Privacy Policy

Updated February 1, 2022

Introduction

1.1. Purpose of Policy

Bridg, a division of Cardlytics, Inc. (“us,” “we,” “Bridg,” or “Company”) is committed to respecting the privacy rights of its customers, visitors, and other users of the Company Website (www.bridg.com, www.relevantloyalty.net, www.relvantmobile.com) and any affiliated sites (the “Site”) and any services, applications, and software provided by and made available by Bridg (collectively with the Site referred to as “Services”). We created this Privacy Policy (this “Policy”) to give you confidence as you visit and use the Services, and to demonstrate our commitment to fair information practices and the protection of privacy. Accordingly, we abide by the following privacy principles for all the personally identifiable information we collect from you. This Policy is only applicable to the Services, and not to any other websites that you may be able to access from the Site, each of which may have data collection and use practices and policies that differ materially from this Policy. When using any of the Services, you are consenting to the collection, storage, manipulation, transfer, disclosure and any other uses of your information as described in this Privacy Policy. In addition to accepting this Privacy Policy you expressly represent that you are over the age of 18 and/or not considered a minorin the jurisdiction where you reside. By accepting this Privacy Policy, you expressly consent to the information handling practices described in this Policy. This Policy is part of and incorporated into Bridg’s Terms of Use and License Agreement associated with its Services.If you have any questions concerning this policy, please contact us at privacy@bridg.com. Your privacy is important to us and we will make every effort to resolve your concerns.Bridg Site may contain links to other third-party web sites. The information practices or content of other third-party web sites is governed by the privacy policies and statements of other such respective web sites. We encourage you to carefully review and understand the information practices of such third web sites.

1.2. Notice Concerning Children

PLEASE NOTE: We are a general audience site, and do not direct any of our content specifically at children under 13 years of age. We do not knowingly seek or collect Personal Information from users under 13 years of age. We understand and are committed to respecting the sensitive nature of children’s privacy online. If we learn or have reason to suspect that a Site user is under age 13, we will promptly delete any personal information in that user’s account.

1.3. International Users & U.S.-EU Switzerland Safe Harbor

Bridg Services may be hosted in the United States. If you utilize our Services from the European Union or Switzerland, or any other region with laws governing data collection and use that may differ from U.S.law, please note you are voluntarily transferring your personal data outside of those jurisdictions to the United States. The United States does not have the same data protection laws as the European Union, Switzerland or other regions. By providing Personal Information under this Policy, you expressly consent to the use of your Personal Information in accordance with this policy and expressly consent to the transfer of your Personal Information to the United States.

Bridg is committed to complying with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce in regard to the collection, use, and retention of personal information from European Union member countries and Switzerland.

Information Collection Practices

2.1. What Basic Information Does the Company Collect and Use?

• TRAFFIC DATA COLLECTED
We automatically track and collect the following categories of information when you visit our Site: (1) IP addresses; (2) domain servers; (3) types of computers accessing the Site; (4) referring/exit websites (5) operating systems (6) Internet Service Providers (ISPs) and (7) types of web browsers used to access the Site (collectively “Traffic Data”). Traffic Data is anonymous information that does not personally identify you but is helpful for marketing purposes or for improving your experience on the Site. We also use “cookies” to customize content specific to your interests, to ensure that you do not see the same advertisement repeatedly, and to store your password so you do not have to re-enter it each time you visit the Site. We may use this information and share it with vendors or advertising partners (collectively “Partners”) and we may contact you based on this information. We may also track and analyze non-identifying and aggregate usage and volume statistical information from you and provide such information to third parties.

• LOGIN DATA COLLECTED.
We may also collect information regarding your use of the Bridg Site and Services, your login time and duration and your last known login date and time. We collect and store any username and password you provide us that you use to gain access to our Bridg Services. We may use this information and share it with our Partners and we may contact you based on this information. We may also track and analyze non-identifying and aggregate usage and volume statistical information from you and provide such information to third parties.

• CONTACT INFORMATION
In operating the Site and Services, Bridg may include registration, subscription accounts, online surveys, and other online forms that ask users to provide their names, e-mail addresses, U.S. postal address and other contact information. In registering for the use of Services on this Site, you will provide information such as your name, username, password, email address, postal address and other contact information or other information requested at the time of registration. You acknowledge this information is personal to you and, you by creating a Bridg account, allow Bridg and others to identify you. We may use this information and share it with our Partners and we may contact you based on this information.

• PERSONAL INFORMATION COLLECTED
In order for you to access certain Services that we offer via the Site, we require you to provide us with certain information that personally identifies you (“Personal Information”).Personal Information includes the following categories of information: (1) Contact Data (such as your name, mailing address, and e-mail address); and (2) Demographic Data (such as your zip code, age, and income). We use this information to contact you about the services on our site in which you have expressed interest. You must provide contact information (such as name, email). We use this information to process or fulfill inquiries or requests regarding Bridg products. If we have trouble fulfilling such request or inquiry, we will use this information to contact you. As part of registering for the Service, you may receive emails and email newsletters from us. We do not collect personally identifiable information about you except when you specifically provide this information on a voluntary basis. If you communicate with us by e-mail, complete online forms, resume applications, Service questionnaires, surveys or contest entries, any information provided in such communication may be collected as Personal Information. We may use this information and share it with our Partners and we may contact you based on this information.

• THIRD PARTY APPLICATIONS OR SERVICES
Bridg may provide Services that allow you integrate third party applications, either directly or via API. (collectively “Third Party Services”) By voluntarily electing to link your Bridg Service(s) with Third Party Services, you will share with Bridg and Bridg will store your Third-Party Services’ access data including any usernames and passwords used in accessing those Third-Party Services. The Bridg Services and Third-Party Services accessed through the Bridg Services are used primarily for providing dataanalysis and Services to you. Any information shared through use of the Bridg Site or Bridg Services or Third-Party Services accessed through Bridg Services will be shared with and stored by Bridg. We may track and analyze usage and volume statistical information from you and provide such information to third parties. We may also use your Third-Party Service or Application Username, IDs or handles and share it with our Partners and we may contact you based on this information. We may also track and analyzenon-identifying and aggregate usage and volume statistical information from you and provide such information to third parties.

• GEOGRAPHICAL INFORMATION
Bridg may access your geographic location data at the time that you login to Bridg Services. We may use this information and share it with our Partners and we may contact you based on this information. We may also track and analyze non-identifying and aggregate usage and volume statistical information from you and provide such information to third parties.

• SERVICE DATA
Service Data is data that resides on Bridg, customer or third-party systems to which Bridg is provided access to perform services (including data analysis, as well as test, develop, manipulate and report data that may be accessed to perform Bridg analytic and consulting Services). Bridg treats Service Data according to the terms of this policy and treats Service Data as confidential in accordance with the Terms of Use for your order of Bridg Services.To illustrate the difference between customer information and services data, when a customer contracts with Bridg for Services, the customer provides information about itself, including its name, address and some employee contact information. Bridg may also collect other information about the customer and some employees, for example through its web sites, as part of that interaction. All of that information is customer information and is treated according to Bridg’s privacy policy.In contrast, having contracted with Bridg for Data Analysis Servicesor other services, the customer provides Bridg access to its production, development or test environment, which may include personal information about its employees, customers, partners or suppliers (collectively “end users”).

2.2. What Additional Information Does Company Collect and Use?

• AUTOMATIC COLLECTION
Our servers automatically recognize visitors’ domain names and IP addresses (the number assigned to computers on the Internet), cookie information, traffic data and other information you request. No personal information about you is revealed in this process. Bridg may gather information about the number and frequency of visits to the Site and Services. The Site may also gather anonymous “traffic data” that does not personally identify you, but that may be helpful for marketing purposes or for improving the services we offer. We use this information, 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. Except as otherwise provided, we do not link this automatically-collected data to personally identifiable information.

• COOKIES
From time to time, we may use the standard “cookies” feature of major browser applications that allows us to store a small piece of data on your computer about your visit to our Web site. “Cookies” are small text files a website can use to recognize repeat users. Bridg uses cookies to recognize visitors and more quickly provide personalized content or grant you unimpeded access to the website. Information gathered through cookies also helps us measure use of our website. Cookie data allow us to track usage behavior and compile data that we can use to improve the site. This data will be used in aggregate form; no specific users will be tracked. Typically, cookies work by assigning a unique number to the user that has no meaning outside of the Web site that he or she is visiting. You can easily turn off cookies. Most browsers have a feature that allows the user to refuse cookies or issues a warning when cookies are being sent. However, our site will not function properly without cookies. Enabling cookies ensures a smooth, efficient visit to our website. We may use a third-party tracking service that uses cookies to track non-personally identifiable information about visitors to our site in the aggregate to capture usage and volume statistics to help us improve our site. We have no access or control over these cookies. This privacy statement covers the use of cookies by www.bridg.com and affiliated Sites only and does not cover the use of cookies by any third party.The use of cookies by our Partners, affiliates, tracking utility company, service providers is not covered by our privacy statement. We do not have access or control over these cookies. Our Partners, affiliates, tracking utility company, service providers use session ID cookies to make it easier for you to navigate our site, in order for you to use the shopping cart, etc. Our third-party partners employ clear gifs (a.k.a. Web Beacons/Web Bugs), images, and scripts that help them better manage content on our site. We may tie the information gathered to our Customers’ or Users’ personally identifiable information.

Use and Sharing of Information

Use and Sharing of Information

• PERSONAL & CONTACT INFORMATION
We use Contact Data to send you information about our company or our products or services, or promotional material from some of our Partners, or to contact you when necessary. We use your Financial Data to verify your qualifications for certain products or services and to bill you for products and services. We may use your personal information to verify your identity, to check your qualifications, or to follow up with transactions initiated on the Site. We may also use your contact information to send follow-up information regarding Bridg’s Services, contact you regarding other services Bridg offers, inform you of the availability of a newsletter or hotline information available on our site, any changes to the Site, or to send you additional information about Company. We use your personal information to contact you about the services on our site in which you have expressed interest. We use this information to fill your order for a subscription to Bridg products and provide you access to Bridg Services. If we have trouble processing an order, we will use this information to contact you. As part of engaging Bridg Services, you may receive email newsletters and direct mailings from us. We do not collect personally identifiable information about you except when you specifically provide this information on a voluntary basis. If you communicate with us by e-mail, complete online forms, third party applications, surveys or contest entries, questionnaires, employment applications, or the like, any information provided in such communication may be collected as Personal Information. We may use this information and share it with our Partners and we may contact you based on this information.

• SHARING OF PERSONAL INFORMATION
We share certain categories of information we collect from you in the ways described in this Privacy Policy. We may use and share with our Partners, the information including contact information such as Name, Phone Number, Address, Email Address, Third Party Application Username, IDs or handles, geographic location, resume, employment profile, employment history, educational information, and any and all other information you provide to us to improve the Services we provide to you, notify you of changes or updates to our Services, customize your experience in using our Services and Site, customize any advertising and content you see on our Site or in using our Services, research the effectiveness of Services provided and adapt our Site and Services to our Customer’s needs. We may share Demographic Data with Partners, advertisers and other third parties only on an aggregate (i.e., non-personally-identifiable) basis. We may share Contact Data with other companies and Partners who may want to send you information about their products or services and employment opportunities, unless you have specifically requested that we not share Contact Data with such companies. We also share Contact Data and Financial Data with our Partners and business partners who assist us by performing core services (such as hosting, billing, fulfillment, or data storage and security) related to our operation of the Site. Those business partners have all agreed to uphold the same standards of security and confidentiality that we have promised to you in this Privacy Policy, and they will only use your Contact Data and other Personal Information to carry out their specific business obligations to Company. If you do not want us to share your Contact Data with any third parties, please email us at privacy@bridg.com or select the “opt out” box on our online forms, but please understand that such a request will likely limit your ability to take advantage of all of the features and services we offer on the Site and may terminate your profile or access to the Services. In addition, we maintain a procedure for you to request changes to your Personal Information; this procedure is described in Section 7.1, below. If you give your permission during the account registration process, we may share your contact information with our business partners or other companies so that they may send you promotional materials.

• ANONYMOUS INFORMATION
We use anonymous information to analyze our Site traffic, but we do not examine this information for individually identifying information. In addition, we may use anonymous IP addresses to help diagnose problems with our server, to administer our site, or to display the content according to your preferences. Traffic and transaction information may also be shared with Partners, business partners and advertisers on an aggregate and anonymous basis.

• COMMUNICATION FROM THE SITE
We communicate with our customers using information provided to us in various ways, which include but are not limited to:

SERVICE-RELATED ANNOUNCEMENTS
We will send you service related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. Typically, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.

CUSTOMER SERVICE
Based upon the personally identifiable information you provide us, we will send you a welcoming email to verify your username and password. We will also communicate with you in response to your support inquiries, to provide some of the services you request. We will communicate with you by email. We may communicate with you by telephone and via direct mailings.

NEWSLETTERS
If you wish to subscribe to our newsletters, we will use your name and email address to send the newsletter to you. Out of respect for your privacy, we provide you a way to unsubscribe in each newsletter. Please see the ‘unsubscribe’ feature at the bottom of each newsletter. The customer’s email list is stored on our system but is not used by Bridg in any other way other than to occasionally remind invited users to join the account that the account owner has registered for, to provide additional information about our Services, to communicate about new features or updates and to provide Customers information about their activity using Bridg Services.

SURVEYS AND CONTESTS
From time-to-time we may provide you the opportunity to participate in contests, promotions or surveys on our site. If you participate, we will request certain personally identifiable information from you. Participation in these surveys or contests is completely voluntary and you therefore have a choice whether or not to disclose this information. The requested information typically includes contact information and demographic information (such as zip code). We use this information to notify contest winners and to monitor site traffic or personalize the site.

TESTIMONIALS
We post testimonials communicated to Us from time to time. We always receive permission to post prior to posting.

NOTIFICATIONS

USE OF COOKIES
We may use cookies to deliver content specific to your interests, to save your password so you don’t have to re-enter it each time you visit our site, or for other purposes. Promotions or advertisements displayed on our site may contain cookies. We do not have access to or control over information collected by outside advertisers on our site.

SERVICE PROVIDERS
We use other third parties to provide services on our site. When you purchase a service from us, we will share contact information as necessary for the third party to provide that service. These third parties are prohibited from using your personally identifiable information for any other purpose including their own marketing purposes.

ANALYTICS TOOLS
We use analytics tools and other third-party technologies, such as Google Analytics, Google Remarketing and MixPanel, to collect non-personal information in the form of various usage and user metrics when you use our online Sites and/or Services. These tools and technologies collect and analyze certain types of information, including cookies, IP addresses, device and software identifiers, referring and exit URLs, onsite behavior and usage information, feature use metrics and statistics, usage and purchase history, MAC Address, mobile unique device ID, and other similar information.The third party analytics companies who collect information on our Sites and/or Services and other online products and/or services may combine the information collected with other information they have independently collected from other websites and/or other online or mobile products and services relating to your activities across their network of websites as well as online and/or mobile products and services. Many of these companies collect and use information under their own privacy policies.

You may opt out of the DoubleClick cookie by visiting the Google advertising opt-out page or you may opt out of Google Analytics by visiting the Google Analytics opt-out page. Google has additional information available about their Remarketing Privacy Guidelines, and Restrictions.

Certain web browsers, including Internet Explorer, Safari and Firefox, provide a “do not track” or “DNT” feature that relies on technology known as a DNT header, which alerts a Web Site, visited by a user employing such a feature, about the user’s browser DNT preference. Bridg does not currently commit to responding to such DNT Signals. Currently, there is not an industry standard for DNT that has been adopted by regulators. Furthermore, there is no consistency in interpreting user’s intent.

OPTING OUT OF NEWSLETTER
Upon request, Bridg will allow any user to opt out of our newsletter. You can unsubscribe by following the simple instructions included in each promotional email sent to you in the newsletter. This website may contain links to other sites that are not owned or controlled by Bridg. Please be aware that we are not responsible for the privacy practices of such other sites. This privacy statement applies only to information collected by this website.

SALE OF INFORMATION
In order to accommodate changes in our business, we may sell or buy portions of our company or other companies or assets, including the information collected through this Web site. Additionally, if Company or substantially all of its assets are acquired, customer information will be one of the assets transferred to the acquirer.

ACCESS TO INFORMATION
If your personally identifiable information changes, or if you no longer desire our service, you may correct, update, delete it by making the change on the Account section page. We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our website.

USE OF SERVICE DATA
Services data may be accessed and used to perform services under your order for support, consulting, analytics or other services and to confirm your compliance with the Terms of Use related to your order of Services from Bridg. This may include testing and applying new product, algorithms, analysis, manipulation; monitoring and testing of data; compilation and extraction of Service Data; marketing analysis of Service Data submitted to Bridg ; creating learned data and improving Bridg algorithms, analysis techniques and trend developments; and any other use of the Service Data, as determined by Bridg, to perform the Services ordered by you. Any copies of Service Data created for these purposes are only maintained for time periods relevant to those purposes.

Bridg may be required to retain or provide access to services data to comply with legally mandated reporting, disclosure or other legal process requirements.

Bridg may transfer and access Services Data globally as required for the purposes specified above. If Bridg hires subcontractors or Partners to assist in providing services, their access to services data will be consistent with the terms of your order for services and this services privacy policy. Bridg is responsible for its subcontractors’ or Partner’s compliance with the terms of this policy and Terms of Use governing your order.

Bridg does not use Services Data except as stated above or in your order. Bridg may process Services Data but does not control your collection or use practices for services data. If you provide any service data to Bridg, you are responsible for providing any notices and/or obtaining any consents necessary for Bridg to access, use, retain and transfer services data as specified in this policy and your order.

4.1. Confidentiality and Security of Personal Information

Except as otherwise provided in this Privacy Policy, we will keep your Personal Information private and will not share it with third parties, unless such disclosure is required by law or in the good-faith belief that such disclosure is necessary: (a) conform to the edicts of the law or comply with legal process served on Company or its parent company, subsidiaries or affiliates, (b) protect and defend the rights or property of Company or the users of the Site, (c) act under exigent circumstances to protect the safety of the public or users of the Site, or (d) enforce our Terms of Service. Your Personal Information is stored on secure servers that are not accessible by third parties. We provide you with the capability to transmit your Personal Information via secured and encrypted channels if you use a similarly equipped web browser. The Site has security measures in place, including but not limited to the use of a Secure Sockets Layer (SSL) software to prevent the loss, misuse, and alteration of the information that we obtain from you, but we make no assurances about our ability to prevent any such loss, misuse, to you or to any third party arising out of any such loss, misuse, or alteration.

5.1. Lost or Stolen Information

You must promptly notify us if your credit card, user name, or password is lost, stolen, or used without permission. In such an event, we will remove that credit card number, user name, or password from your account and update our records accordingly.

Website Areas Beyond Company’s Control

6.1. Third-Party Websites

The Site may contain links to other websites. If you choose to visit other websites, we are not responsible for the privacy practices or content of those other websites, and it is your responsibility to review the privacy policies at those websites to confirm that you understand and agree with their policies.

Contact Information and Policy Updates

7.1. Contacting Us

If you have any questions about this Policy, our practices related to this Site, or if you would like to have us remove your information from our database please feel contact us at the following:

Bridg, a division of Cardlytics, Inc.
11388 W. Olympic Blvd.
Los Angeles, CA 90064
privacy@bridg.com

7.2. Updates and Changes

We reserve the right, at any time, to add to, change, update, or modify this Policy, simply by posting such change, update, or modification on the Site and without any other notice to you. Any such change, update, or modification will be effective immediately upon posting on the Site. When using any of the Bridg Services, you are consenting to the collection, storage, manipulation, transfer, disclosure and any other uses of your information as described in this Privacy Policy. It is your responsibility to review this Policy from time to time to ensure that you desire to with our Service.

8.1. No Error Free Performance

Bridg does not guarantee error free performance under this Privacy Policy. Bridg will use reasonable efforts to comply with this Policy and will take prompt corrective action when it learns of a failure to comply with this Policy. Bridg shall not be liable for any incidental, consequential or punitive damages relating to this Policy. This policy is governed by the laws of the State of California and the United States of America, to the extent applicable.

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