Effective Date: August 11, 2020
ChatThreads Corp. DBA Purchased (“Purchased,” “us,” “we,” or “our”) is committed to protecting the privacy of users (“user,” “you” or “your”) of (a) its websites, including Purchased.com, Shopalongapp.com, WhyNotBuy.com, and their affiliated sub-domains (collectively, the “Site”); (b) mobile applications, including the Shopalong or Why Not Buy mobile applications (collectively, “Mobile Apps”); (c) surveys or other research opportunities offered on the Site or Mobile Apps, or hosted on a third-party website for one of our clients (“Surveys”); (d) sweepstakes or other incentive programs administered by Purchased (“Incentives”); (e) SMS (short messaging service) alert programs (collectively, "SMS Alerts"), and (f) any other products or services offered under the Purchased, Shopalong and/or Why Not Buy brands (collectively, and inclusive of all capitalized terms in this list, the “Services”).
This Privacy Policy governs data collection and usage associated with the Services. By accessing, browsing and/or using the Services, whether you (a) are a “visitor” (which means that you simply browse the Services), (b) are a “registered user” (which means that you have registered with Purchased), or (c) complete a Survey hosted on a third-party website, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.
This Privacy Policy is incorporated into and is subject to our Terms of Use. If you do not agree with this Privacy Policy, do not use the Services.
WHAT PERSONAL INFORMATION DOES PURCHASED COLLECT?
Information You Actively Submit
In order to engage with us beyond simply surfing the Site or a Mobile App (for example, by registering, filling out a Survey, inquiring about our Services, registering for SMS Alerts or contacting us), you may be required to provide information which may personally identify you, such as your name, email address, mailing address, and/or mobile phone number (“Personal Information”). In each case, you know what Personal Information we collect, because you will actively submit the information.
Information We May Passively Collect
If you choose to participate in certain Surveys, we will collect additional information about your activities on your device, including but not limited to all webpages that you visit on the device and apps that you use on the device. Participation in Surveys that require this additional information is optional. For more information, see the “Does Purchased Track Digital Activities?” section below.
Location Information, IP Addresses, Invitation URLs
If you visit the Site or interact with our Services on your mobile device, and your device is configured to allow it, we may also collect geolocation data. Otherwise, we only collect location data from individuals who explicitly agree to share it with us. Your location data will not be sent to us beyond the Survey participation period. We will not share your location data on an individually identifiable basis. You have the ability to stop location sharing by opting out of the Survey. When you fill out a Survey on the Site, or on a third-party website, we may also collect internet protocol (“IP”) addresses and/or the Uniform Resource Locator ("URL") on which you were invited to complete a Survey in order to help assess fraudulent Surveys, and to administer and operate the Surveys.
Registration Information
Only users who are direct participants in marketing programs with Purchased or our business partners are required to complete a registration form in order to complete our Surveys. During this registration process we will ask for Personal Information, as well as demographic information, such as age, sex, income level, and educational and racial/ethnic background (“Demographic Information”).
Online Reporting Tool
Additionally, in connection with our online reporting tool at ort.purchased.com, we collect data on client users (not general consumers or participants in research studies), including how often they access different pages and how often they log in. We also provide this data to our clients so they can see how they use the reporting dashboards.
Automatic Collection via Cookies
We also utilize cookies to gather and store certain information automatically. For more information, see the “Does Purchased Use Cookies?” section below.
No Requirement to Submit Personal Information
You may choose not to provide us with any Personal Information; however, if you do so you may not be able to access and use all of the Services. The results that we send to our clients and/or provide to research participants do not include Personal Information.
HOW DOES PURCHASED USE YOUR PERSONAL INFORMATION?
We may use Personal Information held about you for a number of purposes, included but not necessarily limited to the following: (a) to ensure that content is presented in the most effective manner; (b) to provide you with information, products or services that you request from us or which we feel may interest you; (c) to provide you with email newsletters, if you have requested them; (d) to allow you to participate in interactive features of our Services; (e) to notify you about changes to our Services; (f) to administer and operate Incentives; (g) to screen for and prevent undesirable or abusive activity; and (h) to help our clients better understand how to communicate with and/or serve you.
Contacting You
If we contact you, we generally do so for one of the following purposes: (a) to invite you to participate in Surveys; (b) to confirm the details of Surveys you have agreed to take part in; (c) to conduct Surveys with you; (d) to validate answers/views you gave in a recent Survey (if you have consented to us doing so); (e) to answer any inquiries you have sent us or our client about the Survey; (f) to update and to ensure that our records of your Personal Information are correct; (g) send reminder notifications and confirmation messages; and (h) to ask you about how we can improve your experience with us.
Demographic Information
We may use Demographic Information provided by registered users to analyze similarities, differences or trends among registered users, and we may share such information with third parties. Personal Information may be shared with our business partners but only after permission to do so has been obtained from the registered user.
Legally Required Uses
Purchased may be required to disclose personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. We reserve the right to disclose your Personal Information as required by law and when we believe that disclosure is necessary to: (a) comply with a judicial proceeding, court order, or legal process; (b) protect our rights or property; (c) enforce our Terms of Use; (d) detect, prevent, or otherwise address fraud, security or technical issues; (e) operate or conduct maintenance and repair of our services or equipment, as authorized by law; or (f) protect against imminent harm to the rights, property or safety of the Services, users or the public, as required or permitted by law.
WHAT STEPS DOES PURCHASED TAKE TO PROTECT PRIVACY?
We take reasonable steps to safeguard Personal Information we collect from unauthorized access or disclosure, or accidental loss, alteration or destruction. Personal Information is encrypted during transmission using secure socket layer technology (“SSL”), and is also encrypted while at rest. Unfortunately, no data transmission or electronic storage is guaranteed to be 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk.
Purchased will offer EEA and Swiss individuals whose personal information has been transferred to us the opportunity to choose whether the personal information it has received is to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. An individual may opt-out of such uses of their personal information by contacting us at privacy (at) purchased (dot) com.
SHARING OF PERSONAL INFORMATION WITH THIRD PARTIES
We restrict access to and disclose Personal Information to Purchased employees and third parties acting as either our agents or service providers who need to know that Personal Information in order to perform their functions for Purchased. These third parties are prohibited from using your Personal Information for any other purpose, and have committed to meeting data protection obligations which are at least as restrictive as those contained in this Privacy Policy.
Awarding of prizes from Incentives may result in your contact details being passed onto a third party (e.g., Amazon or PayPal) in order for the prize to be sent out to you electronically.
If you indicate consent to sharing your feedback and contact information with third-party companies (such as retailers or manufacturers) as part of your participation in SMS Alerts or Surveys and use of our Mobile Apps then we will provide your feedback and contact information with the third-party companies you designate.
Except as otherwise stated herein, we will not rent, sell, or otherwise release your Personal Information to third parties without your explicit permission.
Notwithstanding the foregoing, we may transfer, sell or assign information concerning your use of the Services, including without limitation Personal Information, to third parties, as a result of the sale, merger, consolidation, change in control, transfer of substantial assets, reorganization or liquidation of Purchased, provided that said third parties agree to abide by our Privacy Policy as it applies to Personal Information.
DOES PURCHASED USE COOKIES?
We use cookies, including session ID cookies, to make it easier for you to use the Services. A session ID cookie expires as soon as you close your browser window and does not remain on your computer.
Through the use of cookie technology or otherwise, we also gather and store certain information automatically. This information includes IP addresses, browser types, Internet service providers, operating systems, and access dates/times (collectively “Traffic Data”). Except for IP addresses, Traffic Data is anonymous information that does not personally identify you, but Traffic Data may be linked to Personal Information that you provide through other means. We use this Traffic Data to design and arrange our web pages in the most user-friendly manner, to continually improve our Services, to make our Services easier for you to use, and to validate other information the user provides. We may also use Traffic Data to analyze trends, administer the Services, track user’s movement, and gather Demographic Information for aggregate use. Traffic Data and Demographic Information may be shared with third parties.
Cookies may also be placed on your computer as a result of our use of Google Analytics. Google collects and stores Traffic Data and also information about how you got to the Site. Read more about Google Analytics here.
This Privacy Policy does not cover the use of cookies by any advertisers. For more information on internet advertising, including how to opt out of third-party behavioral advertising, see the Digital Advertising Alliance’s Your Ad Choices website.
DOES PURCHASED USE WEB BEACONS OR GIF FILES?
We may access and set cookies using web beacons (or similar technologies) also known as single-pixel GIFs which are invisible graphical images. Our Site may contain web beacons that allow us to count users who have visited the Site and to deliver services. We may include web beacons in e-mail messages, newsletters or the like, in order to determine whether they have been opened and/or acted upon. Some of these web beacons, including persistent cookies, may be placed on your computer by our service providers to help determine the effectiveness of our research or e-mail communications. This allows the service provider to recognize your computer each time you visit certain pages or e-mails and compile anonymous information in relation to those page views, which in turn enables us and our service providers to learn which e-mail communications bring you to our Services and how you use our Site.
DOES PURCHASED TRACK DIGITAL ACTIVITIES?
We may collect information about digital activities on our Mobile Apps. If you conduct a search by entering a search term using our mobile apps then we may capture the search term(s) you entered and the first link you tapped, if any. Your search data will not be sent to us beyond the Survey participation period. We will not share your search data on an individually identifiable basis. You have the ability to not have this search data tracked by opting out of the Survey.
If you choose to participate in certain Surveys, we will collect the following additional information (Additional Digital Information) about your activities on your device:
Participation in Surveys that require Additional Digital Information is optional. To enable us to collect Additional Digital Information, you must take certain steps such as downloading an SSL certificate, granting access to “Survey” capabilities through your operating system, and downloading a Virtual Private Network (VPN) tool that allows us to collect the additional activity data. If you do not want us to collect the additional activity data described above, then do not participate in a Survey that requires this information.
If you choose to enroll in Surveys that require Additional Digital Information, you can temporarily pause the Additional Digital Information data collection at any time in the Mobile Apps. Directions to disable the Additional Digital Information data collection are here. However, if you want to remove the data collection tools that you installed to participate in Surveys requiring Additional Digital Information from your device, then you must follow the additional instructions which will be emailed to you when you disable Additional Digital Information data collection.
Pausing or disabling Additional Digital Information data collection will not pause or disable any other data collection through our Mobile Apps. If you no longer want us to collect information from you, you can stop responding to Surveys and asked to be removed from participation. We may continue to use and share the information that you previously provided, as described in this Privacy Policy.
DO NOT TRACK SIGNALS
Some browsers have a “do not track” feature that lets you tell websites you do not want to have your online activities tracked. Because these features are not yet uniform, we do not presently respond to “do not track” signals.
HOW LONG DOES PURCHASED RETAIN INFORMATION?
If you fill out a Survey on a third-party website, we will retain Personal Information you submit through that Survey for three (3) years, so that the client can follow up with you about your Survey responses and also to detect for fraudulent Surveys. We also retain information in anonymized form indefinitely for benchmarking purposes (i.e., so that we can compare Survey results against aggregate data), and in pseudonymized form for the purpose of associating an initial survey with a follow-up survey. If you register as a Shopalong user, we keep your registration information, including Personal Information, for as long as your account is active. We do this to administer Incentives, to facilitate your repeated participation in Surveys, and for fraud detection services. If you wish to cancel your account or request that we no longer use your information, contact us using the “Contact Information” below. Notwithstanding the foregoing, we reserve the right to retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
HOW DO USERS UPDATE THEIR INFORMATION?
If you wish to delete, correct, or update information previously provided to us, you may do so by logging into your account and changing the information, or by contacting us at the information in the “Contact Information” section below. We commit to responding to your request for access to modify or delete your information without undue delay, and in any event within thirty (30) days.
HOW DO USERS LIMIT THE USE AND DISCLOSURE OF THEIR PERSONAL DATA?
To limit the use and disclosure of your personal data, please use the “Contact Information” below to request that we no longer use your information and to cancel your account. Notwithstanding the foregoing, we reserve the right to retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
CHILDREN’S PRIVACY
We are concerned about the safety and privacy of children, and are committed to protecting their online privacy. In accordance with the Children’s Online Privacy Protection Act, we will not knowingly collect any personally identifiable information from or provide any services to children under the age of 13. In addition, minors are not eligible to participate in any of our Incentives.
PUBLIC FORUMS
Our Site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your Personal Information from our blog or community forum, contact us at the “Contact Information” below. In some cases, we may not be able to remove your Personal Information, in which cases we will let you know why we are unable to do so.
SOCIAL MEDIA AND WIDGETS
Our Site includes certain social media features, such as the Facebook Like button, as well as widgets, such as “share” buttons or other interactive mini-programs that run on our Site. These features may collect your IP address, or which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Your interactions with these features and widgets are governed by the respective privacy policies of the companies providing them.
THIRD-PARTY LINKS
This Services may contain links to third-party web sites. The linked sites are not under our control, and we are not responsible for the contents or use of any linked site. We provide these links as a convenience only, and a link does not imply endorsement or sponsorship of, or association or affiliation with, the linked site. If you decide to access linked third-party web sites, you do so at your own risk.
Our Why Not Buy service uses Google Maps APIs. Please refer to Google's Privacy Policy for more details.
PRIVACY SHIELD
Purchased complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Purchased has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/
Purchased is registered under the EU-U.S. Privacy Shield Framework (“Privacy Shield”), and accordingly is committed to the EU-U.S. Privacy Shield Principles and is under the enforcement authority of the Federal Trade Commission. For a list of all companies participating in Privacy Shield, see here: https://www.privacyshield.gov/list.
Purchased shall remain liable under the EU-U.S. Privacy Shield Principle of Accountability for Onward Transfer if its sub-processors process your Personal Information in a manner inconsistent with the Privacy Shield Principles, unless we prove we are not responsible for the event giving rise to the damage.
If you are visiting this website from a country other than the country in which our servers are located, your communications with us will result in the transfer of information across international boundaries. By visiting this website and communicating electronically with us, you consent to such cross-border transfers. In the case of data transfers from the European Economic Area the EU-U.S. Privacy Shield Framework applies.
Your Information may be transferred to and maintained on servers located outside of your country where the privacy/data protection laws may not provide the same protection level as those in your jurisdiction. If you are located outside the United States and choose to provide Information to us, we might transfer Personal Information to the United States and process it there. To ensure the safety of this transfer and the compliance with the applicable European data law, we utilize EU Model Contracts, the EU-U.S. Privacy Shield (if applicable) and express consents (Data Transfer Agreements) in relation to Personal Information originating the European Union or the United States.
If we share your Personal Information with third-party service providers and/or processors, we will: (a) transfer such Personal Information only for limited and specified purposes; (b) require the processor to provide at least the same level of privacy protection as is required by this Privacy Policy; (c) take reasonable and appropriate steps to ensure that the processor effectively processes the Personal Information transferred in a manner consistent with the obligations under this Privacy Policy; (d) require the processor to notify us if it determines it can no longer meet its obligation to provide the same level of protection as is required by this Privacy Policy; (e) upon notice, take reasonable and appropriate steps to stop and remediate unauthorized processing; and (f) provide a summary or a copy of the relevant privacy provisions of its contract with that processor to the Department of Commerce upon request.
Individuals in the EU
In compliance with the EU-U.S. Privacy Shield Principles, Purchased commits to resolve complaints about your privacy and our collection or use of your Personal Information. European Union individuals with inquiries or complaints regarding this Privacy Policy should contact Purchased at the “Contact Information” below.
Purchased has further committed to refer unresolved privacy complaints under the EU-U.S. Privacy Shield Principles to the Insights Association Privacy Shield Program, a non-profit alternative dispute resolution provider located in the United States and operated by the Insights Association. These dispute resolution services are provided at no cost to you.
If your complaint is not resolved after following the recourse mechanisms described above, you may have the ability to invoke binding arbitration. Additional information is available here.
Please note that, in addition, you also have the right to lodge a complaint with the supervisory authority in the relevant EU Member State.
Individuals Outside the EU
Purchased commits to resolve complaints about your privacy and our collection or use of your Personal Information. Non-EU citizens with inquiries or complaints regarding this Privacy Policy should contact Purchased at the “Contact Information” below.
CHANGES TO THIS PRIVACY POLICY
If we make material changes to this Privacy Policy, we will notify you here or by email, or by means of a notice on our home page. Changes to our Privacy Policy will be effective when posted. Your continued use of the Services following the posting of any change shall constitute your acceptance thereof. Unless otherwise agreed, we will use Personal Information in accordance with the Privacy Policy under which the Personal Information was collected.
CONTACT INFORMATION
If you require any further information about our Privacy Policy, please contact us at:
Attn: Privacy Department
Purchased Corporation
31 St. James Ave
6th Floor
Boston, MA 02116
USA
URL: https://www.purchased.com
E-mail: privacy (at) purchased (dot) com
Phone: 617-209-4319
Fax: 617-249-0238
DISPUTE RESOLUTION
All disputes arising under this Privacy Policy shall be governed by and interpreted in accordance with the laws of Massachusetts, without regard to principles of conflict of laws. The parties to this Privacy Policy will submit all disputes arising under this agreement to arbitration in Boston, Massachusetts, before a single arbitrator of the American Arbitration Association (“AAA”). The arbitrator shall be selected by application of the rules of the AAA, or by mutual agreement of the parties, except that such arbitrator shall be an attorney admitted to practice law Massachusetts. No party to this Privacy Policy will challenge the jurisdiction or venue provisions as provided in this section. Nothing contained herein shall prevent the party from obtaining an injunction.
CLASS ACTION WAIVER
Any arbitration or court trial, whether before a judge or jury or pursuant to judicial reference, related to any claim under this Privacy Policy will take place on an individual basis, without resort to any form of class or representative action (“Class Action Waiver”). THIS CLASS ACTION WAIVER PRECLUDES ANY PARTY FROM PARTICIPATING IN OR BEING REPRESENTED IN ANY CLASS OR REPRESENTATIVE ACTION REGARDING A CLAIM UNDER THIS POLICY. Regardless of anything else herein, the validity and effect of the Class Action Waiver may be determined only by a court and not by an arbitrator.
NOTICE TO RESIDENTS OF CALIFORNIA AND CANADA
If you are a California resident, you have the right to request and receive information about the Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of Personal Information that was shared and the names and addresses of all third parties with which we shared the Personal Information.
If you are a Canadian resident, please note that any Personal Information you provide to us may be transferred to our offices in the U.S. You agree that by providing us with your Personal Information, your Personal Information may be subject to U.S. laws, regulations and/or court orders and may be disclosed to third parties or U.S. authorities in complying with U.S. laws, regulations and/or court orders.
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