Dropshop (“we,” “our,” or “us”) provides the following Privacy Policy ("Privacy Policy” or “Policy"), which sets forth our practices related to collecting, using, disclosing, and sharing information that is personally identifiable to a user (“Information”). This Privacy Policy also discusses consumers’ data privacy rights under U.S. state law, including the California Consumer Privacy Act (“CCPA”), the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CTDPA”), the Virginia Consumer Data Protection Act (“VCDPA”), the Utah Consumer Privacy Act (“UCPA”) and any state data privacy/protection laws enacted after the date hereof and how to exercise those rights. California Consumers: Click here to read the California Notice at Collection within this Privacy Policy. Capitalized terms used but not defined herein shall have the same meaning as in the Website’s Terms and Conditions (“Terms and Conditions”), which are fully incorporated herein by reference.

By accessing and using one of our websites that we own and operate (collectively, the “Websites” and individually, a “Website) which offers programs where users complete Tasks provided by third party advertisers (“Advertisers”) and earn Featured Products, all as described in the Terms and Conditions (the “Program”), you signify your acceptance of this Privacy Policy and your agreement to the collection, use, disclosure, and sharing of your Information as described herein. If you do not intend to agree to the terms of this Privacy Policy or the Terms and Conditions, DO NOT use the Website or participate in the Program.

This Privacy Policy is subject to change from time to time. Your continued use of the Website following the posting of changes to these terms will confirm your acceptance of all changes made except for changes which expand the use of your Information. If we expand or alter how we use your Information, we will notify users by: (a) sending the modified Policy to our users via email; or (b) any other reasonable means acceptable under applicable state and federal law.

We may collect the following categories of Information:

• Identifiers (such as name, shipping address, email address, mobile/landline phone number);
• Commercial information (including preferences, products or services purchased, obtained, or considered, or other purchasing data);
• Internet or similar network activity (such as browsing and search history and information about a consumer’s interaction with a website, application, or advertisement) and information made available via Internet activity (such as device types, user agent data, referring URLs, and IP addresses);
• Information related to a user’s consent to receive SMS messaging, commercial email, and other forms of communication (which may include the creation of a report and session recordation of a user interacting with page(s)) that seek to obtain a user’s “prior express written consent” (as defined in the Telephone Consumer Protection Act (“TCPA”)) (“TCPA Consent”) to receive text SMS messages;
• Information collected from third parties or parties under common control (which includes our parent, subsidiaries, and other entities under common control with us - collectively "Related Parties") to validate and augment a user’s profile including a user’s email address, postal address, telephone number, device ID, or other user Information;
• Information collected from customer support department and fulfillment service providers, including customer support inquiries, Feature Product-related claims and emails and, as needed, proof of identification and completion of Tasks and Feature Product claims process requirements;
• Information relating to a user’s interaction with SMS messaging and other forms of communication; and
• Information collected from Cookies (as defined below), including whether a user has previously visited the Website.

We collect Information from and about users (see below for additional descriptions of the methods of Information collection that are provided to California residents) from the following sources:

We may collect Information from the following sources:

• Directly from the user via registration forms, emails, telephone calls, USPS mail, and other communications received as part of customer service or to redeem Feature Products;
• From publicly availably sources, such as Internet search engines;
• Via our hosting servers, which collect Information from users through various technological means when users access and interact with the Website;
• From our service providers and contractors who assist us in hosting the Websites, providing customer support, and fulfilling Featured Products and Gift Cards (collectively, “Service Providers”);
• From parties under our common control (which includes our parent, subsidiaries, and other entities under common control with us - collectively "Related Parties");
• From our third-party publishers, who may drive users to the Website;
• From cookies (small text files placed on a user’s browser by a website such as the Website that track online behavior), web beacons (single-pixel GIF image files), and other technological means (collectively, “Cookies”); and
• By combining Information, collected from various sources, including our Related Parties, to augment and verify Information and to improve the overall quality of our services.

We do not sell your Information but may use your Information as set forth below:

• For the purpose of selecting Tasks and Featured Products to display to you that we believe may be of interest to you and sending text/SMS message alerts and other communications that users have requested or consented to receive or that we are required to send concerning the Program;
• For Website operations, content improvements, testing, research, analysis, and product development;
• To verify whether users are entitled to participate in the Program, have completed Tasks and entitled to claim and to fulfill a Featured Product;
• To provide users with customer service and respond to customer inquiries;
• To carry out our obligations and enforce our rights arising from any contracts entered into between users and us, including for purposes of our Arbitration Agreement and any inquiry specific to express written consent under the Telemarketing Sales Rule (“TSR”) and/or the TCPA;
• To detect, investigate, and respond to any fraudulent or malicious activity or any other activity we determine is or may be a violation of our Terms and Conditions, this Policy, and/or existing laws, rules, and regulations;
• As necessary or appropriate to protect the rights, property, and/or safety of us and our Advertisers, Service Providers, service providers, Related Parties, and any other third party with whom we have a contractual relationship for commercial or business purposes;
• To maintain suppression or opt-out lists so that we won't contact users who have asked not to be contacted;
• To augment Information by enhancing it with other data sources provided by our Related Parties and service providers to enable us, for example, to gain deeper insights into our users; and
• To respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims, or when we determine it is necessary to comply with applicable laws and/or regulations.

As noted above, we do not sell Information. But we may share Information in the following ways:

• With our Advertisers and Service Providers in connection with our marketing activities, including the delivery of text/SMS messaging provided that we have obtained TCPA Consent from such users to be contacted text/SMS messaging and any other specific form of communication;
• With our Related Parties to augment and verify the Information we collect and to develop and enhance their products and services;
• With one or more Service Providers who provide independent verification of consent, including verification of consent for purposes of the TSR and TCPA;
• To enable our customer service providers to perform their respective tasks, including for fulfillment of Feature Products (including Face Verification where utilized); and
• To enable our Information verification and fraud detection Service Providers to perform contracted-for services.

When we share Information with our Service Providers, we enter into agreements that describe the purpose for which the Information is shared, restrict its use to the agreement’s specified purpose, and require that all Information remain confidential and be protected from unauthorized disclosure.

We may share Information with our Service Providers and technology partners as necessary if we become the subject of bankruptcy proceedings, or in connection with the sale, assignment, merger, or other transfer of all or a portion of our business. If we are involved in any of these transactions, we will notify users via email and a Policy update on the Website regarding any material details pertaining to Information.

The Websites are designed to comply with the Children's Online Privacy Protection Act (“COPPA”) and other laws protecting children’s privacy. In compliance with COPPA, we do not knowingly collect or retain Information from children under the age of 13 and any under the age of 13 is not permitted to claim Feature Products. If you are a parent or guardian of a child under 13 years of age and you think your child has given us Information, you can email us at help@myprivacyrequest.com.) In compliance with the CCPA, we do not knowingly sell or share Information of users under the age of 16.

Our website may use Cookies to determine whether users have previously visited the Website. We may also use Cookies to enhance a user’s experience while on the Website. Some of our third-party partners may place Cookies on the Website to track users’ online behavior while on the Website and after they leave the Website. These third-party Cookies may enable the delivery of interest-based advertisements (to find out more about Cookies, visit https://www.networkadvertising.org/understanding-online-advertising/glossary/) based on a user’s visit to the Website and/or other websites. In addition, our partners may use Information gathered in this manner to recognize users across different channels and platforms, including computers, mobile devices, and Smart TVs. Our partners may use this information over time for advertising, analytics, attribution, and reporting purposes. For additional information about the health-related, political, and related custom data segments used for advertising, please click here .

We may use Google Analytics and similar tools provided by our third-party partners to help analyze how users interact with the Website and to display customized ads and other content to our users during a current browsing session or in the future when the user is online. These analytics are performed by using the technological means described above to monitor a user’s interactions with the Website and do not involve the collection of any additional Information.

Most browsers are initially set up to accept Cookies, but users can reset their Internet browsers to refuse all Cookies or to indicate when a Cookie is being sent or to refused online tracking. To disable and reject certain Cookies, follow the instructions associated with your Internet browser. In general, when a “do-not-track” setting is active, the user’s browser notifies other websites that the user does not want their personal information and online behavior to be tracked and used, for example, for interest-based advertising. As required under some State laws, we are required to inform users that, as is the case with most websites, we generally do not honor or alter our behavior when a user to one of the Websites has activated the "do-not-track" setting on their browser. The exception to this is in the case of California consumers, where, in compliance with the CCPA, we will honor any opt-out preference signals they set on applicable browsers.

Even where you reject a Cookie, you may still use the Website but your ability to use certain features or offerings may be impaired. For example, if you return to the Website, you may have to re-enter Information you previously supplied to us. We may retain Cookie data indefinitely.

Users may opt-out from interest-based advertising delivered to their web browser by companies who have elected to participate in one of the interest-based advertising opt-out mechanisms such as the Digital Adverting Alliance’s opt-out program located here or the National Advertising Institute’s opt-out program located here. Users may also choose to opt-out of interest-based advertising on their mobile devices. For more information, please click here. Please note that opting out of interest-based advertising does not mean you will no longer see advertising online. Rather, it means that the company or companies from which you opt-out will no longer show ads that have been tailored to your interests.

Users may opt-out from receiving future contact from us via the following ways:

• SMS/Text Messaging Opt-Out. To revoke consent for, or opt-out from, SMS/text messaging, reply STOP to text/SMS messages received or contact customer service here; and
• Targeting Advertising Opt-Out. To-opt out of Cookies, interest-based advertising and/or third-party analytics, see the section above. California consumers may also reference the Rights of California Consumers section on how to set their global privacy controls.

In addition, and as described below, residents of California and other U.S. states have the statutory right to opt-out of the sale or sharing of their Information. We do not sell your Information or share it for any cross-contextual advertising purposes. We only share Information with our Service Providers for the limited purpose of performing specific business functions as described above.

Users who provide Information to us may contact us here to correct their Information, request their Information be deleted, and/or access what Information we have collected, processed, and shared with Service Providers. We will respond to user requests within forty-five (45) days. If you request deletion of your Information, please note that your Information will be suppressed from further use as described in this Policy. Note that we may retain and use your Information as necessary to comply with our policies including legal obligations, dispute resolution, and enforcement of our agreements.

When you make a request regarding accessing, correcting, or deleting your Information, we will ask individual users to identify themselves and the Information requested to be accessed, corrected, or deleted before processing such requests. To the extent permitted by applicable law, we may decline to process requests that we are unable to verify, are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning Information residing on archive servers).

The Website contains links to other sites or services. When you link from the Website to a third-party site, for example, when you click on an ad for Deal and link to the Deal website, you are leaving the Website and are subject to the privacy policies and terms and conditions of those sites – NOT this Privacy Policy. We are not responsible for the privacy practices, content, or security of such third-party sites.

We use commercially reasonable efforts to prevent unauthorized access, disclosure, or accidental loss or destruction of your Information. Access to your Information is strictly limited and we take reasonable measures to ensure that your Information is not accessible to the public. We restrict access to users’ Information to only those persons who need access to perform or provide their job or service, both internally and with our third-party Service Providers.

As part of the multistep Feature Product claim process, you may be asked to verify your identification by scanning or uploading a clear photo of an unexpired, government-issued ID and providing a live video or selfie, which will be matched to the government-issued identification card (“Face Verification”). This Face Verification process is operated through our Service Providers, who store the Information for no longer than six (6) months. This Information is treated with strict confidentiality and, other than being collected and processed for the purposes of the Feature Products claim process, is only accessed by us in instances involving disputes or allegations of fraud or abuse. Submission of your government-issued identification card via a secure process is encrypted end-to-end, and your Information will only be used for purposes of identification verification.

We do not otherwise generally collect sensitive Information such as medical information, health insurance information, data collected from an automated license plate recognition system, Social Security Number, and/or credit card information. If and when we do collect, store, and transmit sensitive information, that Information will be encrypted with advanced TLS (Transport Layer Security).

While we have endeavored to create a secure and reliable Website for users, we are not able to fully eliminate security risks associated with Information. Given the nature of the Internet, your Information passes through entities that we are unable to control. Therefore, we cannot guarantee that our security measures or those of third parties who access or transmit your Information will prevent your Information from being improperly accessed, stolen, or altered. In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies if we learn of an information security breach of your Information. You will be notified via email in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.

Some U.S. states have enacted laws that provide statutory rights to consumers in their state. The information below describes those rights and how you can exercise them.

This Policy provides timely notice to users, including those who are California residents and fall within the definition of “consumers” as provided for in the CCPA, that we collect Information at or before collection.

We collect the following categories of Information from users: identifiers (such as name, email address, mobile/landline phone number); commercial information (including preferences, products or services purchased, obtained, or considered, or other purchasing data); internet or similar network activity (such as browsing and search history and information about a consumer’s interaction with a website, application, or advertisement) and information made available via Internet activity (such as device types, user agent data, referring URLs, and IP addresses); information related to a user’s consent to receive SMS messaging and other forms of communication (which may include the creation of a report and session recordation of a user interacting with page(s) that seek to obtain a user’s “prior express written consent” (as defined in the TCPA) (i.e., TCPA Consent) to receive text messages; information collected from third parties or Related Parties to validate and augment a user’s profile including a user’s email address, postal address, telephone number, device ID, or other user Information; information collected from customer support department and fulfillment service providers, including customer support inquiries, Feature Product-related claims and emails and, as needed, proof of identification and completion of Feature Product requirements; information relating to a user’s interaction with SMS messaging and other forms of communication; and information collected from Cookies, including whether a user has previously visited the Website.

We collect these categories of Information for the following purposes: to you with information about our products and/or services that we believe may be of interest to you, including sending text/SMS message alerts and other communications that users have requested or consented to receive or that we are required to send concerning users’ registrations; for Website operations, content improvements, testing, research, analysis, and product development; to verify whether users are entitled to participate in the Program and, if so, to fulfill Featured Products; to provide users with customer service and respond to customer inquiries; to carry out our obligations and enforce our rights arising from any contracts entered into between users and us, including for purposes of our Arbitration Agreement and any inquiry specific to express written consent under the TSR and/or the TCPA; to detect, investigate, and respond to any fraudulent or malicious activity or any other activity we determine is or may be a violation of our Terms and Conditions, this Policy, or existing laws, rules, and regulations; as necessary or appropriate to protect the rights, property, and/or safety of us and our Service Providers, Related Parties, and any other third party with whom we have a contractual relationship for commercial or business purposes; to maintain suppression or opt-out lists so that we won't contact users who have asked not to be contacted; to augment Information by enhancing it with other data sources provided by our Related Parties and Service Providers to enable us, for example, to gain deeper insights into our users; and to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims, or when we determine it is necessary to comply with applicable laws and/or regulations.

We do not sell or share your Information for commercial purposes. We share Information with our Service Providers for the following business purposes: in connection with our marketing activities, including the delivery of email messaging and text/SMS messaging; to provide independent verification of consent, including verification of consent for purposes of the TSR and TCPA; for customer service tasks, including the fulfillment of Featured Products, and for Information and fraud detection purposes. We also share Information with our Related Parties to augment and verify the Information we collect and to develop and enhance their products and services.

We will retain your Information unless you exercise your data privacy rights for so long as we need to protect us from claims related to your interactions with us. For example, if you complete Tasks so you can claim one of our Featured Products or claim a Featured Product, will retain the Information relating to your sign up for so long as you could challenge those transactions. For Face Verification, the Information is retained no longer than six (6) months.

We do not knowingly collect, sell or share Information of users under the age of sixteen (16).

Please see the Rights of California Consumers section immediately below to learn about California consumer privacy rights and how to exercise those rights. This includes the right to know the Information companies may have collected and sold, the right to opt-out from the sale or sharing of Information, and the right to correct or delete your Information.

California consumers have rights under the CCPA regarding their Information. These rights are:

• Right to Know. The right to know what Information we have collected, including the categories of Information, the source of collection, our purpose for collecting the Information, the categories of third parties with whom we disclose, share or sell that Information and for what reason, and the specific pieces of Information we have collected about you. We do not sell or share your Information for commercial purposes.
• Right to Delete. The right to request that we delete the Information about you that we have collected. Note that there are certain exceptions to this right, including when the Information is necessary to provide you with goods or services you requested, to prevent fraud, and to comply with our legal obligations.
• Right to Correct. The right to request that we correct inaccurate Information that we maintain about you.
• Right to Opt-Out of Sale/Sharing. The right to limit or opt-out from the sale or sharing of Information. We do not sell or share your Information for commercial purposes.
• Right to Opt-Out of Sale/Sharing of Sensitive Information. The right to limit or opt out from the sale or sharing of the sensitive Information, as defined under the CCPA. Note that there are certain exceptions to this right, including when the Information is necessary to provide you with goods or services you requested, to prevent fraud, and ensure safety and security. We do not sell or share your Information for commercial purposes.
• Right to Non-Discrimination. The right not to receive discriminatory treatment for exercising your privacy rights.

To exercise your CCPA rights, click on the “Do Not Sell My Personal Info” link on the bottom of the Website page where we collect Information, or send an email to help@myprivacyrequest.com. Although this link is called “Do Not Sell My Personal Info”; we do not sell or share your Information and the link will take you to a form where you can exercise your other rights such as the right to know, the right to delete, and the right to correct.

Verification Process. We require a verification process for requests to access, correct or delete Information in order to prevent an unauthorized third party from accessing or making decisions regarding a user’s Information. Generally, we will verify a request by matching the identifying information supplied by the user with the Information we already have for the user. If we cannot verify the user using the foregoing method, we may request additional information, such as a government-issued identification card, which we will not retain or use for any other purpose. In most cases, we will facilitate your request through automated tools available through your password-protected account.

Use of an Authorized Agent. California consumers may also designate an authorized agent to make these requests on your behalf. You must provide written authorization to the authorized agent that they are authorized to act on your behalf. When contacting us, the agent must submit proof of that authorization. If you use an authorized agent to submit a request, we may need to collect additional information, such as a government issued identification card, to verify your identity before processing your request to protect your Information.

Timing. We will confirm receipt of your request within ten (10) business days. For all verifiable consumer requests, we strive to respond within forty-five (45) days of receipt. If we require additional time, which can be up to ninety (90) days in the aggregate, we will provide written notice. Any disclosures we provide will be delivered electronically in a secure fashion. If, for some reason, we cannot fulfill or comply with your request, our response will explain that decision.

How We Handle Deletion Requests After Verification. Once we receive and confirm your request to delete, we will delete or de-identify (and direct our Service Providers and other applicable third parties to delete) your Information from our system other than from our archive servers (which we maintain for compliance purposes), unless there is an applicable exception. If we do not comply with a deletion request, we will provide you with grounds for the denial in writing. Note that after a deletion request, we may retain and use your Information for the limited purpose of complying with our policies, including this Policy and to comply with applicable laws.

Disclosure of Information Collected and Sold. Once we receive and confirm your verifiable consumer request to access your Information, we will disclose to you the following:

• The categories and sources of Information collected;
• Where applicable, our business and commercial purposes for collecting and selling that Information;
• The categories of third parties with whom we shared that Information;
• The specific pieces of Information collected;
• If we disclosed your Information for a business purpose, we will disclose the Information categories for each category disclosed and the categories of third parties to whom the Information was disclosed.

Face Verification Information Used Only to Fulfill Feature Products. To verify your eligibility for Feature Products, we or our Service Provider may request that you upload a government-issue identification card and live video (collectively “Face Verification”). Our Service Providers processes this Information to ensure your eligibility for Feature Products and the Information is stored for no longer than six (6) months. We do not have access to this Information except in instances involving disputes or allegations of fraud or abuse.

You do not need to provide us with any Sensitive Personal Information (other than Face Verification) in order to claim Feature Products. However, due to the nature of our business, once you provide us with the Information, we unable to separate Sensitive Personal Information from other Information. If you would like to exercise your Right to Limit, we will treat the request as a Right to Delete request. Click on the “Do Not Sell My Personal Info” link on the bottom of the Website page where we collect Information, or send an email to help@myprivacyrequest.com.

Certain browsers allow users to enable an opt-out preference signal in their browser settings (a “Global Privacy Control”). When a Global Privacy Control is enabled, it signals websites that the user visits that the user is automatically exercising their right to opt-out of the sale or sharing of their Information without the need, for example, of clicking on a “Do Not Sell My Information” link. Via our Service Provider, we have enabled acceptance of users’ Global Privacy Control settings.

Commitment to Nondiscrimination. We are committed not discriminating against California consumers who exercise their CCPA rights. As such, unless otherwise permitted by the CCPA, we will not deny, charge you different prices or rates, or provide a different quality level of goods or services, including through granting discounts or other benefits, or imposing penalties, and/or suggest that you may receive a different price, rate, or quality level of goods or services. While we do not provide financial incentives for users who do not exercise their CCPA rights, please note that some of the functionality of the Website may be unavailable if consumers exercise their right to have their Information deleted.

CCPA Metrics. If we are required, we will compile certain annual metrics regarding the CCPA including the number of disclosure, deletion and opt-out requests we receive, the median number of days it takes us to respond, and how many of each were denied.

Virginia, Colorado, Connecticut, and Utah consumers have rights under the VCDPA, CPA, CTDPA, and UCPA, respectively, regarding their Information. These rights include:

• Right to Know. The right to know whether we are processing your Information.
• Right to Access. The right to access your Information we have processed.
• Right to Delete. The right to request that we delete the Information about you that we have collected.
• Right to Correct. The right to request that we correct inaccurate Information that we maintain about you (Virginia, Colorado, and Connecticut).
• Right to Data Portability. The right to obtain a copy of your Information in a portable format.
• Right to Opt-Out. The right to opt-out of targeted advertising, the sale of Information, and/or any automated processing performed on Information that evaluates, analyzes, or predicts personal aspects of the user (“profiling”).

To exercise your statutory privacy rights, click on the “Do Not Sell MyPersonal Info” link on the bottom of the Website page where we collect Information, or send an email to help@myprivacyrequest.com.

Timing. If we have not taken action or deny your request to know, access, correct, delete or opt-out, you may appeal the decision within ninety (90) days by writing to us at help@myprivacyrequest.com. Within sixty (60) days of receipt of this written appeal, we will inform you in writing of any actions taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

De-identified Data Disclosure. We may use de-identified data in some instances (data that cannot be linked to any identifiable natural person or any device linked to any such person). We maintain de-identified data without attempting to re-identify it, and any de-identified data that is sold or shared is not able to be re-identified.

Commitment to Nondiscrimination. We are committed to not discriminating against consumers who exercise their privacy rights. As such, unless otherwise permitted by applicable law, we will not deny, charge you different prices or rates, or provide a different quality level of goods or services, including through granting discounts or other benefits, or imposing penalties, and/or suggest that you may receive a different price, rate, or quality level of goods or services. While we do not discriminate against users who exercise their rights, please note that some of the functionality of the Website may be unavailable if consumers exercise their right to have their Information deleted.

Other U.S states grant their residents privacy rights, including, for example, in Nevada, where you have the right to opt-out of the sale of Information. To exercise your privacy rights, please submit your request by clicking on the link “Do Not Sell MyPersonal Info” or send an email to help@myprivacyrequest.com. In your request, please specify that you want to exercise your rights and specify the Website that you visited and the email address you registered with. We may contact you to ask you for further information to help you exercise your rights. We will try to respond to requests within one month and we will let you know if we need to take longer, for example, because your request is complicated. Other states have enacted data privacy laws and more are expected to do so. We will update this Policy as necessary to reflect these new laws when they take effect.

If you have any questions, comments, complaints, or suggestions regarding this Policy or the Website, please contact us here.