This Privacy Policy describes how MemberHub, Inc. (“MemberHub,” “we,” or “us”) collects, uses, and shares information about you when you use the Givebacks website, www.givebacks.com, our mobile application, our browser extension, or other services that we operate and that refer or link to this Privacy Policy (collectively, the “Services”), including information that identifies, or that can be used to identify or contact you (“Personal Information”), and the choices that you have regarding that information.
By using the Services, you acknowledge that you have read this Privacy Policy. If you do not agree to the handling of your Personal Information as described in this Privacy Policy, please do not use the Services or provide your Personal Information to us.
The Information We Collect and How We Collect It
The information we collect and the sources from which we collect it depend on the context of your interactions with us, the choices you make, and the Services and features you use.
Information You Provide to Us Directly
You may choose to provide certain information to us when you use the Services. The categories of information we collect through this method are summarized below
We collect Personal Information that you submit to us through contact forms that we make available through the Services, including to enable you to inquire about the Services and to request support for your use of the Services. This information may include Personal Information such as your name, your email address, your mailing address, your telephone number, and any other information you submit as part of your inquiry or request.
If you represent a cause or an organization, the information you provide may also include the name and contact information for your organization and your role in the organization.
When you register to create an account to use the Services to access offers from participating merchants and earn rewards from your purchases, we will ask you to provide your email address and create a password to access your account, and other contact and demographic information such as your name, your mailing address, and your date of birth.
We will also ask you to select a local cause or organization to benefit from purchases you make when using the Services, and may collect information you submit to search for and select a cause, which may include the city, zip code, and/or cause and organization name.
To facilitate your redemption of rewards that you earn through the Services, we will ask you to provide information associated with your chosen payment method, which may include your bank account number and routing information, or your account credentials for your online payment service provider.
If you elect to participate in our Card-Linked Offers Program, we will also ask you to provide the details of any eligible debit or credit card that you choose to link to the Services, including the name on the card, card number, expiration date, billing zip code, and card verification value.
Please note that this information is provided directly to third-party financial partners that we work with to facilitate reward redemption. MemberHub does not receive or store your bank account, eligible credit or debit card number, or online payment service credentials on any systems that we operate.
If you use the Services on behalf of a cause or organization, we may ask you to set up an organization account. The information we collect to set up your cause or organization account may also include your contact details such as your name, email address, and telephone number; the name and address of your cause or organization and a description of your cause or organization’s products and services; and your payment account details to facilitate the collection and receipt of payments associated with transactions made through the Services.
Information We Collect Automatically
We collect certain information automatically when you use the Services, which may include information set out in the categories below. We collect some of this information through tracking technologies such as cookies and web beacons. For more information, please see the How We Use Cookies and Other Tracking Technologies section of this Privacy Policy.
When you use the Services we may automatically collect information about the computer, device, hardware, or software you use to access the Services, such as you Internet Protocol (“IP”) address or other transactional or identifier information for your device (such as device make and model, information about device operating systems and browsers, or other device or system-related specifications), and, when you launch any of our Services from a mobile device, the unique device ID for your mobile device.
We may also collect information and statistics about your interaction with the Services, which may include the URLs of the pages that you have visited, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, the application you used, how long you used the application and when, and other similar usage statistics; and information that facilitates a safer and more personalized experience, such as user identification information, saved preferences, and device identifiers or usage information for authentication and fraud prevention purposes.
When you use the Services to shop for offers from our participating merchants, including when you use our mobile application and when you install our browser extension, we will automatically collect information that may include the participating merchants, products, services, and offers you searched for, viewed, or clicked; the websitesyou visit and your browsing activity on those sites; and transaction information related to our Services, including purchase confirmation data and rewards accrued through the Services.
When you install our browser extension, in addition to collecting the shopping and rewards information described above, we may automatically track all websites you visit using the browser for which you have installed the extension, and your activity on those websites.
When you use the Services, we may collect information about your location from your device, including your approximate location derived from your IP address, as well as precise location information that is provided through the GPS and other functionality on devices you use to access the Services. We will use this location information to customize the Services, including offers that are shown to you when you use the Services.
Information We Receive from Third Parties
When you use the Services to shop at participating merchants for goods and services, in addition to the information we may collect automatically through the Services, we may also receive information from those participating merchants and other business partners with whom we work to provide the services, including the participating merchant name, transaction date, transaction amount, and other information relating to your shopping activity and purchases.
If you elect to participate in our Card-Linked Offers Program and link an eligible debit or credit card to your account, we will receive Personal Information from your eligible debit or credit card network (e.g., Visa, Mastercard, American Express), and from other partners we work with that operate card-linked offer networks, including Rakuten Card Linked Offer Network, Inc. and Rewards Network Establishment Services, Inc. The information we receive will include transaction details for purchases you make using the linked eligible debit or credit card, including participating merchant name, participating merchant location or other store identifier, transaction date, and transaction amount.
For more information, please review the “Our Collection and Use of Transaction Data” section of this Privacy Policy.
We may receive your Personal Information, including your name and email address, from organizations, causes, and referral partners that we work with, as well as from other users of our Services, if they think you may be interested in our Services and/or invite you to participate.
If you use an account that you have established on a third-party service such as Facebook or Apple to connect with or Services, we may receive certain information about that account from the third-party service, the nature and extent of which will depend on the privacy policies and settings for those third-party services.
If you choose to interact with us or our partners on social media by posting to our pages, tagging us (or using certain hashtags or other identifiers) in posts, or participating in activities, we may collect certain information from the social media account you use to interact with us, including the name associated with the account, the account handle, recent activity, the content of any posts in which we are tagged, and other information that may be contained on your social media profile to allow us to respond to the posts and understand and engage with our audience.
In addition to the sources noted above, we may receive your name and other contact information Personal Information from publicly-available and commercially-available sources such as government databases and data brokers. We may also receive information, such as device information and browsing information, from third parties for marketing and analytics purposes, for example to provide you with personalized ads on our Services and in third-party websites and mobile services.
Our Collection and Use of Transaction Data
If you elect to participate in our Card-Linked Offers Program and link an eligible debit or credit card to your account, MemberHub and its third party service providers will collect transaction data which may include your contact details, eligible debit or credit card details, and the transaction details for qualifying purchases of goods and services at participating merchants. Notwithstanding anything to the contrary in the Terms of Service or this Privacy Policy, MemberHub and its Third Party Service Providers (including Rakuten Card Linked Offer Network, Inc. and Rewards Network Establishment Services, Inc.) will use and share transaction information in connection with the Card Linked Offers Program as follows:
By participating in the Card Linked Offers Program, you authorize the sharing, exchange and use of transaction data described above and herein by and among MemberHub and MemberHub’s third party service providers, applicable payment card networks and applicable participating merchants.
By registering a payment card in connection with transaction monitoring, you authorize MemberHub and its third party service providers to share your payment card information with Mastercard, Visa and American Express. You authorize Mastercard, Visa and American Express to monitor transactions on your registered 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 Mastercard, Visa and American Express to share such transaction details with MemberHub and its third party service providers to enable your card-linked offer(s). You may opt-out of transaction monitoring on the payment card(s) you have registered by logging into your MemberHub account and clicking “Manage Connected Cards,” selecting the card for which you wish to opt-out, and clicking “Remove This Card.” You must repeat this process for every card for which you wish to opt out of transaction monitoring.
How We Use Your Information
We may use information that we collect about you or that you provide to us, including any Personal Information, for the following purposes:
We may also use your Personal Information to create anonymous or aggregated information that does not and cannot be used to identify you, and use such information for any lawful purpose.
How We Share Your Personal Information
To accomplish the purposes set out above, we may disclose your Personal Information to third parties that may include:
We may also disclose aggregated information about our users, and information that does not identify any individual, without restriction.
How We Use Cookies and Other Tracking Technologies
We also collect information about your use of the Services through tracking technologies such as cookies and web beacons. A “cookie” is a unique numeric code that is transferred to your computer to track your interests and preferences and to recognize you as a return visitor. A “Web beacon” is a transparent graphic image placed on a website, email, or advertisement that enables the monitoring of things such as user activity and site traffic.
Some content or applications, including advertisements, on the Services are served by third parties, which may include advertisers, ad networks and servers, content providers, and analytics and application providers. These third parties may use cookies alone or along with web beacons or other tracking technologies to collect information about you when you use the Services. For instance, we use Google Analytics. Google Analytics uses cookies to help us analyze how visitors use the Service. For more information on Google Analytics, including how Google Analytics collects, uses and discloses information, please refer to the following page: https://policies.google.com/technologies/partner-sites.
The information third parties collect through cookies and web beacons may be linked to your Personal Information, and they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
Use of Services by Children
MemberHub does not knowingly collect information from, or provide any of our Services to, children under the age of 16. Nor do we target our Services to children under these ages.
IF YOU ARE UNDER 16 YEARS OF AGE, THEN PLEASE DO NOT USE OR ACCESS THE SERVICES AT ANY TIME OR IN ANY MANNER.
If you are the parent or legal guardian of a child under 13 who has used the Services and provided personal information to us in violation of this policy, then please contact us at support@givebacks.com to have that child’s information deleted.
Your Choices Regarding Your Personal Information
We provide you with choices regarding your Personal Information.
Links to Other Websites; Third Party Services
Our Services may contain links to other websites and online services. If you choose to click on an advertisement or another third-party link within the Services, such as to a participating merchant, you may be directed to that third party’s website or service. The fact that we link to a third-party website or service is not an endorsement or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third-party websites or services. These other websites or services may place their own cookies or other files on your computer or mobile devices, collect data or solicit personal information from you. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites and services you use.
Other third parties with whom we work to provide the Services, including networks we work with to provide offers and participating merchants, also have their own privacy statements that apply to Personal Information we share with them in connection with our operation of the Services. We encourage you to familiarize yourself with the privacy statements provided by these other parties prior to providing them with information.
To that end, we use PayPal’s Hyper wallet service to facilitate the redemption of rewards and remittances of funds to our users and causes and organizations. The Hyper wallet Privacy Policy, available at https://www.hyperwallet.com/privacy-policy/ applies to PayPal’s handling of Personal Information it collects through the operation of the Hyper wallet Service. You may exercise any rights that you may have with respect to Personal Information received by Hyper wallet according to the instructions set out in the Hyper wallet Privacy Policy.
International Users
If you are located outside the United States and choose to provide Personal Information to us, we transfer Personal Information to and process it in the United States. Your use of the Services and submission of Personal Information to us represents your agreement to that transfer.
Additional Information for Residents of California
This section applies only to residents of the State of California and generally describes how we collect, use, and disclose the personal information of California residents and their households (“California Personal Information”). However, California Personal Information does not include, and this section does not apply to:
Additionally, this section applies only to the extent we direct the purposes and means of California Personal Information processing and otherwise qualify as a “business” that is subject to the CCPA.
California Personal Information We Collect
We may collect, and may have collected in the preceding 12 months, the following categories of California Personal Information, as described in more detail above in “The Information We Collect and How We Collect It” section of this Privacy Policy:
Sources of California Personal Information We Collect
We collect California Personal Information from the sources described in the “The Information We Collect and How We Collect It” section of this Policy.
Purposes for Which We Use California Personal Information
We may collect and use the categories of California Personal Information described in the “California Personal Information We Collect” section above for one or more of the business and commercial purposes described in the “How We Use Your Information” section above.
Disclosures of California Personal Information for a Business Purpose
We may disclose the categories of California Personal Information that we collect as indicated above to the categories of third parties described in the “How We Share Your Personal Information” section of this Privacy Policy. In the preceding 12 months, we may have disclosed the categories of California Personal Information that we collected, as described above, for a business purpose to the categories of third parties listed in the “How We Share Your Personal Information” section of this Privacy Policy.
Sales of California Personal Information
To the extent that we receive monetary or other valuable consideration for sharing or providing access to California Personal Information about you with participating merchant, third parties, or affiliates in order to provide you rewards and benefits and for our and their targeted marketing purposes, the CCPA may deem this a “sale” of your personal information. To that end, in the preceding 12 months we may have sold the categories of California Personal Information that we collect as indicated above to the categories of third parties described in the “How We Share Your Personal Information” section of this Privacy Policy.
You have a right under California law to opt-out of our “sale” of your information in this way. If you would like to exercise your right to opt-out of having your personal information shared in this way, please visit the “Do Not Sell My Personal Information” link on our website homepage, or email us at support@givebacks.com.
Please note that if and to the extent you opt-out of this sharing, we may be unable to offer you any aspects of the Services that require such sharing.
We do not have actual knowledge that we sell the personal information of consumers under 16 years of age.
California Personal Information Rights and Choices
The CCPA provides California residents with specific rights regarding their California Personal Information. This section describes those rights and explains how to exercise them.
You may designate an authorized agent to submit requests on your behalf through a signed written permission that authorizes the agent to act on your behalf. We may mandate additional requirements when submitted through an authorized agent, such as requiring you to verify your identity directly with us or to directly confirm the authorized agent’s permission to act on your behalf.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. Your request must provide information sufficient to permit us to reasonably verify you are the person about whom we collected California Personal Information, or an authorized agent of that person. In order to verify your request, we may require you to provide additional information, including account profile information such as your email address and other information elements necessary to verify your identity. Your request also must include sufficient detail for us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with California Personal Information if we cannot verify your identity or authority to make the request and confirm the California Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, if you have a password-protected account with us we consider requests made through that account sufficiently verified when the request relates to California Personal Information associated with that specific account.
Any disclosures we provide will only cover the 12-month period preceding our receipt of the verifiable request. If we cannot fulfill, or are permitted to decline, your request then we will alert you or your authorized agent. For data portability requests, we will select a format to provide your California Personal Information that is readily usable.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision, and we reserve the right to either refuse to act on your request or charge you a reasonable fee to complete your request if it is excessive, repetitive, or manifestly unfounded.
Other Notices
Shine the Light
California’s “Shine the Light” law, S.B. 27, California Civil Code Section 1798.83, permits California residents who have an established business relationship with us to request certain information regarding our disclosures of their personal information (as defined by that law) during the preceding year, if any, to third parties for those parties’ own direct marketing purposes. If you are a California resident who has an established business relationship with us and wish to exercise your rights under that law, please send your written request by mail to MemberHub, Inc., 3041 Farrior Road, Raleigh, NC 27607.
Information Security
You are solely responsible for protecting your account credentials, limiting access to your devices and signing out of the Services when you are finished using them.
We take precautions, including organizational, technical, and physical measures to help safeguard the Personal Information that we maintain against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure, or access. No method of data storage or transmission is 100% secure, however, and we cannot and do not guarantee the security of your Personal Information.
Contacting Us
If you have any questions about these privacy policies or information practices, please contact us by email at support@givebacks.com, or by mail at MemberHub, Inc., 3041 Farrior Road, Raleigh, NC 27607.
Changes to this Privacy Policy
We reserve the right to change the terms of this Privacy Policy at any time. When we change the Privacy Policy, we will update the “Last Updated Date” above and post the modification on our website. Your continued use of the Services following the posting of changes to this Privacy Policy means you accept those changes.