Mobile App Privacy Policy

Scanbuy Inc. (“Scanbuy,” “us, “we,” or “our”) understands that privacy is important to you. This Privacy Policy (“Policy”) explains how personal information about you is collected, used and may be disclosed by Scanbuy. This Policy applies to information we collect when you use the ScanLife PowerShopper™ application (“ScanLife” or the “App”), and other online products and services where this Policy is posted (collectively, the "Services").

What Is ScanLife?

ScanLife helps you create and organize your shopping lists and unlock offers on the products most relevant to you. The App provides you with access to coupons and other discounts on products (“Offers”). When you redeem an Offer by buying the product and submitting your receipt on ScanLife, you will earn cashback and other rewards (“Rewards”). When you upload your receipts or otherwise use ScanLife, you are directing ScanLife to share your receipt information and other shopping related data, which may include personal information, with our consumer brand partners, as well as marketing and advertising companies that help brands sell their products (“Scanbuy Partners”). Scanbuy Partners use your information to power the ScanLife Offers and Rewards, as well as to help brands understand your preferences and shopping trends so that they can better tailor their advertisements to you. For a list of Scanbuy Partners, which we update from time to time, visit: https://app-content.scanlife.com/legal/en/partners-list.html.

Please take the time to read the Policy carefully, so that you can make informed choices concerning your personal information and can better protect your privacy and security. You can jump to particular topics by going to the headings below:

• Notice at Collection
• What Information Do We Collect?
• How Do We Use the Information We Collect?
• Who Do We Disclose Information To?
• U.S. State Privacy Rights
• What Other Choices Do You Have?
• Children’s Privacy
• Other Important Information
• Changes to This Privacy Policy
• Contact Us

ScanLife’s Offers and Rewards are powered by Scanbuy’s Partners. When you sign-up and use the Services, you are directing us or intentionally using the Services to share your personal information with Scanbuy Partners. Your information may be used by Scanbuy’s Partners for targeted advertising purposes.

We retain your personal information for as long as reasonably necessary for the purposes disclosed in the chart above.

Please see Section 6 (“U.S. State Privacy Rights”) of this Policy for information about your rights and choices pursuant to applicable California law.

Users of ScanLife must become a registered user of our Rewards partner Quotient Technology prior to using the App in order to receive Rewards. When you sign-up on ScanLife, you are assigned a unique identifier that connects to your Quotient account. While you are able to create a profile on ScanLife and share your name, photo and other information, there is no requirement to do so. Likewise, when you connect to PayPal through the Quotient unique identifier assigned to you, that information is sent directly to Quotient. We do not access or store any payment information that you provide in order to obtain or redeem Rewards (defined above).

Information You Provide To Us. Scanbuy collects personal information that you provide to us. For example, we collect information when you create an account or a profile, configure your preferences, and when you email, text, call, or otherwise communicate with us. The types of personal information we may collect include:

• Contact and Account Information (e.g. your ScanLife Account User ID, name, biographical information, photo and information about your preferences).
• Demographic Information (e.g. age, gender).
• Purchase Information (e.g. product descriptions and quantities, time of purchase, total purchase, cost, and the store you purchased the product from). This also includes any additional information displayed on any receipt that you scan (e.g. payment mechanism).
• Geolocation Information (e.g. GPS data). ScanLife, upon installation on your mobile device, will provide you with an opportunity to give permission to collect location-based information to locate the stores where you can find and save money on the products that have active coupons that match against your shopping receipts. If you subsequently choose to stop Scanbuy’s collection of location-based information, you can adjust your preferences on your mobile device settings for the ScanLife mobile application at any time.
• Other information you affirmatively provide to us (e.g. any message you send to us, or products you place on your shopping list when using the Services).

Please consider carefully before disclosing any personal information.

Information Collected By Automated Means. When you access or use our Services, we automatically collect information about you, including:

• Transaction Information (e.g. the offers you view and the earnings you save, the stores where you shop, and other information about how you use our Services, including information about how you interact with our Scanbuy Partners).
• Device, Internet, and Network Activity Information using cookies, Web beacons, persistent device identifiers (e.g. Android ID), advertising identifiers (e.g. Google’s “Advertising ID,” Apple’s “IDFA”) and other technologies. This information is used for tracking, advertising, analytics,personalization and optimization of the Services. Additional details about our automatic data collection practices and the different technologies we use to facilitate these activities can be found below.
• Cookies. A Cookie is a string of information that a website saves on a visitor’s computer or mobile device and that the visitor’s browser provides to the website operator each time the visitor returns. A cookie or similar technology will also be placed on a visitor's device when an ad is clicked.
• Persistent cookies remain on the visitor’s computer or mobile device after the browser has been closed.
• Session cookies exist only during a visitor’s online session and disappear from the visitor’s computer or mobile device when they close the browser software.
• Persistent Device Identifiers. Persistent device identifiers are unique strings that are associated with the mobile device that you use to connect to a given service. Persistent device identifiers may be modified or disabled by sophisticated users. Some persistent device identifiers can only be reset by wiping the entire device.
• Advertising Identifiers. Advertising identifiers (e.g. Google’s “Advertising ID,” Apple’s “IDFA”) are unique strings associated with your mobile device provided by the operating system. Advertising identifiers may be modified or disabled by users in the operating system settings.

When you access ScanLife, we collect certain Device, Network and Internet Activity Information automatically such as your IP address, Internet service provider, operating system, the service from which you arrived, the page you requested, the time and date of your visit, and potentially other site usage statistics that will be collected automatically as part of the software processes of the web page.

For mobile devices, we collect information regarding the type of mobile device you use, your mobile device’s unique device ID, the IP address of your mobile device, your mobile operating system, applications installed on the device, your use of those applications, the type of mobile Internet browser you use when accessing products and services, and information about the way you use our Services.

This information does not directly identify you but could be linked with personal information that you provide us. These statistics allow Scanbuy to analyze the effectiveness of its Services, including its website and software applications, and make improvements where needed. Please note this information may be required in order for the Services to function properly. Please see Section 6 (“U.S. State Privacy Rights”) and Section 7 (“What Other Choices Do You Have?”) below to review your rights and choices regarding your information.

Information We Obtain From Third Parties. We obtain information about you from other sources, including publicly available sources and third-party partners, including advertising/marketing companies, advertising networks, consumer service companies, and data analytics providers. For example, Scanbuy receives information about consumers such as location information, online identifiers, and Consumer Packaged Goods (CPG) data from third parties to enable targeted advertising on the application(s) that we support. The collection and use of that data is governed by the privacy policy and legal terms of the data collector and the website using the data; it is not governed by Scanbuy and this Policy does not apply.

Information We Derive. We may derive information or draw inferences about you based on the information we collect above (e.g. inferences and analytics based on your purchase/transaction history, preferences that you provide us or that we observe).

De-identified and Aggregate Information. Scanbuy may de-identify some personal information so that it cannot be readily used to personally identify an individual user. Scanbuy obtains aggregate information by combining de-identified information that meets certain criteria into groups. Scanbuy may disclose aggregate or de-identified information in various formats with Scanbuy Partners and may work with certain partners to do research to improve the Services we provide where needed. Scanbuy will not attempt to re-identify information once it has been de-identified.

Ad Measurement Data. We partner with ABCS Insights to collect anonymous data about the effectiveness of our advertising campaigns. This data may include information such as device identifiers, interaction with advertisements, and other usage data. ABCS Insights uses cookies and similar technologies to collect this information.

We may use the information collected from and about you to:

• Provide the ScanLife Services (as described in the Terms of Use), which includes:
• enabling and managing registration;
• evaluating the types of offers, products, and services that you are eligible for and that may be of interest to you;
• providing you with advertisements and offers that are relevant to you based on your use of the Services (e.g. your stated and anticipated user interests, demographic information, interaction with advertisements, shopping lists created through the Services, past purchase history, and user location);
• tracking redemption of offers and past coupon usage, including audits of user earnings for fraud prevention;
• performing data matching;
• facilitating payment processing that you have requested by third parties; and
• maintaining service quality.
• Create user profiles based on your preferences. We use an automated procedure to process the information we collect, where all the coupons downloaded and receipts scanned and redeemed are filtered in order to classify users according to their purchases, interests, and preferences (age range, place of purchase, type of products purchased, monthly expenditure in the supermarket or pharmacy, etc.).
• Personalize your experience on our Services, including the content, ads, and offers displayed to you. For example, we send personalized promotional information about ScanLife Services by means of notifications in the Apps themselves, and inform you that you may withdraw the consent given at any time. We also work with third parties to collect certain information about your interests, including Device, Internet, and Network Activity Information, to provide targeted advertising and analytics services on our site or within our application, or across other sites and other applications. Please note that data collected from a particular device may be used on a different device that is linked to the device on which the data was originally collected. Any choice made by you regarding Scanbuy’s collection of data on one device will be reflected on the other device(s) linked to that device. Please consider carefully before making any choices regarding Scanbuy’s collection of data.
• Measure and analyze the effectiveness of the Services and make improvements where needed. For example, we may analyze statistics and trends to make our Services better and to develop or better personalize the Services or new services or features.
• Protect the security and integrity of our business, comply with legal requirements and obligations, or as otherwise permitted by law. We may use your personal information to:
• satisfy any applicable law, regulation, legal process or governmental request;
• enforce our Terms of Use, including investigation of potential violations of our Terms of Use;
• detect, prevent, or otherwise address fraud, security or technical issues (including, without limitation, the filtering of spam);
• respond to user support requests; or
• protect the rights, property or safety of Scanbuy, its users, and the public.
• Answer the questions that you send to us. We may use your information to communicate with you about your account and our Services, including allowing our customer support team to respond to your questions, inquiries, comments and suggestions.
• Advertising and Analytics. The data collected by ABCS Insights is used to measure the performance of coupons and ads to help improve our advertising strategies. This information is aggregated and does not include personal data.

Scanbuy may combine all of the information collected from or about you and use it in the manner described in this Policy.

We may disclose any personal information and other information we collect from and about you with:

• Service Providers. We disclose personal information with third parties who complete transactions or perform services on our behalf. These third parties will be required to treat your information in accordance with our privacy policies. This includes: Data analysts, and AI experts analyzing behavior.
• Consumer Brand Partners. We share your information with our customers who are manufacturers or brands of consumer products, as well as their advertising agencies, who we partner with so they can provide shopping-related offers, promotions, advertising, and marketing to you when you use the Services. To view a list of these Consumer Brand Partners, click here. We encourage you to read any privacy policy that Consumer Brand Partners may have posted.
• Marketing and Advertising Partners. We may share your personal information with third party advertisers in order to support and grow our business as well as bring you relevant offers and advertisements. To view a list of these Marketing and Advertising Partners, click here. We encourage you to read any privacy policy that Marketing and Advertising Partners may have posted.
• Organizations in Connection with a Business Transfer. If Scanbuy becomes involved in a merger, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution, or other transaction or if the ownership of all or substantially all of our business otherwise changes, we may disclose or transfer your information to a third party or parties in connection therewith.
• Ad Measurement Partners. We share anonymous data with our ad measurement partner, ABCS Insights, to analyze and report on the performance of our advertisements.

Scanbuy may also disclose certain information, including aggregated and de-identified information, relating to users of the Services with affiliated or unaffiliated third parties.

You may be able to adjust what information we make available to third parties by changing options within the Services (please see “Your Choices” below).

Depending on a user’s state of residence, under applicable law users may also have the following rights (each of which are subject to various exceptions and limitations):

• Access: This is the right to request up to two times every 12 months that we disclose to you (i) the categories of personal information we collected about you, (ii) the categories of sources from which we collected the personal information, (iii) the business or commercial purpose for collecting, selling, or sharing your personal information, (iv) the categories of third parties with whom we shared the personal information and (v) the specific pieces of personal information we collected about you.
• Correct: This is the right to request the correction of personal information held by us and concerning you.
• Delete: This is the right to request the deletion of your personal information held by us and concerning you. For clarity, Scanbuy will not delete information that is de-identified and required for the Services to function properly.
• Opt Out: Although we do not sell personal information in exchange for money, some of the ways in which we share personal information for advertising or marketing may be considered a “sale” under several U.S. state privacy laws (e.g. where we license personal information to Scanbuy Partners to help them better understand your preferences and shopping trends so that they can better tailor their offers, coupons and advertisements to you) and the “sharing” of personal information in connection with the display of targeted advertising across third party websites. As noted above, your personal information may be shared with our Scanbuy Partners who use your information to advertise to you. You can opt-out here – DO NOT SELL OR SHARE MY PERSONAL INFORMATION – or through the link in the footer of our website. We also honor the Global Privacy Control, a browser-based opt-out signal, to the extent that signal has been adapted for the mobile environment.
• Limit the Use of Sensitive Personal Information: You have the right to request that we limit our disclosure or use of sensitive personal information to only what is necessary to provide the ScanLife Services.
• Appeals. You have a right to appeal decisions concerning your ability to exercise your consumer rights.
• Submission of Requests. You may exercise the above rights by emailing us at legal@scanbuy.com. You may also request a portable copy of your personal information by clicking here, or exercise your right to delete by clicking here. Note that we may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate consumer requests.
• Authorized Agent. You may designate an authorized agent to make a request on your behalf. When submitting the request, please ensure the authorized agent identifies himself/herself/itself as an authorized agent and can show written permission from you to represent you. We may contact you directly to confirm that you have authorized the agent to act on your behalf and confirm your identity.
• Verification. Whether you submit a request directly on your own behalf, or through an authorized agent, we will take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the personal information and whether you have an account with us.

For California Users:

• Shine the Light. California’s “Shine the Light” law permits California residents to request certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their direct marketing purposes in the preceding calendar year. We do not share personal information with third parties for their own direct marketing purposes.
• Do Not Track. Apple iOS and Google Android devices provide the ability for users to enable a “do not track” setting that disables your advertising identifier. If the “do not track” setting is disabled, we may record when a user installs the App. We may also run targeted advertising on third party applications via our advertising display partners. For users who have enabled the “do not track” setting in iOS or Android, this data will not be collected.
• Please note that the “do not track” setting may not be available on all operating systems or versions of ScanLife. The “do not track” settings require iOS 6 or later, or Android 2.3 or later. In order for the “do not track” settings to function within ScanLife, you must have a version of ScanLife installed which is up to date as of the effective date of this Policy.
• To enable the “do not track” setting on iOS, visit: http://support.apple.com/kb/HT4228
• To enable the “do not track” setting on Android please perform the following steps: (i) Open your ‘Settings’ app; (ii) Locate Privacy; (iii) Select ‘Advanced’; (iv) Select ‘Ads’; (v) Select ‘Opt out of Ads Personalization’; and (vi) When prompted select ‘Ok’.
• For additional details on option out of ads personalization for your Google account, visit the following external link: Opt out of seeing personalized ads

Scanbuy may update these instructions periodically as new information becomes available from Apple, Google, and other Operating System manufacturers.

You can manage your consent preferences by visiting the “Privacy” section of the navigation panel within the app. From there, you can choose to opt-out of certain types of data collection. However, please note that disabling certain types of data collection may impact your ability to use certain features of our app.

You can stop the collection of information by ScanLife by uninstalling the application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. We will retain any personal information collected in connection with your use of our Services for one year after the app is uninstalled.

Scanbuy may also disclose certain personal information, including Geolocation Information and Device, Network, and Internet Activity Information (as defined in Section 2 above), with Scanbuy Partners. Scanbuy provides an opt-out tool which is cookie based. If you’d like to opt-out of Scanbuy’s use of cookie-based information, outside of use that is required for the Services to function properly, please click here and follow the relevant instructions.

Some Scanbuy Partners provide opt-out tools which are cookie-based. If you’d like to opt-out of the services of Scanbuy Partners who provide such an opt-out mechanism, but would like to continue using the ScanLife application, please click here to view of a list of Scanbuy Partners, click on the applicable privacy policies made available on their websites, and follow the relevant instructions to opt out.

You may also opt-out of the collection of aggregate level and/or anonymous information using mechanisms provided by industry groups such as the Network Advertising Initiative (the “NAI”) and the Digital Advertising Alliance (the “DAA”).

• To opt-out of the collection of information by NAI members, visit http://www.networkadvertising.org/choices/
• To opt-out of the collection of information by DAA members, visit http://www.aboutads.info/choices/

Please note that the opt-out tools discussed above are cookie-based, and only prevent the collection of information pertaining to you on the browser on which they are installed, will only function as described if you browser is set to accept third-party cookies, and may not be as reliable if your cookies are automatically disabled or removed (e.g., some mobile devices and operating systems). If the opt-out cookie is deleted from a browser, the collection of information by participating members will resume until an opt-out cookie is reinstalled on that browser.

Scanbuy’s Services are intended for adult use only and we do not knowingly solicit data from or market to children under the age of 18. Scanbuy’s Services are not intended for children, and we ask that children under the age of 18 not submit any personal information to us. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at privacy@scanbuy.com. We will delete such information from our files within a reasonable time.

• Security. Scanbuy will take reasonable technical and organizational precautions to prevent the loss, misuse or alteration of your personal information. Scanbuy will store all the personal information you provide on secure servers. Information relating to electronic transactions entered into via this website will be protected by encryption technology. No method of transmission over the Internet, or method of electronic storage, is 100 percent secure. While Scanbuy uses reasonable efforts to protect your information from unauthorized access, use or disclosure, Scanbuy cannot guarantee its absolute security. Please consider carefully before disclosing any personal information.
• Third-Party Applications and Services. Scanbuy is not liable for any information collected, used or disclosed by the user’s mobile device manufacturer or service provider. Your internet service provider or mobile carrier network may have access to communications, such as text messages, phone calls or emails, sent using the mobile device. For information regarding your service provider’s or carrier’s treatment of your information, please consult their privacy policies, which we encourage you to do. If you decide to use third party applications on your device, any information those applications collect may be sent to third parties and this Policy does not apply. However, third party applications may have their own privacy policies that you should review.
• Jurisdictional Issues. Information collected by Scanbuy in connection with your use of our Services may be stored and processed in the United States or any other country in which Scanbuy maintains facilities. Accordingly, your use of ScanLife, or any other Services provided, grants Scanbuy permission to transfer such information to other Scanbuy facilities which may be outside of your country. We may need to transfer your personal information outside of the country from which it was originally provided. This may be intra-group or to third countries with which we work, and which may be located in jurisdictions outside the EEA, Switzerland and the UK that do not have data protection laws or laws that are less stringent compared to those in Europe.

Scanbuy reserves the right to change this Policy from time to time. Be sure to check this page periodically for updates. If Scanbuy makes any changes to this Policy, we will notify you by changing the “Effective Date” listed. If Scanbuy makes any significant or substantial changes to this Policy, we will obtain your express consent prior to your continued use of the Services. Please be advised that failure to consent may result in the Services not functioning properly or not functioning at all.

If you have questions about this Policy, please contact us at:

• Scanbuy, Inc.
• 10 East 39th Street, 10th Floor,
• New York City, NY 10016
• legal@scanbuy.com