Spreezio Privacy Policy

Last Revision Date: December 21, 2009

This Privacy Policy governs all personal information associated to or resulting from your access to and use the mobile and web-based location-based services offered by Spreezio at www.spreezio.com.

All capitalized terms used in this Privacy Policy but not defined in it have the meaning given them in the TOU Agreement.

Consent

Access to, and use of the Site is subject to the terms of this Privacy Policy. By accessing, using, or obtaining any content, products, or services through the Site, and by submitting personal information to us, you agree to be bound by these terms. If you do not agree with all of these terms, then please do not use the Site and do not provide any personal information to us.

Minors

Minors (as defined under the laws of their jurisdiction or residence) are not eligible to register for, use, or purchase products or services available on or through our site, or register as Shoppers, Merchants, or Sales Representative. We do not knowingly collect personal information from any minor, and we will not use this information if we discover that it have been provided by a minor.

What information we collect and how we use it

For all visitors of the Site

You can visit certain areas of our Site without revealing who you are, or signing in. When a visitor accesses our Site, we collect the visitor’s IP address and browser information. The visitor’s computer or Internet Service Provide may assign the same or different IP addresses to the computer for different Internet sessions. Browser information includes the type and version of the Internet browser that your computer is using to access the Site, such as Internet Explorer, Firefox, or Safari. We may also identify the website or location from which the visitor came. We also collect information regarding the visitor’s traffic pattern and Site usage, such as the time spent on a page or the links or advertisements on which the visitor has clicked.

We use this information in aggregate form for statistical purposes in order to better understand our visitors, optimize the content that we serve, and improve the way in which we provide information about our Site or to our users and visitors. “Aggregated non-personal information” is information that is recorded about users and collected into groups so that it no longer reflects or references an individually identifiable user.

For registered users

We offer location-based shopping service that requires you to register for an account, providing Spreezio with personal or business registration information. In order for us to provide our full range of services, we may collect the following types of information.

Registration

When you sign up for a Spreezio account, you must complete the registration form. The following type of accounts can be created within Spreezio:

Shoppers

If you are a shopper, we may ask for personal information such as your name, home address, email address, cell phone number, date of birth, and account password. To protect your anonymity from Merchants and Sales Representatives, you must create an alias name to be referenced by. This alias name should not contain Personally Identifiable Information as this information will be communicated to Merchants and Sales Representatives when you submit an offer. You have the option to provide demographic information such as income level, educational level, net worth, and presence of children; we encourage you to submit this information so we can provide you a more personalized experience on our Site and / or present more relevant content. Only your alias is visible to third parties. All other personal information is kept confidential.

We use this information to contact you about the services on our Site in which you have expressed interest. We may combine the information you submit under your account with information from other third parties in order to provide you with a better experience, provide more relevant targeted content and / or advertisements, and to improve the quality of our services.

If you provide your email address, you may receive promotion email marketing communications from Spreezio from time to time. Spreezio users who wish not to receive these email marketing communications can unsubscribe from them by utilizing the “opt-out” link provided in each email. We reserve the right to send you certain communications relating to the Spreezio service, such as service announcements, administrative messages and the Spreezio Newsletter, that are considered part of your Spreezio account, without offering you the opportunity to opt out of receiving them.

Merchants or Sales Representatives

If you are registering as a Merchant or a Sales Representative, we ask for business information such as company name, your name, address, phone number, account password, merchandise or service category. You have the option to provide additional business information for public view to let shoppers know more about the products or services you carry to better differentiate yourself.

Profile

When you access Spreezio services, our servers automatically record information that your browser or Smartphone sends whenever you visit our Site. The server log files may include information such as your web request, Internet Protocol address, browser type, browser language, the date and time, and sales transaction information. We store information that we collect through cookies and log files to create a “profile” of your preferences. We may use this information for direct marketing purposes, or in aggregate for statistical purposes to better understand our customers.

In order to improve the quality of our smartphone applications, we have installed a “bug catcher” to collect application and system data in case the application encounters an abnormal condition yielding an application crash. This log information is automatically sent to our server so we can troubleshoot and fix the problem.

User Communication

If you contact Spreezio to ask a question, register a complaint, provide feedback, we will record any personal information and other content you that you provide in your communication so that we can effectively respond to it and improve our service. For service emails that we exchange with you, we collect only the personal information needed to handle your request, and retain it only for statistical purposes.

Business Messaging

In order to allow you to “make a deal” with other registered Merchants or Sales Representatives of the Spreezio Site, we record search queries, offer proffers (offers, counter offers, and acceptance) that you send and receive using the Spreezio business messaging system. We tie your personal identifiable information under your alias name to keep a purchase history while maintaining your anonymity. We also use this information in the aggregate to perform statistical analysis of user behavior and characteristics that we may share with third-parties as defined in the Terms of Use agreement. You cannot be identified from this aggregate information.

Site Activity

We record information relating to your use of the Spreezio Site such as your search queries, the pages you view, your browser type, IP addresses, requested URL, referring URL, and timestamp information. We use this information to administer the Spreezio Site and provide the highest level of service to you. We also use this information in the aggregate to perform statistical analysis of user behavior and characteristics in order to measure interest in and use of the various areas of the Spreezio Site.

Tell-A-Friend

If you choose to use our referral service to tell a friend or Merchant about our Site, we will automatically send them a one-time email inviting him or her to register on the Site, after your provide their name and email address. Spreezio stores this information for the sole purpose of sending this one-time, operational email. We do record information related referrals at the aggregate level to measure and track the success of our referral program.

Enforcement

Spreezio may use the information we collect in connection with your use of the Spreezio Site (including your personal information) in order to investigate, enforce, and apply our Terms of Use and Privacy Policy.

Location-based Data

Spreezio is 100% permission-based. Shoppers share location information only when an offer is sent. We are the only recipients of your location information and we do not constantly track your location. Spreezio receives this information about your actual location through GPS signals sent by a Smartphone or the physical address you gave us when you registered for an account. We tie your personal identifiable information under your alias name to your location in order to keep a purchase history while maintaining your anonymity. We also use this information in the aggregate to perform statistical analysis of user behavior and characteristics that we may share with third-parties as defined in the Terms of Use agreement. For example, we might use your location information to create aggregate data for location-sensitive advertising where a Merchant (the advertiser) does not know who you are. Location-based Data retained for long-term statistical use is converted to aggregate level data, and is only stored for 18 months.

Spreezio uses information for the following general purposes: to customize the advertising and content you see, fulfill your requests to submit an offer to Merchants and Sales Representatives, improve our services, contact you, conduct research, and provide anonymous reporting for internal and external clients.

How we collect personal information

We collect information about individuals in different ways. Some of the information is provided directly by you when you register with our Site, or fill out the forms displayed on our Site, or when you send us emails. We also use cookies to collect information while you are using Spreezio services.

A cookie is a small amount of data, which often includes an anonymous unique identifier, that is sent to your browser from a web site's computers and stored on your computer's hard drive. Each web site can send its own cookie to your browser if your browser's preferences allow it, but (to protect your privacy) your browser only permits a web site to access the cookies it has already sent to you, not the cookies sent to you by other sites.

Spreezio uses its own cookies for a number of purposes, including:

Access your information when you "sign in" so we can provide you with customized content and relevant information associated with your Spreezio account.
Keep track of preferences you specify while you are using Spreezio products or services.
Deliver advertisements relevant to your interests.
Provide general internal and customer analytics.
Conduct research to improve Spreezio’s content, products and services.
To assist in identifying possible fraudulent activities.

Spreezio may also use Web Beacons. A Web Beacon is an electronic file that allows Spreezio to count users who have visited a page. Spreezio’s practice is to include web beacons in HTML-formatted email messages (messages that include graphics) that Spreezio sends in order to determine which email messages were opened and to note whether a message was acted upon.

Information Sharing

Spreezio does not rent, sell, or share personal information about you with other people or non-affiliated companies except to provide products or services you've requested or when we have your permission. We do not provide personal information of Shoppers to Merchants or Sales Representatives. We will not disclose any personal information about our Shoppers except as set forth below, or as permitted or required by law.

Aggregate Information (non-personally identifiable) - We share aggregated demographic information about our user base with our partners, third parties, or affiliates. For instance, an appliance manufacturer might want to understand the shopper demographics of a large statistical population where their dishwashers sell best. For example, Spreezio could provide them with information related to the total number of Shoppers who purchased a dishwasher based on age ranges and zip code.
Personally Identifiable Information Under An Alias Name - We might share your Personally Identifiable Information that is masked (obscured) by your Alias name that you created at account registration. An example of this might be an advertiser sending you a personalized shopping incentive based on your location and/or demographics for an LCD TV that you are in the market for via Spreezio’s ad engine.

We may also share your information under the following circumstances:

We provide the information to trusted partners who work on behalf of or with Spreezio under confidentiality agreements. These companies may use your personal information to help Spreezio communicate with you about offers from Spreezio and our marketing partners. However, these companies do not have any independent right to share this information.
We may share your personal information with third parties to provide you with services that we offer through the Spreezio Site, conduct quality assurance testing, facilitate creation of accounts, provide technical and customer support, or provide specific services. These third parties are required not to use your personal information other than to provide the services requested by you.
We may share personal information provided by you during the registration process with third parties to gain additional insights about users. This information will be used in aggregate to facilitate research insights, delivery or relevant content and / or advertisements.
We believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Spreezio’s terms of use, or as otherwise required by law.
We may share your personal information with our parent company, subsidiaries, joint ventures, or other companies under a common control (collectively, "Affiliates") that we may have now or in the future, in which case we will require them to honor this Privacy Policy. If another company acquires our company or our assets, that company will possess your personal information, and will assume the rights and obligations with respect to that information as described in this Privacy Policy.

Spreezio displays targeted advertisements based on personal information. Advertisers may assume that people who interact with, view, or click targeted ads meet the targeting criteria—for example, men ages 25-34 from a particular geographic area.

Spreezio does not provide any personal information to the advertiser when you interact with or view a targeted ad. However, by interacting with or viewing an ad you are consenting to the possibility that the advertiser will make the assumption that you meet the targeting criteria used to target the ad.

We may disclose your personal information to third parties in a good faith belief that such disclosure is reasonably necessary to (a) take action regarding suspected illegal activities; (b) enforce or apply our Terms of Use and Privacy Policy; (c) comply with legal process, such as responding to a facially valid search warrant, subpoena, statute, or court order; or (d) protect our rights, reputation, and property, or that of our users, affiliates, or the public. Please note that we may question or contest the validity of any search warrant, subpoena or other similar governmental request that we receive.

Controlling your Personal and Business Data

Shoppers

Spreezio does not include personal information in a Shopper’s offer to Merchants or Sales Representatives. Your shopper personal information won’t be associated to your real name by Merchants, Sales Representatives, or third parties. They will be only able identify you and reply to your offer by your fictitious alias name you created at shopper registration. Their offer acceptance, counter offer, or “sweetened” offer is sent to your Spreezio account.

Note: if a shopper chooses to use our Click-to-Call feature, we cannot prevent the Merchant or Sales Representative from seeing your telephone number.

The shopper offers that you send using the Spreezio Sites are only confidential to the extent that you and the Merchant / Sales Representative/recipient keep them confidential. For example, we do not have any control over whether a recipient of one of your offers publicly posts the contents of such a offer.

Merchants and Sales Representatives

To the extent you include business information in your Merchant / Sales Representative (such as an image of yourself or business), Shoppers, users, and third parties will be able to identify you, associate you with your business account, and contact you. However, the responses to an offer or a proposal you send or receive using the Spreezio Site messaging feature are only confidential to the extent that you and the shopper/recipient keep them confidential private. For example, we do not have any control over whether a Shopper of one of your offers publicly posts the contents of such a offer.

How to change your contact and other personal information

Shoppers

As a registered Spreezio shopper, you can modify some of your personal information and your privacy preferences by accessing the “Your Account” section of our website. For example, you may choose not to receive e-mail solicitations from Spreezio by accessing the “Your Account” tab on the Spreezio Site and updating your notification settings. Upon your request, Spreezio will use commercially reasonable efforts to close your account, and cease displaying your submissions on the Spreezio Site; nevertheless, we may still retain your personal information in our systems for record keeping purposes or as part of our document retention policy. Registered users who wish to close their account should click here.

Merchants and Sales Representatives

As a registered Spreezio Merchant or Sales Representative, you can modify some of your personal information and your privacy preferences by accessing the “Your Account” section of our website. For example, you may choose not to receive e-mail solicitations from Spreezio by accessing the “Your Account” tab on the Spreezio Sites and updating your notification settings. Upon your request, Spreezio will use commercially reasonable efforts to close your account, and cease providing you offers on the Spreezio Site; nevertheless, we may still retain your business information in our systems for record keeping purposes or as part of our document retention policy.. Registered users who wish to close their account should click here.

How you can protect your personal information

Please remember to protect your login ID, password, and computer against unauthorized access. Remember to sign-off your password protected account when you are done. Close your browser to prevent your settings from being displayed to the next user.

Each Shopper, Merchant, and Sales Representative is responsible for keeping his/her login ID and password confidential. Please contact us immediately if you lose or misplace your login ID and/or your password, of if you become aware of an unauthorized use of this information, so that we can deactivate your account. You will be held responsible for all activities and access to our Site that were made through that login ID or password and that occurred before you notified us of their loss.

Information Security

We use physical, technical, and administrative safeguards to protect personal information stored within our Site against unauthorized access, alteration, disclosure, or destruction. We restrict access to personal information to Spreezio employees, contractors and agents who need to know that information in order to operate, develop, or improve our services. These individuals are bound by confidentiality obligations. Although we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot assure you that your personal information will never be disclosed in a manner that is inconsistent with this Privacy Policy. Transmissions over the Internet are never completely secure or error free. Because of this we cannot and do not guarantee the security, accuracy, or completeness of personal information while in transit through the Internet or air waves.

Email and Telephone Fraud – A warning about phishing

Fraudulent emails or telephone calls may attempt to lure you into sending personal information to a website without questioning or challenging the legitimacy of the request. We do not, and will not at any time request your personal account information, login ID, password, or other information in an unsecure or unsolicited email or telephone communication.

For more information about phishing, you may want to visit the Federal Trade Commission at www.onguardonline.gov.

Emails and Opt-Out

Spreezio users who wish not to receive email marketing communications from Spreezio can unsubscribe from them by utilizing the “opt-out” link provided in each email. In addition, you may opt-out of receiving commercial solicitations from us by changing your notification settings under the “Your Account” tab after you log on to a Spreezio Site. We reserve the right to send you certain communications relating to the Spreezio service, such as service announcements, administrative messages and the Spreezio Newsletter, that are considered part of your Spreezio account, without offering you the opportunity to opt out of receiving them.

Changes in this Privacy Policy

Please note that this Privacy Policy may change from time to time. We will post any Privacy Policy changes prominently on our Site. Your continue use of the Site following the posting of any changes to this Privacy Policy will constitute your acceptance of these changes.

Please note that at all times you are responsible for updating your personal information to provide us with your most current e-mail address. In the event that the last e-mail you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice.

Changes to this Privacy Policy may affect our use of personal information that you provided us prior to our notification to you of the changes. If you do not wish to permit changes in our use of your personal information after Site notification, you must deactivate your account with us. Your continued use of the Site following the notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

California Notice of Information-sharing Disclosure

We do not share personal information with a third party for that third party's direct marketing purpose other than as permitted by law. If we decide that we wish to provide business partners with contact details for direct marketing purposes of relevant services, products, and programs, we will provide a method for you to opt-out of having your personal information shared in such a manner. If you have further inquiries regarding our personal information sharing practices, please let us know.

If you no longer wish your information to be shared, please let us know by sending an email to privacy@spreezio.com.

Third party sites

Links

Spreezio may present links in a format that enables users to get additional value-added services from our partners. For example, if you want to see what products are available through Shopzilla, we will pass the search terms that you entered within the Spreezio application in the click through URL so Shopzilla can present appropriate results.

Other Sites

This Privacy Policy applies to Spreezio services only. We do not exercise control over sites linked to our Site that include Spreezio applications, widgets, or services, or links from within our various services. These other sites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Your use of these third party sites is subject to the Terms and Conditions, and the Privacy Policies of these other sites.

How to contact us

If you have any questions about this Privacy Policy, please feel free to contact us through our website or write to us at:

Privacy Matters
c/o Spreezio, Inc.
1290 Parkmoor, 3rd floor
San Jose, CA

In your letter, please describe in as much detail as possible ways in which you believe the Privacy Policy has not been complied with. We will investigate your complaint.