Privacy Policy
Effective Date: January 1, 2021
This PRIVACY POLICY (the “Privacy Policy”) explains how GABS ELEPHANT, INC. (“Elephant Foot Stamp”, “Elephant Foot” “EFS” “Company”, “we”, “us”, and/or “our”) and protects the personal information of persons who interact with our website, elephantfoot.com (“Site”), mobile application (“App”), or platform (“Platform”) (the Site, App, and Platform shall collectively be the “Service”), and the transactional information of persons who make purchases from merchants that have subscribed to our Platform (“Rewards Providers”).
Even if you do not sign up as a customer of Elephant Foot Stamp, we may still collect, process, use, store, and share your transactional data in accordance with this Privacy Policy. By using the Service, you agree to the policies and practices described in this Privacy Policy and the Terms of Use. If you do not agree with our policies and practices, you may choose not to use the Service.
Elephant Foot Stamp may offer certain products and/or services for a fee or for evaluation purposes. In such situations, additional terms or requirements may apply to our collection and use of personal information, and if there is any conflict between such additional terms and this Privacy Policy, the additional terms will control.
PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE SUBMITTING ANY INFORMATION TO COMPANY OR THROUGH ANY COMPANY SOFTWARE OR MOBILE APPLICATION. BY SUBMITTING ANY INFORMATION, YOU ARE ACKNOWLEDGING THAT YOU HAVE READ AND UNDERSTAND THIS POLICY AND THAT YOU AGREE TO BE BOUND BY ITS TERMS. IF YOU DO NOT AGREE TO BE BOUND BY THE TERMS OF THIS PRIVACY POLICY, SIMPLY EXIT THIS PAGE AND/OR THE APPLICATION WITHOUT ACCESSING OR USING ANY OF OUR SERVICES.
Information We Collect
When you interact with us through the Service, we may collect personal information from and about you. You may interact with us directly, such as when you sign up for a Elephant Foot Stamp account through the Site or App, as well as indirectly, such as when you sign up for a Elephant Foot Stamp account through our Platform operated by one of our Rewards Providers. When you make a purchase or otherwise interact with one of our Rewards Providers, we may also collect transactional information from you.
Information You Provide
We collect personal information from you when you voluntarily provide it, such as when you register for access to the Service and create an account, use certain aspects of the Service, contact us with inquiries or respond to one of our surveys. For example, we may collect your name, phone number, email address, birthdate, location information, Third-Party Service (defined below) login credentials, other information (such as your online activity) based on your registration and privacy settings on those Third-Party Services, and the messages you send or receive through the Service.
Information Automatically Collected
We collect transactional information automatically when you transact with one of our Rewards Providers. Transactional information may include details from your stamping activity (e.g., stamp, coupon), coupon activity (e.g., coupon issued, coupon redeemed) by Rewards Providers.
When you interact with the Service, we also may use various technologies, including cookies, web beacons, pixel tags, log files, local shared objects (Flash cookies), HTML5 cookies, or other tracking technologies, to automatically collect certain general user data and information, including aggregate measures of the Service’s use and aggregate technical and other data about your use of the Service that does not personally identify you. For example, we may track the total number of visitors or users of the Service, the number of visitors to each page of our Site or App, the domain names of our visitors’ Internet service providers, and how end user customers use and interact with the Service.
We automatically receive information from your web browser or mobile device. This information
includes the name of the website from which you entered our Website, if any, as well as the name of
the website to which you’re headed when you leave our website. This information also includes the IP address of your computer/proxy server that you use to access the Internet, your Internet Website
provider name, web browser type, type of mobile device, device number (IMEI for Android and a UUID-
analog for iOS,) and operating system.We use all of this information to analyze trends among our Users to help improve our Services.
Tracking Options and California Do Not Track Disclosures
Our cookies and other tracking technologies help provide additional functionality to the Service and help us analyze Service usage more accurately. For instance, our Service may set a cookie on your browser that saves your login credentials. You can set your browser or operating system settings to limit certain tracking or to decline cookies, but by doing so, you may not be able to use certain Service features. Please refer to your web browser’s or operating system’s website or “Help” section for more information on how to delete and/or disable your browser or operating system from receiving cookies or controlling your tracking preferences.
To learn more about the use of cookies or other technologies to deliver more relevant advertising and to know your choices with respect to collection and use of the data by these third-party tools, you may visit the Network Advertising Initiative’s (NAI) opt-out page at http://www.networkadvertising.org/choices.
To opt-out of the use of your mobile device ID for targeted advertising, please see http://www.aboutads.info/appchoices. On your mobile device, you may also adjust your privacy and advertising settings to control whether you want to receive more relevant advertising.
Our system may not respond to Do Not Track requests or headers from some or all browsers.
Combination of Information & Collected from Third-Party Services
We may combine the personal information we receive from or about you, including information you provide to us and information we automatically collect through the Service, as well as information across other computers or devices that you use, with information we collect or receive about you from other online and offline sources, or from other third party sources.
In addition, one of the special features of the Service is that it allows you to integrate various online third-party services, such as social media and social networking services (“Third-Party Services”), directly into your Elephant Foot Stamp experience. To take advantage of this feature, we will ask you to provide us your username and password for the relevant Third-Party Services. By enabling such Third-Party Services, you are allowing us to pass your Third-Party Service log-in information to these Third-Party Services for this purpose. When you add a Third-Party Service account to the Service, we will collect your Third-Party Service login information and other relevant information necessary to enable the Service to access that Third-Party Service and your data contained within that Third-Party Service. However, please remember that the Third-Party Services may use, store and disclose your personal information differently, as described in their policies, and Elephant Foot Stamp shall have no liability or responsibility for the privacy practices or other actions of any Third-Party Service.
INFORMATION USE
Elephant Foot Stamp uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to the Elephant Foot Stamp Services, we will use your Personal Data to provide you with access to such services and to monitor your use of such services. Elephant Foot Stamp and its subsidiaries and affiliates (the “Related Companies”) may also use your Personal Data and other personally non- identifiable information collected through the Services to help us improve the content and functionality of the Services, to better understand our users, and to improve the Elephant Foot Stamp Services. Elephant Foot Stamp and its Related Companies may use this information to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each communication we send you will contain instructions permitting you to “opt-out” of receiving future communications. Elephant Foot Stamp and its Related Companies may also use the Personal Data we collect from and about you for our business purposes, such as data analysis, audits, developing new products and services, enhancing our Sites improving our services, personalizing your experiences, identifying usage trends and determining the effectiveness of our promotional campaigns. In addition, if at any time you wish not to receive any future communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.
If Elephant Foot Stamp intends on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.
Email Newsletters and Push Notifications:
Where permitted by applicable law, we may contact you and/or send to you commercial communications via electronic communications, such as email, to inform about our products, services, offers, or any commercial content related to the company. If you do not want to receive marketing emails from us, you can always opt-out by following the unsubscribe instructions provided in such emails. Please note that even if you opt-out from receiving commercial communications, you may still receive administrative communications from Elephant Foot Stamp, such as transaction confirmations, notifications about your account activities (e.g. account confirmations, password changes, etc.), and any other important announcements. We may also send you push notifications if you have opted-in to receive them. You can disable push notifications in your mobile device’s settings.
INFORMATION DISCLOSURE
Elephant Foot Stamp is not in the business of selling your personal information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your information for a business or commercial purpose with certain service providers or partners, or where you may share your information with third parties, as set forth below:
§ Rewards Providers: To the extent you have obtained or redeemed a reward offered by a merchant (“Rewards Provider”), added a Rewards Provider as a membership to your account or otherwise participated in any other activity sponsored or offered through the Service on behalf of the Rewards Provider, we may provide such Rewards Providers with your Personal Data (a) in order for the Rewards Provider to redeem and validate your reward, send you customized offers, troubleshoot redemption, combat fraud and otherwise communicate with you, (b) as part of legal proceedings affecting Company and the Rewards Provider, or (c) to facilitate a direct relationship between the Rewards Provider and you.
Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets. We may sell, transfer and/or share Personal Data with third parties in connection with a merger, reorganization, joint venture, assignment, spin-off, transfer or sale or disposition of all or any portion of our business, and in the event of bankruptcy.
§ Related Companies: We may also share your Personal Data with our Related Companies for purposes consistent with this Privacy Policy.
§ Agents, Consultants and Related Third Parties: Elephant Foot Stamp, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include maintaining databases, sending emails and SMS messages, offering and developing certain features of the Services, and maintenance and security. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function. We also disclose automatically collected data (card scans, promotional activities, and redemption information) to our Rewards Provider, third-party ad servers and advertisers. These third parties may match this data with information that they have previously collected about you under their own privacy policies, which you should consult on a regular basis.
§ Your Public Profile: If you make any information available through your public profile, it will be made available to members of the Company community. Please note that your first name and last initial and photo are, by default, available on your public profile. Your phone number, email address, and birthday are private and will never be displayed publicly as part of any profile.
§ Legal Requirements: Elephant Foot Stamp may disclose your information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation or assist government enforcement agencies, (ii) protect and defend the rights or property of Elephant Foot Stamp, Rewards Providers, or our users, (iii) act in urgent circumstances to protect the personal safety of users of the Service or the public, (iv) protect against legal liability; (v) protect Rewards Providers from fraudulent, abusive, or unlawful uses; or (vi) protect the security or integrity of the Service.
Non-Identifiable or Aggregated Data: When you interact with Company through the Services, we also receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Company may store such information itself or such information may be included in databases owned and maintained by Company affiliates, agents or service providers. We may use such information and pool it with other information to track, for example, the total number of visitors or users of the Services, the number of visitors to each page of our website, the domain names of our visitors’ Internet service providers, and how our users use and interact with the Service. Also, in an ongoing effort to better understand and serve the users of the Services, Company may conduct research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis. Company may share this non- identifiable and aggregate data with its affiliates, agents and business partners, as well as for use by or resale to others, but this type of non-identifiable and aggregate information does not identify you personally. Company may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
YOUR CHOICES AND OPT-OUTS
We do not share Personal Data with other third-party organizations for their marketing or promotional uses without your consent except as part of a specific program or feature for which you will have the ability to opt-out. We may offer contests that require you to take an action in order to receive a reward. This data is provided to the advertiser and you will always have the option to not participate.
The Services will automatically send you SMS messages with updates and other information as part of the Services. You may stop receiving SMS messages from the Services generally by replying STOP in response to any received SMS from the program. You may also opt-out of receiving SMS messages on the Company website. If you opt-out of receiving SMS messages, you may not be able to use certain Services.
YOUR CALIFORNIA PRIVACY RIGHTS
If you are a California resident, you have the right to ask to make an access and deletion request. Elephant Foot Stamp will not discriminate against you for exercising these rights, but we may offer financial incentives to those who opt in to our collection of personal information.
§ Access Request. You may make up to two requests per year for information as to:
§ The categories of personal information that we’ve collected about you, or shared with a service provider or partner for a business or commercial purpose;
§ The sources from which we collected such information;
§ The business or commercial purpose for collecting that personal information.
§ The specific pieces of personal information we’ve collected about you.
§ Deletion Request. You may request that we delete the Personal Information that we’ve collected from or about you. If we cannot delete all of your information, we will let you know the reason why, such as if we need to continue to provide you with rewards, or for an internal business or legal reason.
We will respond to your request within 45 days unless we need additional time, in which case we will let you know. Please see the “Access to Information/Contacting Us” section of this Privacy Policy for instructions on how to make one of these requests.
Further to the “Information Disclosure” section, over the last 12 months, Elephant Foot Stamp has collected and shared for a business or commercial purpose the following categories of personal information:
§ Identifiers/Contact Information: These include your name, postal and email address, phone number, and unique identifiers that may identify your device or browser but not you by name.
§ Commercial/Transactional Information: Your transaction and usage history, and which Rewards Providers you visit.
§ Internet/Electronic Activity: Your geolocation information, IP address, web/app browsing and search history related to our Services, and information regarding your interaction(s) with the Services or our advertising.
EXCLUSIONS
This Privacy Policy does not apply to any Personal Data collected by Company other than Personal Data collected through the Services. This Privacy Policy shall not apply to any unsolicited information you provide to Company through the Services or any other means. This includes, but is not limited to, information posted to any public areas of the Services, such as public forums (collectively, “Public Areas”), any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Company shall be free to reproduce, use, disclose, distribute and exploit such Unsolicited Information without limitation or attribution.
§ Children: Elephant Foot Stamp does not direct the Service to, nor does it not knowingly collect personal information from children under the age of 13 If we learn that a child under the age of 13 has provided personally identifiable information to Elephant Foot Stamp through the Service, we will endeavor to delete that information from our databases.
§ Links to Other Websites: This Privacy Policy applies only to the Services. The Services may contain links to other web sites not operated or controlled by Company (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that Company endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.
SECURITY
Company takes reasonable steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet, email, mobile or other electronic transmission is ever fully secure or error free, so you should take special care in deciding what information you send to us in this way.
CHANGES TO THIS PRIVACY POLICY
The Services and our business may change from time to time. As a result, at times it may be necessary for Company to make changes to this Privacy Policy. Company reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.
ACCESS TO INFORMATION; CONTACTING US
To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously
submitted via the Services.
Please also feel free to contact us if you have any questions about Company’s Privacy Policy or the information practices of the Services.
You may contact us at info@elephantfoot.com.