Incentives Marketplace Privacy Policy

Incentives Marketplace, LLC, on behalf of its subsidiaries, contractors, and partners (collectively, “Incentives Marketplace,” “us,” “we,” or “our”) is committed to building user trust and confidence by promoting, and complying with, business practices that help protect the privacy of our customer and user data.  This Privacy Policy covers all information collected and obtained through our operations, including hosted sights on behalf of our clients.  For more information about our solutions and companies, please review the information at the end of this Privacy Policy. 

Incentives Marketplace has prepared this Privacy Policy to describe to you, or if you represent an entity or other organization, that entity or organization, (in either case, “you,” “your,” or “User”) our practices regarding the personal information that Incentives Marketplace collects, uses, and shares regarding our online platforms (the “Platform”) accessed through the website located at http://www.IncentivesMarketplace.com/, and any other websites operated by Incentives Marketplace or its subsidiaries and partners (each, a “Site”) or using mobile applications provided by and on behalf of Incentives Marketplace or its subsidiaries and partners (each, an “Application,” and each Site and Application treated as a part of the “Platform” for purposes of this Privacy Policy). 

Incentives Marketplace reserves the right, at any time, to modify this Privacy Policy.  If we make revisions that change the way we collect, use, or share personal information, we will post those changes in this Privacy Policy.  You should review this Privacy Policy periodically so that you keep up to date on our most current policies and practices.  We will note the effective date of the latest version of our Privacy Policy at the end of this Privacy Policy.  

Please read this Privacy Policy carefully to understand Incentives Marketplace’s views and practices regarding your personal information and how we will treat it.  By visiting this Platform, you are freely accepting and consenting to the practices in this Privacy Policy.  You may withdraw your consent at any time and for any reason with effect to future data processing by contacting us at the address listed below in the Section titled “Communications”.  Without your consent, Incentives Marketplace will use personal information, only insofar as such processing is permitted by applicable law (e.g., for the performance of a contract or agreement between Incentives Marketplace and you) or where such processing is necessary for compliance with a legal obligation to which Incentives Marketplace is subject.

COLLECTION OF PERSONAL INFORMATION

Through your interactions with the Platform, Incentives Marketplace collects “personal information,” which is information that identifies an individual or relates to an identified individual.  Non-personal information means information that does not directly identify an individual.  We collect both types of information about you. 

The following provides some examples of the type of data that we collect from you:

In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources.

USE OF PERSONAL INFORMATION

In addition to the uses described above, Incentives Marketplace uses the personal information collected in an effort to improve your experience on the Platform, to provide services to you, and to communicate with you about information that you request.  Incentives Marketplace may also use personal information to help target specific offers to you and to help Incentives Marketplace develop and improve its services.  Additionally, Incentives Marketplace may use your personal information:

·       To identify you when you access and use any Sites or Applications.

·       To administer Accounts.

·       To provide services and content to our clients, which may include your employer.

·       To provide you with products and services you request, or that maybe be of interest to you.

·       To improve our services and product offerings.

·       To streamline your checkout process.

·       To send marketing and promotional materials, including information relating to products, services, sales, or promotions.

·       To respond to your inquiries related to support, employment opportunities, or other requests. 

·       To conduct research and analysis.

·       For internal administrative purposes, as well as to manage our relationship with you.

SHARING OF PERSONAL INFORMATION

In addition to the specific situations discussed elsewhere in this Privacy Policy, Incentives Marketplace may disclose personal information in the following situations:

·       Subsidiaries and Acquisitions. We may share your personal information with our corporate subsidiaries and divisions (e.g., affiliates, parent company, sister companies, joint ventures, or other companies under common control).  If another company acquires Incentives Marketplace or our assets, we will also share your personal information with that company. 

·       Other Disclosures with Your Consent.  We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy, and we may do so with your consent.

·       Other Disclosures without Your Consent. We may disclose personal information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws.  We may also share your personal information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our Terms of Use, or to comply with your request for the shipment of products to or the provision of services by a third-party intermediary.

·       Public.  Some of our Sites or Applications provide the opportunity to post comments, or reviews, in a public forum.  If you decide to submit information at these locations, that information may be publicly available.

·       Partner or Client Promotions and Offerings.  We may offer events, contests, sweepstakes, promotions, or any other offerings with third party partners or our clients, which may be your employer.  The personal information that you submit through an event, contest, sweepstakes, promotion, or other offering may be combined and transmitted with the Registration Information related to your Account.  Third-party partners may collection information directly from you, which may be combined with personal information disclosed by Incentives Marketplace.  This information may be collected through the Platform or during an Incentives Marketplace Event.  If you decide to enter into or participate in an event, contest, sweepstakes, promotion, or other offering that is offered by Incentives Marketplace, or a third-party partner or client, the information that you provide may be shared with us and with them.  Third party partners and clients that use Incentives Marketplace products and services to collect personal information must agree to abide by the same principles followed by Incentives Marketplace. 

·       Service Providers. We may share your personal information with service providers.  Among other things service providers may help us to administer our website, plan or facilitate events or travel, conduct surveys, provide technical support, or sending marketing, promotions, and communications related to our business, payment processing, and for other legitimate purposes permitted by law. 

SECURITY OF PERSONAL INFORMATION

Incentives Marketplace has implemented reasonable and appropriate security measures to help protect the personal information Incentives Marketplace collects from loss, misuse, unauthorized access, disclosure, alteration, and destruction.  Although Incentives Marketplace attempts to protect the personal information in its possession, no security system is perfect, and Incentives Marketplace cannot promise that your personal information will remain absolutely secure in all circumstances.

RETENTION OF PERSONAL INFORMATION  

Incentives Marketplace will retain your personal information as needed to fulfill the purposes for which it was collected.   Incentives Marketplace will retain and use your personal information as necessary to comply with Incentives Marketplace’s business requirements, legal obligations, resolve disputes, protect our assets, and enforce our agreements.

DATA INTEGRITY AND PURPOSE LIMITATION

Incentives Marketplace limits the use of personal information to ways that are compatible and relevant to the purposes for which the personal information was collected or subsequently authorized or for which consent was obtained.  Incentives Marketplace will take reasonable steps to ensure that personal information is reliable for its intended use, accurate, complete, and current.

YOUR CHOICES

You can make the following choices regarding your personal information:

·       Promotional Emails.  You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties or Incentives Marketplace’s clients.  You can stop receiving promotional emails by submitting a request at the contact in the “Communications” section below or following the unsubscribe instructions in e-mails that you receive.  Clicking on an unsubscribe link will take you to a webpage where you can complete the opt-out process.  Certain programs will provide a contact for support or other means to remove your name to remove your name from our contact list.  If you decide not to receive promotional emails, we may still send you transactional communications, such as those about your Account, to fulfill orders you have made, to ask you to rate a product you purchased, event you attended, or other service-related communications.

·       Changes to Your Personal Information.  We rely on you to update and correct your personal information.  Note that we may keep historical information in our backup files as permitted by law.  All requests to correct your information must be directed to the contact in the “Communications” section below.  

·       Access to Your Personal Information.  If required by law (for example, the EU General Data Protection Regulation), upon request, we will grant reasonable access to the personal information that we hold about a User.  All requests must be directed to the contact in the “Communications” section below.

·       Deletion of Your Personal Information.  Typically we retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.  Some Users may have the legal right (for example, under the EU General Data Protection Regulation) to request that we delete their personal information.  All deletion requests must be directed to the contact in the “Communications” section below.  We may also decide to delete your personal information if we believe that the data is incomplete, inaccurate, or that our continued use and storage are contrary to our obligations to other individuals or third parties.  When we delete personal information it will be removed from our active database, but it may remain in archives where it is not practical or possible to delete it.  In addition, we may keep your personal information as needed to comply with our legal obligations, resolve disputes, or enforce any of our agreements.

·       Revocation of Consent.  We rely on the processing of personal information that you have provided.  If you revoke your consent for the processing of personal information, then we may no longer be able to provide you services.  In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity.

·       Online Tracking.  We do not currently recognize browser signals of tracking preferences, which may include "Do Not Track" instructions.

·       California Residents.  California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing.  If you are a California resident and would like a copy of such notice, please submit a written request to us using the information in the “Communications” section below. 

·       European Economic Area Citizens.  Where you believe that we have not processed your personal information in accordance with the applicable provisions of the EU General Data Protection Regulation, you may lodge a complaint with the respective EU data protection authority (DPA).

CROSS-BORDER TRANSFER OF PERSONAL INFORMATION

Incentives Marketplace may transfer your personal information to Incentives Marketplace’s entities in the United States, or to third parties as described in this Privacy Policy that are located in various countries around the world.  By using Incentives Marketplace’s Platform, or providing any personal information to Incentives Marketplace, where applicable law permits, you consent to the transfer, processing, and storage or such information outside of your country of residence where data protection standards may be different.  When Incentives Marketplace collects information in one country, and transfers it to another, to the extent possible it applies the same level of data protection required under the laws in the first country even when the data is in the second country.

Incentives Marketplace safeguards and enables the global transfer of personal information in a number of ways.  The following describes some of the protections that are taken with regard to data originating from certain countries:

·       EU-U.S. and Swiss-U.S. Privacy Shield:  Incentives Marketplace adheres to the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Framework concerning the transfer of personal information from the European Union and Switzerland to the United States.  Accordingly, Incentives Marketplace follows the EU-U.S. Privacy Shield Principles published by the U.S. Department of Commerce (“Privacy Shield Principles”) with respect to all such data.  Incentives Marketplace complies with the Privacy Shield Principles for all onward transfers of personal information from the EU and Switzerland, including the onward transfer liability provisions.  Incentives Marketplace specifies in contracts with service providers that handle the personal information collected by Incentives Marketplace that the personal information "may only be processed for limited and specified purposes consistent with" the purposes laid out in this Privacy Policy.  Those third parties agree to provide the same level of protection as the Privacy Shield Principles.  In certain situations, if a third party that receives personal information from Incentives Marketplace takes an action that is contrary to the Privacy Shield Principles, Incentives Marketplace will be liable for those actions unless it can prove that it was not responsible for causing them.  If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  Compliance with the Privacy Shield Principles may be limited, however, in certain cases to the extent necessary to meet national security, public interest, or law enforcement requirements.  All Incentives Marketplace personnel with access to personal information are obligated to familiarize themselves and comply with provisions of this Privacy Policy.  To learn more about the EU-U.S. and Swiss-U.S. Privacy Shield Framework, please visit https://www.privacyshield.gov. A violation of Incentives Marketplace’s commitment to EU-U.S. and Swiss-U.S. Privacy Shield Framework may be investigated by the Federal Trade Commission.  With respect to personal information received or transferred pursuant to the EU-U.S. and Swiss-U.S. Privacy Shield Framework, Incentives Marketplace is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

DISPUTE RESOLUTION

In compliance with the Privacy Shield Principles, Incentives Marketplace commits to resolve complaints about your privacy and our collection or use of your personal information.  EU individuals with questions or concerns about our use of personal information or our privacy policy should submit a written request to us using the information in the “Communications” section below.

Incentives Marketplace commits to cooperate with EU data protection authorities (DPAs) and comply with the advice given by such authorities with regard to human resources data transferred from the EU in the context of the employment relationship.  Incentives Marketplace has further committed to cooperate with the panel established by the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from Switzerland in the context of the employment relationship.

COMMUNICATIONS

Questions, concerns, or complaints should be directed to:

By phone: 952-934-5474 

By Email: info@incentivesmarketplace.com; Attn:  Data Integrity

Through Mail:

Attn: Data Integrity Office                                                                                     Incentives Marketplace, LLC
8929 Aztec Drive
Eden Prairie, MN 55347

If Incentives Marketplace is required to contact you about your personal information we may do so by mail, phone, or email.

Effective as of 5/15/2020.