If you have any questions about our privacy practices, please contact us as set forth in the “Contact Information” section below. If you are a resident of certain jurisdictions, including California, Colorado, Connecticut, Delaware, Iowa, Minnesota, Maryland, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, Virginia, and other U.S. States with similar Privacy Laws (collectively, “Applicable States”), please see the additional disclosures at the end of this Privacy Policy.

For our privacy practices concerning our products, including our practices as a data broker, please visit our Products Privacy Policy here: https://www.becausal.com/privacy-policy

1. How We Collect Personal Information

From you. We may collect personal information and other information that you voluntarily provide when you take certain actions, such as when you contact us, view website or mobile app content, use our mobile applications, register for an account, provide us feedback, apply for a job, or otherwise use our Services.

From devices you use when you interact with us online. This includes information collected through our Services and automatically from devices you use to connect to our Services. For more information about this, please see our “Cookies and similar technologies” section below.

From third parties and publicly available sources. This includes publicly available sources and third-party partners, including advertising/marketing companies, advertising networks, consumer service companies, and data analytics providers.

2. The Categories of Personal Information We May Collect

Depending on how you interact with us, we may collect the following information:

• Contact Information, such as your name, zip code, email address, telephone number, or other similar identifiers.
• Demographic Information, such as your age and gender.
• Consumer Purchase Information and Transaction Information, such as metadata surrounding shopping events, identifiers associated with Consumer purchases, purchase location data, or purchase brand/category information.
• Activity Information, such as information we collect when you access and interact with our Services, including browser or device model and settings, operating system, and unique identifiers, clickstream data, cookies and localStorage, browsing history, search history, web-based location, IP address, geolocation, and any other Internet usage information our Services may automatically record when you visit. For more information about cookies and similar technologies, please refer to the section “Cookies and Similar Technologies” below.
• Information from Third Parties, such as demographic data, online identifiers, or purchase insights we receive from service providers, advertising or analytics partners, or publicly available sources.
• Geolocation Information, such as the location of your mobile device when you consent.
• Inferences, such as inferences drawn from any of the personal information identified and discussed in this Privacy Policy.
• Other Personal Information, including information you may voluntarily provide to us when using our Services.
• Job Applicant Information, such as professional and employment-related information (e.g., employment history, education, skills, qualifications, and references) and any other information you choose to provide during the application process.
• Deidentified or Aggregate Information, which we may use or share for research, analytics, or to improve our Services, provided it does not identify you.

3. How We Use Your Personal Information

We may use your information for the following reasons, depending on your relationship with us:

• To provide you the Services requested and in accordance with your acceptance and direction.
• To help recognize you as a previous visitor and save and remember your preferences and settings, and to deliver appropriate and personalized interest-based content, coupons, and offers.
• To personalize your experience on our Services, including the content, coupons, offers, and advertisements displayed to you.
• To evaluate and process job applications, assess a job applicant’s qualifications, communicate about the recruitment process, and comply with applicable employment, legal, or regulatory requirements.
• To communicate with you, such as when we respond to your inquiries and send you other communications regarding our products and services. This may also include administrative email notifications such as security or support and maintenance advisories.
• To send you surveys, news, and/or marketing communications (by email, phone, or text), subject to your marketing preferences and choices, including information about us or third-party offerings we think may be of interest to you.
• To conduct market research, analytics, and quality assurance activities, including studying, developing, and improving our Services. This may include measuring and analyzing the effectiveness of our Services, audience traffic, user interests, trends, and patterns.
• To aggregate, anonymize, and/or deidentify personal information for any lawful purpose, including improving our Services and operations.
• To serve you targeted advertising or content and understand how you interact with our Services to personalize your experience (including advertising and messaging campaigns).
• To maintain the safety, security, and integrity of our Services, including monitoring for fraud, misuse, or illegal activity.
• To debug, detect, and secure our systems, networks, and websites against errors and vulnerabilities.
• To comply with legal and regulatory obligations, respond to lawful requests, or investigate and address claims or disputes related to your use of the Services. This includes defending ourselves in litigation or investigations and pursuing or enforcing legal rights.
• To conduct internal business purposes, including data analysis, audits, and improving our Services.
• To collect analytics and usage data to understand how our Services are used and to improve them over time.

4. How We Disclose Personal Information

We may disclose some or all of the personal information collected from or about you with any of the following entities and for any of the following purposes:

• Service Providers and Vendors. We may share personal information with third parties who provide services to us or perform functions on our behalf, such as data analysis, technology support, customer service, and operational assistance. These third parties are required to handle personal information consistent with this Privacy Policy.
• Marketing and Advertising Partners. We may share personal information with advertising, marketing, or media partners to support and improve our Services and deliver relevant offers and advertisements.
• Ad Measurement Partners. We disclose anonymous data with our ad measurement partner, ABCS Insights, to analyze and report on the performance of our advertisements.
• Government, Regulatory, or Law Enforcement Agencies. We may disclose personal information when required to comply with applicable law, respond to lawful requests, or protect our rights, property, safety, or the safety of others.
• In Connection with a Business Transfer. We may disclose or transfer personal information as part of a merger, acquisition, sale of assets, reorganization, or other corporate transaction.
• In Connection with a Job Application. For job applicants, we may disclose personal information to third-party service providers assisting with recruiting, application management, background checks (where applicable), or regulatory compliance.
• At Your Direction. We may disclose personal information with your consent or at your specific direction.

5. Children's Privacy

You must be 18 years or older to use our Services. Our Services are for a general audience, are not targeted to children, and we do not knowingly collect personal information from children under 18 years of age. If a parent or guardian becomes aware that his or her child or minor has provided us with information without their consent, he or she should contact us at privacy@becausal.com.

6. Your Advertising Choices

When you use our Services, our third-party advertising partners, and analytics providers may collect personal information about your online activity on our Services and on third party websites.

These providers may set web tracking tools (e.g., cookies and web beacons, as discussed further below) to collect information regarding your online activity. In addition, our advertising partners may use this information to deliver advertisements to you when you visit third party websites within their networks. If you would like more information about this practice, and to know your choices with respect to it, please visit https://youradchoices.com/, https://optout.aboutads.info/, or https://thenai.org/. You may also opt out in mobile apps using your device’s settings to opt-out of personalized advertisements or similar settings. Please note that you may continue to receive generic ads that are not based on your preferences.

You may have additional rights related to these technologies depending on your state of residency, as outlined in the section below on additional information for residents of Applicable States.

7. Information Security

We use commercially reasonable administrative, technical, personnel, and physical measures designed to safeguard information in its possession against loss, theft, unauthorized use, disclosure, or modification. However, the confidentiality of information transmitted over the Internet cannot be guaranteed. We urge you to exercise caution when transmitting personal information over the internet. We cannot guarantee that unauthorized third parties will not gain access to your information; therefore, when submitting personal information to us, you do so at your own risk.

8. Cookies and Similar Technology

We and our partners use various tools to collect data when you visit our sites and apps, including cookies, pixels, localStorage, and other similar technologies. Some of these technologies store data in the browser or on your device. Other technologies may use network-related or other information to recognize your device (e.g., IP address). Our Services use these technologies, for example, when you first request a web page and data is then stored on your computer or other device so the website or mobile application can access personal information when you make subsequent requests for pages from that Service. These technologies may also be used to collect and store information about your usage of the Services, such as pages you have visited and other content you viewed, and search history. Additionally, we may use these technologies to collect analytics and measure the use of our Services.

We and our partners may also use these technologies to gather personal information about how you view and use our Services and content and to connect your activity with other data we store about you. We and our partners may collect your personally identifiable information about your online activities over time and across different websites when you use the Services. The use of these technologies helps us serve you better by understanding what you are interested in, tracking trends, measuring the effectiveness of ads, saving your preferences, and storing information you may want to retrieve on a regular basis. We also allow specific, approved partners to collect data from your browser or device for advertising and measurement purposes using their own similar tools.

Your web browser can be set to allow you to control these technologies, such as whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie-enabled will not recognize you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting these technologies, such as cookies. To find out more about cookies, visit https://www.aboutcookies.org. Depending on the make and model of your phone, you may be able to use device settings to opt out of the use of certain device IDs for targeted advertising. For more information about Google Analytics, please review the site “How Google uses data when you use our partners’ sites or apps,” located at https://www.google.com/policies/privacy/partners/. To opt out of Google Analytics specifically, please go to https://tools.google.com/dlpage/gaoptout.

Some browsers permit the user to send a “Do Not Track” (“DNT”) preference to websites that the user visits indicating that the user does not wish to be tracked over time and across websites. Because there is not yet a common understanding of how to interpret DNT, we do not currently respond to the DNT signal on our website. We do, however, respond to global privacy preferences when required by law.

9. Your Marketing Preferences

We may periodically send promotional materials or notifications related to our Services. If you no longer wish to receive promotional marketing materials from us, you may opt out of receiving such materials. You may unsubscribe from receiving marketing or other commercial emails from us by following the instructions included in the email or by emailing us with the subject line “Email Unsubscribe” at privacy@becausal.com.

There are certain service notifications and other non-promotional emails that you may not opt out of, such as notifications of changes to our Services or policies.

10. Additional Information for Residents of Applicable States

Depending on where you reside, you may have certain additional rights regarding your personal information. This section provides information for consumers residing in Applicable States in connection with the laws in those states, and other states with similar privacy laws (“Applicable Laws”).

Under these Applicable Laws, and for purposes of this Section, “Personal Data” and/or “Personal Information” (collectively, “Personal Information) generally mean information that identifies, relates to, or describes a resident or household in one of the Applicable States, and, for Oregon residents, may also include information that is linkable or linked to a device. Personal Information and/or Personal Data does not include publicly available information; lawfully obtained, truthful information that is a matter of public concern; information that has been deidentified or aggregated; or other information covered by certain sector-specific privacy laws, as consistent with state law. We do not reidentify Personal Information that has been deidentified.

We and our advertising partners use certain Personal Information to deliver online advertisements to you on your devices tailored to your interests. Depending on your state of residence and under Applicable Laws, this may be considered “sharing,” “selling,” or “targeted advertising.” This Section provides details about the categories of Personal Information of consumers in Applicable States, and other U.S. states with similar privacy laws, that we have collected, disclosed, processed for purposes of targeted advertising, “shared”, or “sold” during the last 12 months, as well as rights consumers have under Applicable Laws.

Categories of Personal Information Collected, Disclosed, “Shared”, “Sold”, or Processed for Targeted Advertising:

The categories of Personal Information that we, under Applicable Laws, collected, disclosed (or enabled you to disclose), “shared” in the past 12 months, processed for purposes of targeted advertising, or “sold” are below, along with the purposes for processing, and categories of third parties to whom each category of Personal Information was disclosed, “shared”, “sold”, or processed for the purpose of targeted advertising. Please note that we process some categories of Personal Information in connection with targeted advertising, which could be considered “sharing” or “selling” under certain Applicable Laws. Depending on how you interact with us, we may not have processed Personal Information about you for each (or any) of these purposes.

Additionally, we do not knowingly “share” or “sell” Personal Information of minors under 18 years of age.

Please note that we may process Personal Information in each of the above categories in order to protect ours and others’ rights, and/or to complete a merger or sale of assets or other corporate transaction.

Under Applicable Law, “sale” and “share” do not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other similar transaction involving all or any portion of our business.

Sensitive Personal Information

Outside of potentially what is noted below regarding our mobile applications, we do not process “sensitive” Personal Information of Clients for purposes other than those permitted by Applicable Law (such as to provide the services and for security purposes).

In connection with our mobile applications, we will ask for your consent to process precise geolocation data, which may be considered a category of “sensitive” Personal Information under Applicable Law. Please see below for how you may exercise your rights with respect to sensitive Personal Information.

Data Retention

We will retain your Personal Information for the period necessary and proportionate to fulfill the purpose(s) for which the Personal Information was collected or processed as outlined in this Section unless a longer retention period is required or allowed by law.

Purposes

We may use this Personal Information for the following purposes, including commercial purposes:

• to operate, manage, and maintain our business;
• to provide our Services;
• to respond to requests and questions;
• to accomplish our business purposes and objectives, including:
• developing, improving, repairing, and maintaining our Services;
• personalizing, advertising, and marketing our Services and content;
• conducting research, analytics, and data analysis;
• maintaining our facilities and infrastructure;
• quality and safety assurance measures;
• conducting risk and security controls and monitoring;
• detecting, preventing, and investigating fraud, misuse, or illegal activity;
• performing identity verification and authentication;
• performing accounting, audit, and other internal functions;
• complying with the law, legal process, and internal policies;
• maintaining records;
• exercising and defending legal claims;
• processing transactions and payments where applicable;
• aggregating, deidentifying, or anonymizing information for lawful business purposes, including analytics and improvement activities;
• communicating with individuals about our Services, including responding to inquiries and sending administrative or transactional messages;
• evaluating and processing job applications and complying with employment, legal, or regulatory obligations related to applicants.

Depending on your interactions with us, we may not have used Personal Information collected about that Applicable State resident for each (or any) of these purposes.

Sources of Personal Information

We collect this Personal Information directly from residents of Applicable States themselves, as well as from social media platforms (e.g., if the individual has connected a social media account to our website); referrals; joint marketing, co-branding, co-promotional, or advertising partners; and sources of demographic and other information, including through devices you used to interact with us through our Services. We may collect Personal Information from job applicants when they apply for a position with us or submit related materials, such as resumes or applications. All sources of personal information collected are noted in the “How We Collect Personal Information” and “The Categories of Personal Information We May Collect” sections above.

Your Privacy Rights under Applicable Laws

If you are a resident of an Applicable State, you may have the following rights with respect to any information about you that constitutes “Personal Information” or “Personal Data” depending on your state of residence.

We are required by law to verify your identity in connection with any request in order to prevent unauthorized access of your data. Failure to verify your identity may result in your request not being processed. Where required by Applicable Law, we will notify you if we deny your request and notify you of the reasons we are unable to honor your request and any available appeal processes available to you.

Right to Know and Access Personal Information: You may request to access the following information we have collected and maintain about you:

• The specific pieces of Personal Information we collected about you;
• The categories of Personal Information we collected about you and the categories of sources;
• The business or commercial purpose for collecting, disclosing, or selling Personal Information about you; and,
• The categories of Personal Information about you that we sold, shared, or otherwise disclosed and the categories of third parties (or, depending on your state of residence, a list of specific third parties) to whom we sold, shared, or otherwise disclosed that Personal Information.

Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.

Deletion of Personal Information: You may request that we delete your Personal Information. Depending on the scope of your request, we may refrain from granting your request, as permitted by Applicable Law. For example, we may be legally required to retain your Personal Information in our business records. Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.

Opt Out of “Sale”, “Shares”, and Targeted Advertising: Depending on the state you reside in, Services users have the right to opt out of the “sale” of your data and the disclosure of your data for cross-context behavioral advertising/targeted advertising (known as a “share” in California). We also honor alternative opt out signals, such as the GPC. We process opt out preference signals in a frictionless manner.

Right to Process and Limit the Use of Sensitive Personal Information: If we process categories of personal information that may be considered “sensitive”, we will not disclose or use this information for purposes other than those permitted by Applicable Law (such as to provide the services and for security purposes) without your explicit consent. If you do provide us explicit consent to process categories of personal information that may be considered “sensitive”, you have the right to request that we limit our disclosure or use of such information to only what is necessary to provide the Services.

Correction of Inaccurate Personal Information: You have a right to request the correction of inaccurate Personal Information that we may have on file about you. Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.

Non-Discrimination: You have the right to be free from unlawful discrimination for exercising your above-listed rights under Applicable Law.

Right to Appeal: Depending on your state of residence, you may have the right to request an appeal of a denied consumer request. Please see below for how to submit an appeal.

Authorized Agent

Depending on whether you reside in an Applicable State, consumers may have the right to submit a request through an authorized agent. If you are an authorized agent acting on behalf of a consumer to exercise a privacy right discussed in this section, you must be able to demonstrate that you have the requisite authorization to act on behalf of the consumer. We may also contact the consumer directly to verify his or her own identity and that the consumer granted you authorization to act on their behalf as an authorized agent. An authorized agent may also be permitted to act on behalf of a consumer in order to exercise certain opt-out rights.

If you are an authorized agent trying to exercise rights on behalf of a consumer, please submit a request via the linked form here (https://www.becausal.com/data-subject-requests) and select the option for “Authorized Agent” under requestor type. We may request supporting verification information, which should include proof that you have the consumer’s authorization to act. Under certain circumstances, we may also require you to prove and verify your identity if you are acting as an authorized agent on behalf of a consumer.

To Exercise Rights

In order to exercise your Right to Opt Out of “Sales”, “Shares”, and Targeted Advertising, please visit our "Do Not Sell or Share My Personal Information" page. [https://www.becausal.com/personal-information]

In order to exercise your right to limit use of sensitive Personal Information, please visit our “Limit the Use of My Sensitive Personal Information” page. For precise geolocation data collected through our mobile applications, you may withdraw your consent at any time by adjusting your device’s location settings to restrict further collection.

In order to exercise your other rights described above, please send an email to privacy@becausal.com or submit a request through the linked form at https://www.becausal.com/personal-information. Authorized agents may submit requests through the linked form. Additionally, we may need to obtain information about you or your specific request in order to verify your identity and respond.

11. Notice of Financial Incentive

We offer consumers the ability to participate in a registration program ("Program"). Depending on your state of residence, the Program may be considered a financial incentive or loyalty program. Participation in the Program is entirely voluntary. If you would like to participate in the Program, please opt-in by signing up. If you sign up, you will receive:

• Access to coupons and other discounts on products (“Offers”). When you redeem an Offer by buying the product and submitting your receipt on the ScanLife PowerShopper mobile application (“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 (“Becausal Partners”). Becausal Partners use your information to power Offers and Rewards, as well as to help brands understand your preferences and shopping trends so that they can better tailor advertisements to you.

Depending on your state of residence, if you decide you no longer wish to participate in the Program, you may withdraw at any time. You may exercise this right to withdraw using the following method, depending on the information you have provided to us:

• Email privacy@becausal.com to request withdrawal from the Program. To process your withdrawal request, we will need to delete your account. Before deleting your account to honor your withdrawal request, we will send you an email requesting that you explicitly acknowledge and confirm your decision to delete your account. This step is essential to ensure that the account deletion aligns with your intentions and helps mitigate unauthorized actions. Once we receive your confirmation, your account will be deleted, and you will be withdrawn from the Program.

We estimate that the value of your data is equal to the value of Offers and Rewards. Information you provide enables us to deliver personalized content, offers, and value to you, which enables us to establish a relationship with you, and is valued by us in order to facilitate a positive customer experience. In determining the value of this information, we consider the profit generated from our advertising partners that includes personal information, which is reasonably correlated to the value provided to you through personalized Offers and Rewards.

12. International Data Transfers

We are based in the United States. Any information you provide to us through use of the Services may be stored and processed, transferred between, and accessed from the United States and other countries, which may not guarantee the same level of protection of personal information as the one in which you reside. We may need to send your personal information overseas as part of our normal business operations. Provided the data protection laws of these other countries differ from those in the United States, please be assured that we take reasonable steps to protect your privacy.

13. Changes to Our Privacy Policy

This Privacy Policy may be amended from time to time. Any changes will be posted on this page. We will notify you of any material changes by, as applicable, placing a prominent notice on our Services or otherwise as legally required.

14. Contact Information

Questions about our Privacy Policy may be directed to: privacy@becausal.com.