We collect personal data on the Site when you attempt to become a Subscriber or otherwise choose to provide personal data to us. Personal data may include, but is not limited to: name, business entity name and/or your title with the applicable business entity, as well as your personal and/or business entity related e-mail address, mailing address, daytime and/or cellular telephone numbers, fax number, credit card and/or any other information requested on the applicable Subscriber registration form.
We may automatically collect and store in log files certain non-personal data about you when you visit many of the Site’s pages, such as the type of browser you are using (e.g., Chrome, Mozilla, or Internet Explorer), the type of operating system you are using, (e.g., Windows or Mac OS) and the domain name of your Internet service provider (e.g., AT&T, Comcast). We use the non-personal data that we collect to improve the design and content of the Site and to enable us to personalize your Internet experience. We also may use this data in the aggregate to analyze Site usage. We do not link this automatically collected data to other information we collect about you.
You can log in to our support section of the Site using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities on this Site to your profile page to share with others within your network.
We and our third party tracking utility partner collect data using tracking technologies such as Web beacons (which are commonly referred to in the industry as web bugs, pixel tags or Clear GIFs), cookies, scripts, and tags. We do not tie the information gathered by clear gifs to our customers’ personal data. Web beacons are electronic images that may be used on the Site, in our Services, or in our emails to deliver cookies, count visits and determine if an email has been opened and acted upon. These technologies are used in analyzing trends, administering the Site, tracking users’ movements around the Site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
We use Local Storage (HTML5), and our third party utility partner uses Local Shared Objects (Flash cookies) and Local Storage (HTML5) to store content information and preferences, and to display advertising based on your web browsing activity. Various browsers may offer their own management tools for removing HTML5. To manage Flash, please click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html
HasOffers collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes. We collect information for our clients, if you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the client that you interact with directly.
We use your personal data in the following ways: (a) to send you information regarding HasOffers and your Subscription to the Services; (b) to track your compliance with the HasOffers Services Agreement (“Services Agreement”); and/or (c) for validation, suppression, content improvement and feedback purposes. You agree that we may contact you at any time with updates and/or any other information that we may deem appropriate for you to receive in connection with your continued use of the Services and request for information regarding additional HasOffers products and/or services.
As a general rule, and other than in connection with the limited exceptions set forth below, HasOffers will not sell, share or rent your personal data to or with others.
Notwithstanding the foregoing, HasOffers may, from time to time, provide personal data to certain third-party administrative vendors for credit card processing, offering customer service, efficiency purposes in providing administrative or program management services in connection with your Subscription to the Services such as billing and delivery. Any third-party vendor so used has agreed to protect the confidentiality of information provided by HasOffers.
HasOffers may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our Clients.
We display personal testimonials of satisfied customers on our Site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at firstname.lastname@example.org.
Our Site offers publicly accessible community forums. You should be aware that any information you provide in this area may be read, collected, and used by others who access it. To request removal of your personal information from our community forum, contact us at email@example.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at firstname.lastname@example.org. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We endeavor to safeguard and protect our users’ data. When users submit personal data at the Site, their personal data is protected both online and offline. When our registration process asks users to submit Sensitive Data (such as bank account information and login credentials), and when we transmit such Sensitive Data, that Sensitive Data is encrypted and protected with SSL encryption software. While we use SSL encryption to protect Sensitive Data online, we protect all other user data online and offline We have security measures in place to protect the loss, misuse and alteration of personal data under our control. Please be advised that, although we take every reasonable precaution available to protect your data, no data transmission over the Internet can be guaranteed to be 100% secure. Therefore, we cannot warrant that your data will be absolutely secure. Any transmission of data at or through our Site is at your own risk. However, access to your personal data is strictly limited, and not accessible to the public. Only employees, and third party agents, that need the data to perform a specific job are granted access to personal data. Our employees are dedicated to ensuring the security and privacy of all user data. Employees not adhering to our written firm policies are subject to disciplinary action. In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an data security breach with respect to your personal data. You will be notified via e-mail 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. You acknowledge that you provide your personal data to HasOffers with knowledgeable consent and at your own risk.
If you would like to delete or update the personal information that we have collected from you, simply send your request via certified mail to: HasOffers, Inc., 2200 Western Avenue, Suite 200, Seattle, WA 98121. You may also send your request via e-mail to: email@example.com. We will respond to your access request within 30 days. We will process your request, where possible and subject to the terms and conditions contained herein, within a reasonable period of time after receipt. To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access or making corrections.
You may at any time choose to stop receiving emails containing general information regarding HasOffers and/or HasOffers by following the instructions at the end of each such email or by contacting us at firstname.lastname@example.org. There may be a short delay of up to several business days while your request is being verified, deployed and processed across our servers. Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your Subscription to the Services, as well as to respond to any inquiry or request made by you.
HasOffers has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his or her query to the HasOffers Client in question (the data controller). If the Client requests HasOffers to remove the data, we will respond to their request within 30 business days.
HasOffers complies with the U.S. – E.U. Safe Harbor framework and the U.S. – Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. HasOffers has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view HasOffers’ certification, please visit http://www.export.gov/safeharbor/.
October 2015 update: TUNE is awaiting additional regulatory guidance for compliance for EU to US data transfers, given the European Court of Justice’s recent decision on the Safe Harbor. In the meantime, we urge all clients to continue to obtain end user consent for data sharing with TUNE, and respect other privacy protections under EU law. You and TUNE are compliant during this period of uncertainty so long as you don’t upload or share personal data with TUNE products (e.g. email addresses that are not hashed or otherwise secured). See section 9.3 of the TUNE Master Services Agreement for more details (available at www.tune.com/msa).
2200 Western Ave., Suite 200
Seattle WA, 98121