disclosure; Business Transfers
teamDigital may transfer and disclose your information to third parties to comply with a legal obligation; when we believe in good faith that the law or a governmental authority requires it; to verify or enforce the terms of our Promotions or other applicable policies; to address fraud, security or technical issues; to respond to an emergency; or otherwise to protect our rights or property or security of third parties, visitors to our Platforms or the public.

In order to accommodate changes in our business, we may sell all or part of our company, as part of a merger, acquisition, liquidation or bankruptcy. In such event, any information collected on the Platforms shall be considered an asset of the company and subject to transfer to another company or other companies.

What Choices Do You Have About How Your Information Is Used?
teamDigital acts as a data processor on behalf of its clients. Each of our clients is the data controller for the data they collect in the applicable Promotion and is the sole owner of that data. Individuals have the right to access the personal data processed about them, subject to applicable law. Individuals may request to access their personal data processed by us by emailing us at PrivacyInquiry@teamDigital.com. However, if we collect your personal data on behalf of a client in connection with that client’s Promotion, your request should be directed to the client data controller. In most cases, we will in the first instance direct your request to our client, the data controller. You have certain choices available to you when it comes to your information. Subject to applicable law, you may have some or all of the following rights available to you in respect of your personal data:

  • to obtain a copy of your personal data together with information about how and on what basis that personal data is processed;
  • to rectify inaccurate personal data (including the right to have incomplete personal data completed);
  • to erase your personal data (in limited circumstances, such as where it is no longer necessary in relation to the purposes for which it was collected or processed);
  • to restrict processing of your personal data under certain circumstances
  • to port your data in machine-readable format to a third party (or to you) when we justify our processing on the basis of your consent or the performance of a contract with you;
  • to withdraw your consent to our processing of your personal data (where that processing is based on your consent); and
  • to obtain, or see a copy of the appropriate safeguards under which your personal data is transferred to a third country or international organization.

In relation to these rights, you may contact us at PrivacyInquiry@teamDigital.com.

Notice: If you contact us regarding personal data collected in connection with a client Promotion for which we are a data processor, we will attempt to refer your request to the relevant client, which is the sponsor of the Promotion and the data controller. We are not responsible for responding to your request on behalf of the data controller and your request will be directed to the client only. We will process such requests only upon instructions from the data controller that is sponsoring the Promotion.

If we are required to respond directly to your request, we may require proof of identity. We also reserve the right to charge a fee where permitted by law, especially if your request appears unfounded, excessive, or abusive. We will use reasonable efforts to respond to your request within all applicable timeframes.

Special Note about Children
teamDigital occasionally operates Promotions on behalf of its clients which collect personally identifiable information from children under the age of 13. In each such instance, teamDigital and its clients   will fully comply with all aspects of the Children's Online Privacy Protection Act ("COPPA") or other applicable law in the operation of the Promotion, in the collection of the data, and in the subsequent use and deletion of the data collected. In the EU, Promotions will generally not be available to children under the age of 16 unless permitted by applicable law and upon written instructions by a client. Specific measures will be disclosed at the time of collection and may include:

  • Notifying parents about our information practices with regard to children, including the types of personal information we may collect from children, the uses to which we may put that information, and whether and with whom we may share that information.
  • In accordance with applicable law, obtaining consent from parents for the collection of personal information from their children, or for sending information about a Promotion directly to their children.
  • Limiting our collection of personal information from children to no more than is reasonably necessary to participate in an online activity.

Giving parents access or the ability to request access to personal information we have collected from their children and the ability to request that the personal information be changed or deleted.


How Do We Store and Protect the Information We Collect?

Information Storage and Security
We use data hosting equipment and service providers in the United States to host the information we collect, and we use technical measures to secure your data.

How Long We Keep Information
How long we keep personal data and other information we collect about Promotion participants depends on the type of information, as described below. After such time, we will either delete or anonymize the information or, if this is not possible, we will securely store your information and isolate it from further use until deletion is possible.

Promotion information
We retain the information you provide to participate in a Promotion for a reasonable period after the Promotion and all related services and requirements are completed. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our terms and rules, to support business operations and to continue to develop and improve our Promotions and services. Where we retain information for service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to develop general insights about use of our Promotions, not to analyze personal characteristics about any individual.

Marketing information
If you elect to receive marketing emails from us, we retain information about your marketing preferences unless you specifically ask us to delete such information. We retain information derived from cookies and other tracking technologies for a reasonable period from the date such information was created.

California Privacy Rights (California Civil Code Section 1798.83)
A California resident who has provided personal information to a business with whom they have established a business relationship for personal, family, or household purposes ("California customer") is entitled to request information about whether the business has disclosed personal information to any third parties for the third parties' direct marketing purposes. In general, if the business has made such a disclosure of personal information, upon receipt of a request by a California customer, the business is required to provide a list of all third parties to whom personal information was disclosed in the preceding calendar year, as well as a list of the categories of personal information that were disclosed. However, under the law, a business is not required to provide the above-described lists if the business adopts and discloses to the public (in its privacy policy) a policy of not disclosing customer's personal information to third parties for their direct marketing purposes unless the customer first affirmatively agrees to the disclosure. The business may comply with the law by notifying the customer of their right to prevent disclosure of personal information and providing a cost free means to exercise that right.

If you are a California resident and would like to make such a request, contact us at the address below.

How Can You Contact teamDigital?

If you wish to contact teamDigital to communicate about privacy related issues, or for any reason at all, you may do so by sending an email to: PrivacyInquiry@teamDigital.com

Do Not Track

teamDigital does not support Do Not Track browser settings and does not currently participate in any Do Not Track frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your personal information.

Notice Regarding International Users

If you are accessing our Platforms from outside the United States, by providing your information to us, you are consenting to the transfer of your information to the United States for processing and maintenance in accordance with this policy. You are also consenting to the application of United States law in all matters concerning the Platform.

How Will We Notify You of Privacy Policy Changes?

teamDigital may make changes to this privacy policy from time to time. Therefore, you should periodically visit this page to view the current privacy policy. In the event of a material change to this privacy policy, teamDigital will advise of the change by posting notice of the changes on our Platforms.