Introduction & Purposes
This Privacy Notice (“Notice”) explains how Prize Logic LLC (“PrizeLogic”, “our”, “us”, “we”), a full-service promotions and loyalty agency, collects, uses and handles personally identifiable information that individuals (“users,” “you,” or “your”) share with us, with our clients and other information we collect during your participation in various activities we manage.
We are committed to protecting the privacy of your personally-identifiable information that you provide to us. This is your PII that (i) you choose to provide to us when you decide to engage in client promotions and marketing activities that we manage; (ii) we gather when you visit our website at www.prizelogic.com or other websites we own or manage (the “Website”); (iii) we gather when you interact with PrizeLogic directly (e.g., our website, mailboxes, points of entry offline); or (iv) we possess and process.
If you have any questions about this Notice, please email us at email@example.com or call (248) 663-8700. Additional contact information is provided in the Contacting Us section below.
This Notice consists of the following main sections:
- Information We Collect
- How We Use the Information We Collect
- Additional Services and Third-Parties
- Security of PII
- Special Note About Children
- California Privacy Rights
- Client Privacy Notices and Opting-Out of Client use of PII
- Opting Out of PrizeLogic Use of PII
- Contacting Us
- Third Party Links
- International Users
- Changes to Notice
1. Information We Collect
A. Personally Identifiable Information (“PII”)
B. Personal information that is not PII.
PrizeLogic, on behalf of our clients and for its own purposes, may also collect or generate non-personally identifiable information about your use of PrizeLogic services or client promotions. This information includes, but is not limited to, browser type and version, operating system, referral source, length of visit, page views, demographics, interests, online habits, geographical location, analytical data, receipts, images, social posts, video, audio, information collected by website visitor tracking tools such as “cookies,” “web beacons,” “pixels,” Internet tags and other navigational data. More information about our online activity tracking tools is provided below.
C. Website Visitor Tracking Tools That We Use
Additionally, emails we send to you may contain a bit of code known as a “web beacon” or “pixel.” This code helps us understand the time and date that you opened an email and when you used a link within the email to visit a website, allowing us to collect analytics about our traffic, customize our services, and send you ads about our services. You can disable our web beacons by turning images “off” in your email client (e.g., Outlook, Outlook Express).
2. How we Use the Information We Collect
Generally, we may use your information that we collect for: (i) analytical purposes, including the creation of recognition databases; creation of common event data databases; development and use of benchmarking, indexing, and analytics; product development, testing, analytics, modeling and algorithm development (e.g., machine learning, artificial intelligence, and fraud mitigation); (ii) providing and fulfilling services ordered by our clients (including SMS and email messaging); (iii) internal and third-party fraud detection, data matching, validation and recognition use, including, for example, use of PII for recognition database, matching to external services and augmentation with third party information and (iv) the promotions entered by you. More information about how we use the information we collect is provided below.
A. To Operate Promotions and Personalize Your Experience
Our promotions may include features that personalize your experience. To that end, we use your PII and non-personally identifiable information to operate and benchmark the promotions, including, without limitation, to process transactions with you and validate the information you provided. We may also use your email domain to ensure your eligibility or your affiliation with a particular organization or industry or to personalize the content and experience you receive.
Where you use multiple promotion platforms (such as, website, mobile website, or mobile app), we may combine information about you and your activities to provide an integrated experience, such as to allow you to seamlessly engage from the various platforms we make available.
B. For Development and Improvement of our Promotions and Services
We continually strive to improve our promotions and services to make them more engaging, secure, rewarding, and useful to you and our clients. We use the information we collect to better understand how our users engage with our promotions, to troubleshoot and to identify areas for improvement.
C. To Communicate With You About The Services
We use your PII to send transactional communications to you by email, text messages, mobile app messaging, and other means to access a promotion. We also remind you of promotion deadlines, respond to your comments, questions and requests, provide customer support, and may send you notices, updates, and administrative messages using your PII. We also provide personalized communications based on your activity and interactions with a promotion. For example, certain actions you take in a promotion may automatically trigger communications related to the promotion engagement, such as loyalty points in your account. Transactional communications are part of the promotion and in most cases, you cannot opt-out of them and continue to participate in the promotion. If an opt-out is available, you will find that option within the communication itself. Importantly, if you do enter into a promotion and opt-out of transactional communications, we will have no way to reach you if you are a potential winner or otherwise eligible for something of value. For more information about opting out, please see Sections 7 and 8.
D. To Market, Promote, and Drive Engagement With The Services
We will use your information about how you engage with promotions to send communications that may be of specific interest to you, including by email, and by displaying PrizeLogic ads on other companies’ websites and applications, as well as on platforms like Facebook and Google. These communications are aimed at driving engagement with our promotions and may include information about new programs and sites we think may be of interest to you. We may also communicate with you about new product and service offers, promotions and contests. You can control how and whether you receive these communications as described below in Sections 7 and 8.
E. Fraud Detection and Prevention; Safety and Security
We will use your information to detect and prevent fraud and as may be otherwise necessary to help ensure the integrity of our promotions and to identify violations of the promotion rules or the policies of PrizeLogic or those of our clients.
F. To Protect our Legitimate Business Interests and Legal Rights
Where required by law or where we believe it is necessary to protect the legal rights and interests of PrizeLogic, our clients, or others, we may use your PII in connection with legal claims, compliance, regulatory, and audit matters.
G. With Your Consent
We also use your PII where you have provided consent for PrizeLogic or our client to do so for a specific purpose not listed above. For example, with your consent, we may post contest entries or other user generated content to social media platforms.
H. Customer Support
We use your PII and non-personally identifiable information to resolve technical issues you encounter, to respond to your requests for assistance, to analyze crash information, and to repair and improve the promotions.
I. Legal Bases for Processing (for EEA Users)
If you are an individual in the European Economic Area (EEA), we collect and process your PII only where we have legal bases for doing so under applicable EU laws. The legal bases depends on the promotions you enter, how they operate, and how you use them. This means we collect and use your PII only where:
- We need it to operate the promotion, provide customer support and personalized features, help prevent fraud, and to protect the safety and security of our platforms and promotion services;
- It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for our internal development of improved services, to market and promote the promotions, and to protect our legal rights and interests;
- You give us consent to do so for a specific purpose; or
- We need to process your PII to comply with a legal obligation or where the processing is necessary to the establishment, exercise or defense of legal claims.
If you consented to our use of your PII for a specific purpose, you have the right to change your mind at any time but note that this will not affect processing that has already taken place.
Where PrizeLogic is using your PII because our client and/or PrizeLogic have a legitimate interest to do so, you have the right to object to that use although this may mean no longer participating in a promotion. If we are unable to manage your participation in a promotion without the PII you provided (such as your registration information), you will no longer be able to participate in the applicable promotion. To learn how to opt-out of allowing use of your PII, please refer to Sections 7 and 8.
3. Additional Services and Third-Parties
PrizeLogic may also offer social sign-on services that allow you to register for a promotion using a third-party social networking site such as Facebook, Twitter, Instagram, YouTube, etc. By using these services, we may share PII with that service about you and we will access the available PII from your third-party social network profile such as your name, age, gender, location, email address, and list of friends. This PII may be used by PrizeLogic to administer the technical and operational aspects of the Website, or make your experience on our promotions and services more personal and social. PrizeLogic does not control the privacy practices of these (or any other) third-party services. We encourage you to read the privacy policies of these services before connecting to them.
4. Security of PII
Although no computer network is invulnerable to attack, PrizeLogic uses reasonable physical, electronic, and procedural security measures designed to protect your PII from unauthorized disclosure.
5. Special Note About Children
Unless otherwise specifically indicated, PrizeLogic promotions are not available to anyone under the age of thirteen. PrizeLogic does, however, operate some promotions and platform solutions on behalf of its clients that collect PII from children under the age of thirteen. In each such instance, PrizeLogic complies with the Children’s Online Privacy Protection Act (“COPPA”) when operating the promotion, collecting the PII itself, and subsequently using the data collected. PII will not be collected from children under the age of thirteen without parental consent in compliance with the COPPA guidelines. If you have questions concerning PrizeLogic’s information collection and use practices with respect to children, or if you would like to review, have deleted, or stop the further collection of your child’s PII, you may contact PrizeLogic as set forth in Section 9 below.
6. California Privacy Rights
Pursuant to California Civil Code Section 1789.83, a California resident who has provided PII to a business with whom he/she has established a business relationship for personal, family, or household purposes (a “California customer”) is entitled to request information about whether the business has disclosed PII to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such a disclosure of PII, upon receipt of a request by a California customer, the business is required to provide a list of all third parties to whom PII was disclosed in the preceding calendar year, as well as a list of the categories of PII that were disclosed. However, under the law, a business is not required to provide the above-described lists if the business adopts and discloses to the public a notice of not disclosing customer’s PII to third parties for their direct marketing purposes unless the customer first affirmatively agrees to the disclosure, as long as the business maintains and discloses this notice. Rather, the business may comply with the law by notifying the customer of his or her right to prevent disclosure of PII and providing a cost free means to exercise that right.
7. Client Privacy Notices and Opting-Out of Client use of PII
8. Opting Out of PrizeLogic use of PII
In general, “opting out” means that you want PrizeLogic to limit the PII it collects and stores about you and to not target ads that are based on your interests to your browser or device. Your opt-out is only applicable to PrizeLogic marketing material and will not opt you out from platforms provided by third-party companies or client promotions. If you use multiple browsers, computers or mobile devices, and wish to limit the PII and non-personally identifiable information PrizeLogic collects and stores or do not wish to receive PrizeLogic interest-based advertising on any of them, you must opt out from each browser, computer, and mobile device individually. Please note that if cookies are not enabled in your browser, or if you use certain ad-blocking tools, our opt-out mechanism may not work properly. Please also note that deleting your cookies does not opt you out. To opt-out of PrizeLogic using your PII, you need to contact us using the contact information provided below.
9. Contacting Us
It is PrizeLogic’s goal to keep all PII that you provide to us accurate. You may contact us to correct or update your PII, deactivate your PII or opt-out (if PrizeLogic is holding on to your PII as explained above), and to ask general questions regarding this Notice or any other privacy related issues. PrizeLogic’s Information Security Director can be reached at:
Prize Logic, LLC
25200 Telegraph Rd, Suite 405
Southfield, MI 48033
Telephone: (248) 663-8700
or faxing or emailing the details of your request to:
Fax Number: (480) 270-3020
If you are based in the European Economic Area (“EEA”), you may contact our Data Protection Officer/Information Security Director at firstname.lastname@example.org
10. Third Party Links
Hypertext links which redirect you to third-party websites may be encountered while browsing the Website. These hypertext links are maintained or operated by third-parties, not PrizeLogic. These third-party websites are not under our control, and we are not responsible for the contents, links, or any changes or updates to these websites. Further, the inclusion of any hypertext links on the Website does not imply endorsement by us of the related third-party website, that website’s contents or security, or any association or affiliation with its operators. PrizeLogic is not responsible for data and information collected by these third-party websites.
11. International Users
PrizeLogic is based in the United States, and, regardless of where you use PrizeLogic solutions or otherwise provide PII and non-personally identifiable information, that information may be transferred to and maintained on servers located in the U.S.
12. Changes to Notice
This Notice was last updated on January 31, 2019. However, this Notice will change over time, for example to comply with legal requirements or to meet changing business needs. The most up to date version can be found on the Website. In case there is a change that we want to highlight to you, we will also inform you in another appropriate way (for example, via a pop-up notice or statement of changes on our Website).
Last Updated: January 31, 2019