Effective Date: December 31, 2023
PerkSpot operated by 12 Interactive LLC (“PerkSpot” or “we” or “us”) respects your privacy and is committed to protecting it through our compliance with this policy. This Privacy Policy (our “Privacy Policy”) describes the type of information we may collect from you when you visit the website www.perkspot.com or a private label sub-domains delivered by 12 Interactive LLC, (i.e., abc.perkspot.com, etc.), use our mobile application, browser extension; or the PerkSpot service on behalf of your employer or organization (collectively, our “Services”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This Privacy Policy applies to information we collect:
Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services. By accessing or using our Services, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Notification of Changes to this Policy). Your continued use of these Services after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.
12 Interactive LLC is a limited liability corporation with a principal place of business at 320 W. Ohio St., Chicago, IL 60654. If you reside or are located in the European Economic Area ("EEA") 12 Interactive LLC is the data controller of all Personal Information (as defined below) collected via the Site and of certain Personal Information collected from third parties, as set out in this Privacy Policy.
We are committed to protecting your privacy. At no time will we trade, sell, or distribute for free organization-specific or personal information, including email addresses or other user IDs, to any individual, company, vendor or organization, in ways other than disclosed in this privacy statement.
The PerkSpot service is a portal through which users access discounts redeemable at selected vendors. In some cases, online purchases facilitated by the PerkSpot portal are subject to the privacy policies of the website where that transaction is conducted, whose policies may differ from those that govern PerkSpot.
Throughout this Privacy Policy, the term “Personal Information” means any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or device. However, Personal Information does not include any deidentified or aggregated information.
Your first name, last name, email address, and location represent the only pieces of personal information required to access the Services. In certain instances, other demographic data will be collected but is not required. Purchases on our website or through vendors may require the collection of billing information such as address, phone numbers, credit card numbers, and banking information. Your information may also include preferences, other demographic or anonymous usage data.
In the past twelve (12) months we may have also collected information from the following categories.
Category | Applicable Pieces of Personal Information Collected |
---|---|
A. Identifiers. | A real name, postal address, unique personal identifier/employee ID, online identifier, Internet Protocol address, email address, or other similar identifiers. |
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). |
A name, address, telephone number, education, and employment information. Some Personal Information included in this category may overlap with other categories. |
C. Protected classification characteristics under California or federal law. | Gender |
D. Commercial information. | Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
F. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interactions with PerkSpot Services, log file information, operating system, browser type, or advertising ID |
G. Geolocation data. | Physical location through IP address. |
Current or past job history, employee ID, or employer. | |
K. Inferences drawn from other Personal Information. | Profile reflecting a person’s preferences and behavior. |
We obtain the above categories of personal information from the following categories of sources:
PerkSpot collects click-stream data and other preference information in order to improve the function and vendor selection of the service for you or for others. (Click-stream data represents a page-by-page history of a person’s service usage.)
We use (or may use) cookies and web beacons when you visit our Site. For more information on our use of cookies and web beacons, please refer to our Cookies Policy.
Personal information is gathered to ensure a prompt and accurate reply by a PerkSpot representative, as well as other vendors and service providers. You may also have the option to provide feedback on services.
You, your employer, or organization may provide data to us, such your status as an employee and other personal information.
PerkSpot uses your Personal Information to provide the benefits/services associated with the program.
PerkSpot uses your information to provide the Services to you and customize the Services to your interests. Other business purposes of collecting your information include:
We will also use your personal information in any other way we may describe when you provide the information or for any other purpose with your consent.
We may also use your information to contact you about third parties’ goods and services that may be of interest to you. If you wish to change your choice, you may do so at any time by logging into the Services and adjusting our user preferences in the “My Account Page” by checking or unchecking the relevant boxes or by sending us an email stating your request at cs@perkspot.com.
We take measures to protect your privacy and your right to only be contacted with your permission. Your information is only shared in the following cases:
Please note that our Services link to vendor websites and your use of those vendor websites are governed by those vendors without direct control or jurisdiction by us or this Privacy Policy. Each vendor maintains its own privacy policy that you should be familiar with before you submit your personal information. Our Privacy Policy is not applicable on any of the vendor sites. Therefore, it is important for a potential buyer to familiarize themselves with the privacy policies of each vendor.
We do not share your Personal Information with your employer or organization, unless your employer’s or organization’s contract with us permits or the law requires us to do so.
Your information may be combined with others or anonymized to provide insights into the use of the Services including user enrollment and use. This anonymous or aggregated data may be shared with vendors, employers, organizations, and others with an interest in our Services.
We partner with reputable service and technology providers to deliver our Services. Your information may be transmitted to them and stored on their servers; however, your information, along with our own company secrets and software, is considered confidential. Providers have no rights to your information.
PerkSpot may use an outside company to fulfill orders and a credit card processing company to bill you for goods and services. These companies do not retain, share, store, or use Personal Information for any other purposes unless explicitly disclosed to you.
PerkSpot may also disclose your Personal information:
At any time, users may opt out of PerkSpot related correspondence by sending an email to cs@perkspot.com. Users may also access their personal information, including email address, and make edits in the “My Account” section of the website.
Requests are honored as immediately as possible but may take up to five days.
When you opt-out of communications, your email address and some data is retained, but only for these specific purposes:
Our Services are not intended for children under 18 years of age. No one under age 18 may provide any personal information to or on the Services. We do not knowingly collect Personal Information from children under 18. If you are under 18, do not use or provide any information on our Services or on or through any of its features, make any purchases through the Services, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received Personal Information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information directly from a child under 18, please contact us at cs@perkspot.com.
In accordance with the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (collectively, the “CPRA”), if you are a resident of California, you have the additional rights described below.
We have collected over the prior twelve (12) months the Personal Information that is listed in Section III above (See Information We Collect). We collect personal information from the sources (See Categories of Sources) and use your Personal Information (See How Information is Used) as described in this Privacy Policy.
In the past twelve (12) months, we have disclosed the following categories of Personal Information for one or more of the business purposes to the following categories of third parties:
Personal Information Category | Categories of Non-Service Provider and Non-Contractor Third Party Recipients |
---|---|
A. Identifiers. | Advertisers and advertising networks, Affiliates, parents, and subsidiary organizations of PerkSpot, and business partners. |
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | Advertisers and advertising networks, Affiliates, parents, and subsidiary organizations of PerkSpot, and business partners. |
C. Protected classification characteristics under California or federal law. | Not disclosed |
D. Commercial information. | Advertisers and advertising networks, Affiliates, parents, and subsidiary organizations of PerkSpot, and business partners. |
F. Internet or other similar network activity. | Not disclosed. |
G. Geolocation | Advertisers and advertising networks, Affiliates, parents, and subsidiary organizations of PerkSpot, and business partners. |
I. Professional or Employment Related Information | Not disclosed. |
K. Inferences drawn from other Personal Information. | Not disclosed. |
We disclose your Personal Information to the categories of third parties listed above for the following business purposes:
In addition to the above, we may disclose any or all categories of Personal Information to any third party (including government entities and/or law enforcement entities) as necessary to:
We do not sell Personal Information as the term “sell” is commonly understood to require an exchange for money. However, the use of advertising and analytics cookies on our Website is considered a “sale” of Personal Information as the term “sale” is broadly defined in the CPRA to include both monetary and other valuable consideration. Our “sale” would be limited to our use of third party advertising and analytics cookies and their use in providing behavioral advertising and their use in understanding how people use and interact with our Services. Our “sales” of your Personal Information in this matter is subject to your right to opt-out of those sales (see Your Choices Regarding our “Sale” of your Personal Information).
In the preceding twelve (12) months, PerkSpot has not “shared” for the purpose of cross-context behavioral advertising.
In the preceding twelve (12) months, PerkSpot has “sold” for monetary or other valuable consideration the following categories of Personal Information to the following categories of third parties:
Personal Information Category | Sold or Shared | Categories of Third Parties To Whom Your Personal Information is Sold or Shared |
---|---|---|
A. Identifiers. | Sold | Service Providers (such as advertising networks and analytic providers) and Affiliates of PerkSpot |
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | Sold | Service Providers (such as advertising networks, analytic providers, and payment processors) and Affiliates of PerkSpot |
C. Protected classification characteristics under California or federal law. | No | N/A |
D. Commercial information. | Sold | Service Providers that utilize data to help PerkSpot deliver our Services |
F. Internet or other similar network activity. | Sold | Service Providers (such as advertising networks and analytic providers) |
G. Geolocation data. | Sold | Service Providers that utilize data to help PerkSpot deliver our Services |
I. Professional or employment-related information. | No | N/A |
K. Inferences drawn from other Personal Information. | No | N/A |
Your Personal Information may be “sold” as described above for the following business or commercial purposes:
The CPRA prohibits a third party from reselling Personal Information unless you have received explicit notice and an opportunity to opt-out of further sales.
We do not “sell” the Personal Information of minors under the age of 16 for monetary or other valuable consideration without affirmative consent as required by the CPRA. More information on how minors under the age of 16 may change their choice regarding the “sale” of their Personal Information can be found in Your Choices Regarding our “Sale” of your Personal Information.
The CPRA provides California residents with specific rights regarding their Personal Information. This section describes your CPRA rights and explains how to exercise those rights. You may exercise these rights yourself or through your Authorized Agent. For more information on how you or your Authorized Agent can exercise your rights, please see Exercising Your Access, Data Portability, Correction, and Deletion Rights. These rights include the right to:
Brief details of each of these rights are set out below. You also have the right to opt-out of our sale or sharing of your Personal Information, as described further below.
You have the right to request that PerkSpot disclose certain information to you about our collection and use of your Personal Information over the past 12 months (a “Right to Know” Consumer Request).
You also have the right to request that PerkSpot provide you with a copy of the specific pieces of Personal Information that we have collected about you, including any Personal Information that we have created or otherwise received from a third party about you (a “Data Portability” Consumer Request).
You have the right to request that we correct any incorrect Personal Information about you to ensure that it is complete, accurate, and as current as possible. In addition to other methods, you may have to exercise this right as described below, you may review and correct some Personal Information about yourself by logging into the “My Account” page and updating your details directly.
You have the right to request that PerkSpot delete any of your Personal Information that we collected from you and retained, subject to certain exceptions.
As a consumer you have a right not to receive discriminatory treatment by PerkSpot for the exercise of privacy rights conferred by the CPRA.
To exercise the right to know, data portability, correction, and deletion rights described above, please submit a verifiable consumer request to us by either:
PerkSpot will only comply with a privacy request when a request is made by yourself or an authorized agent. To designate an authorized agent, see Authorized Agents below. We may request additional information so we may confirm a request to delete your Personal Information.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. To verify your identity, you must:
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, PerkSpot considers requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.
We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
You may authorize your agent to exercise your rights under the CPRA on your behalf by registering your agent with the California Secretary of State. You may also provide your authorized agent with power of attorney to exercise your rights. If you authorize an agent, we may require that your agent provide proof that they have been authorized exercise your rights on your behalf. We may request that your authorized agent submit proof of identity We may deny a request from your agent to exercise your rights on your behalf if they fail to submit adequate proof of identity or adequate proof that they have the authority to exercise your rights.
If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information for monetary or other valuable consideration at any time (the “right to opt-out”). We do not sell the Personal Information of Consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time.
To exercise the right to opt-out of the “sale” of your Personal Information for monetary or other valuable consideration, you (or your authorized representative) may submit a request to us. You may also set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. However, if you do not consent to our use of cookies or select this setting you may be unable to access certain features or parts of our Services or other websites. You can find more information about cookies at http://www.allaboutcookies.org and http://youronlinechoices.eu.
Do Not Sell or Share My Personal Information
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales. However, you may change your mind and opt back into the sale of Personal Information at any time by:
You do not need to create an account with us to exercise your opt-out rights. You may be required to provide us with additional contact information so that we may verify your request to opt-in to the sale of your Personal Information. We will only use Personal Information provided in an opt-out request to review and comply with the request.
PerkSpot offers our members certain perks, including discounts, rewards and other offers and benefits as part of the PerkSpot Rewards & Recognition Program ("Rewards Program"). We also offer other programs, including the PerkSpot Loyalty Points Program ("Loyalty Program"). When you sign up for PerkSpot or one of our programs, we typically ask you to provide certain contact information (such as name, email address, and/or telephone number). Because our programs involve the collection of personal information as well as the offering of various benefits, they might be interpreted as providing a “financial incentive” under California law. By participating in our programs, you agree that in addition to the Rewards Program-specific terms provided in our Terms of Use, the following terms apply.
By using the PerkSpot Rewards Program or participating in the Loyalty Program, you agree that the incentive you receive as the result of your participation in the program (e.g., the discounts on goods or services that you access through our Website and/or Rewards Points) is reasonably related to the value of any personal information that you provide to us as a result of participating in the program. To the extent that we derive value from the collection of your personal information, that value is directly related to the value to us of the opportunity to promote products and services to you as well as the value of the benefits that you obtain. The specific expenses for the program vary based on your participation, activity, total spend, the information you provide, and the discounts, promotions, or offers you choose to use.
You may withdraw from participating in a program at any time by contacting us at cs@perkspot.com. You acknowledge and agree that withdrawing may result in limited or restricted access to PerkSpot's offers and that you may no longer receive the incentive offered as part of our Loyalty Program and that this is not a discriminatory practice against you for exercising your rights under the CPRA.
We do not collect any Sensitive Personal Information
We adhere to GDPR guidelines, meaning we make the following commitments to users residing or located in EEA, and strive to make the same available to others where possible:
You can access your Personal Information and confirm that it remains correct and up-to-date or choose whether or not you wish to receive material from us or some of our partners by logging into the Site and visiting your “My Account” page.
If you would like further information in relation to your rights or would like to exercise any of them, you may also contact us via cs@perkspot.com. You have the right to request that we:
We try to answer every email promptly where possible and provide our response within the time period stated by applicable law. Keep in mind, however, that there will be residual information that will remain within our databases, access logs and other records, which may or may not contain your Personal Information. Please also note that certain Personal Information may be exempt from such requests in certain circumstances, which may include if we need to keep processing your Personal Information to comply with a legal obligation.
When you email us with a request, we may ask that you provide us with information necessary to confirm your identity.
If you have any concerns or complaints regarding the way in which we process your data, please email us directly at cs@perkspot.com. You also have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.
We will keep your Personal Information for no longer than is necessary for the purpose(s) it was provided for and to meet our legal obligations. Further details of the periods for which we retain Personal Information are available on request.
We adhere to GDPR guidelines, meaning we make the following commitments to users residing or located in the EEA, and strive to make the same available to others where possible: Personal Information is retained for no longer than necessary for the purposes for which the Personal Information is processed.
However, we may retain any or all categories of Personal Information when your information is subject to one of the following exceptions:
In order to provide our Services to you, we may send and store your Personal Information outside of the EEA or the United Kingdom, including to the United States. Accordingly, your Personal Information may be transferred outside the country where you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Data. Your information may be processed and stored in the United States and United States federal, state, and local governments, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your information through the laws of the United States. By using our Services, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Data outside the country where you reside or are located, including in the United States.
We respect your privacy and take precautions to ensure your safety as a user of our Services. We strive to treat your personal information with the same standard of care we use with our own Personal Information. While we cannot protect from every eventuality, we take measures to protect the Services and your data from theft, corruption, misuse, illegal action, or other malfeasance.
We assign a special standard of care to Personal Information for the purpose of protecting your privacy and to make it difficult for anyone to contact you without your permission.
Within our company, access to your information is restricted to those with a business need to be able to access it. We employ additional safeguards including encryption, physical controls, and two-factor authentication to restrict access to your information.
When selecting vendors to participate in the Services, we consider their history and reputation with regard to consumer privacy and data protection.
Users will be notified of changes or revisions to this Privacy Policy, including our email practices, by a notice posted on the login page of PerkSpot. The notice will contain a link, whereby the Privacy Policy can be examined in full. In this way, registered users are made aware of policy changes prior to shopping or browsing the website. As always, a user who is not amenable to the conditions of a revised privacy policy may request to have their account deleted by emailing cs@perkspot.com.
As a user of PerkSpot, you consent to our collection and storage of your personal information, including email address, (as defined above) in our database, and to our use of aggregated and non-personal information generated by the viewing habits of our users. We store your personal information on servers located in the United States of America. By agreeing to this Privacy Policy, you give your consent for us to do so.
Neither you, nor your employees or other Users, may redistribute, sublicense, or modify the Service or the Content, in any manner without our express prior written consent. Users may use the Service for generally acceptable personal or business purposes subject to the terms of use posted on our Website. Users may not knowingly: (i) send or store material containing software viruses, worms, Trojan horses or other harmful computer code, files, scripts, agents or programs; (ii) interfere with or disrupt the integrity or performance of the Services; or (iii) attempt to gain unauthorized access to the Services or its related systems or networks.
Questions or comments regarding this Policy should be submitted to PerkSpot by mail to:
PerkSpotOr by email to 12 Interactive Customer Service (cs@perkspot.com)