Privacy Policy

Effective Date: April 15, 2024

This website is owned and operated by Coupon Hulk, Inc. (“Website”). The Website provides content, resources, and corporate information to enhance your experience with Coupon Hulk, Inc. and its affiliated products and services. We value your privacy and are committed to protecting the personal information you provide to us.

This Privacy Policy (or “policy”) describes how this Website uses the personal information you provide and the rights you have. We have created a Privacy Portal at www.couponhulk.com/privacy to help you exercise your rights.

1. Privacy Policy Overview

Coupon Hulk, Inc. owns and operates this Website, and this policy covers information collected only through this Website. You can review the privacy policies for our individual products and services on their respective websites and applications (for example, the Coupon Hulk Shopping Privacy Policy governs data collected through our coupon and deal services).

The purpose of this policy is to notify users of this Website’s policies and practices with respect to their data. By using the services provided, you have agreed to the Terms of Use (“ToU”); and this policy is incorporated as a part of the ToU.

2. Information We Collect, Receive, and Create About You

We may collect or obtain information about you when you sign up, when you create profiles, pages, or contributions, when you use and interact with our services, and when you make your personal information public. In some cases, we may also receive information about you from third parties.

Data you provide when you sign up: This includes, for example, your username, password, subscription information, and basic information about any other accounts you choose to associate with your registration, such as your Apple, Facebook, or Google account.

Data we collect through your use of our services: We make and keep records when we provide you support or assistance on our services. We may also collect information about how you interact with our Website and its various features, as well as third-party content you see on our sites. We also collect data on how you interact with the advertisements displayed on the Website.

Data we receive from third parties: In some cases, we may receive information about you from third parties, for example, social networking sites, analytics providers, or business partners. Please note that this policy does not cover the practices of third parties, including those that may disclose information to us.

3. Data Processing and Retention

We process your personal information in order to provide you the best experience of our services. We may also process your information where the processing is necessary for the establishment, exercise, or defense of legal rights.

Below is a chart stating which categories of your personal information we process, for which purposes specifically, and how long we retain that data. Our processing of your data is subject to your use of our service, your privacy preferences, and your account settings choices.

Personal Information

We may process the following categories of personal information about you:

Category of Personal Information	Purpose of Processing	Legal Basis	Retention Period
Account Information (Personal Details): Name, postal address, telephone/mobile number, email address, employer, login credentials (username and password), interests, public social media handles or profiles, and photographs.	To provide use of our services as agreed in the Terms of Use.	Legitimate Interest	Life of the account and a reasonable and legally compliant time thereafter.
App Data: Information collected through our applications and tools, including third-party apps hosted on external platforms.	Maintain and improve service standards.	Legitimate Interest	Life of the account and a reasonable and legally compliant time thereafter.
Consent Records: Records of any consents you may have given, together with the date and time, means of consent, and any related information (e.g., the subject matter of the consent).	Comply with applicable laws and regulations and honor users’ choices.	Legal Requirement	Life of the account and a reasonable and legally compliant time thereafter.
Customer Records: Electronic customer records containing personal information such as name, signature, address, telephone number, or financial information. Also includes data from customer support communications. NOTE: Please do not submit sensitive personal data in support requests.	Maintain service standards and provide users with efficient and effective customer communication.	Legitimate Interest	In accordance with applicable laws.
Demographic Information: Gender, age/date of birth, nationality, salutation, job title, company information, education, work experience, other professional information, and language preferences.	Enable customer expression, maintain and improve service standards, and marketing.	Legitimate Interest	Life of the account and a reasonable and legally compliant time thereafter.
Location Information: IP address (from which we derive imprecise location such as city or zip code level). Also includes location information you provide during sign-up or in your profile.	Maintain service standards, provide relevant content and marketing.	Legitimate Interest	Life of the account and a reasonable and legally compliant time thereafter.

 

4. Sensitive Personal Information

We do not seek to collect or process sensitive personal information, such as race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, or sex life. Where users choose to disclose sensitive personal information within profiles, contributions, or other free-text fields available through this Website, we do not use the sensitive information for any additional purpose without consent, unless required to comply with laws or prevent crimes.

5. Direct Marketing

We may use the contact details you provided to reach out to you with information regarding services that may be of interest to you, for example, upcoming promotions, corporate news, product updates, and event invitations. You may unsubscribe from marketing communications at any time at no cost by following the unsubscribe instructions in any marketing email, or by contacting us at support@couponhulk.com. You may also opt out of SMS messages at any time at no cost.

6. Information We Share with Third Parties

Coupon Hulk Companies

This Website is operated by Coupon Hulk, Inc.. We share your information with other businesses owned by or affiliated with Coupon Hulk, Inc. (“Coupon Hulk Companies”) to assist us in the operation of our services, improve them, and further develop them.

We may also share information with other Coupon Hulk Companies for the purposes of targeted advertising. If you would like to opt out of the sale or sharing of your data with other Coupon Hulk Companies, you can do so via our Privacy Portal at www.couponhulk.com/privacy.

Other Third Parties

We may also share your personal information with the following:

• Relevant third-party providers where our services use third-party advertising, plugins, or content, subject to your privacy choices and settings, and our Terms of Use.
• Merchants, business partners, or advertisers where you have consented and chosen to participate in offers, contests, or other activities.
• Third-party processors (such as analytics providers, data centers, etc.), located anywhere in the world, subject to applicable requirements and limitations.
• Legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation.
• Any party as directed by a law enforcement agency or court, to the extent necessary for the establishment, exercise, or defense of legal rights.
• Law enforcement agencies for the purposes of prevention, detection, or investigation of criminal offenses and any legal proceedings associated with them.
• In the case of a full or partial acquisition, merger, reorganization, or sale of assets, relevant third parties as part of such transaction.

7. International Transfers of Information

We may transfer your personal information to recipients in other countries. Coupon Hulk participates in the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF), and the APEC Cross Border Privacy Rules System. Where we transfer user information from the European Economic Area (“EEA”) to a recipient outside the EEA that is not in an adequate jurisdiction, we do so on the basis of standard contractual clauses.

Because of the international nature of our business, we may need to transfer your information within the Coupon Hulk group of companies, and to third parties as noted in Section 6 above, in connection with the purposes set out in this Policy. For this reason, we may transfer your information to other countries that may have different laws and data protection compliance requirements. We remain liable under the DPF Principles if any third parties that we transfer your personal information to process it in a manner inconsistent with the DPF Principles, unless we prove that we are not responsible for the event giving rise to the damage.

Coupon Hulk and its associated affiliates and subsidiaries comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Coupon Hulk has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Coupon Hulk has also certified that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov.

We are committed to staying current with developments related to the Data Privacy Framework and may update our transfer mechanisms and safeguards as necessary to remain compliant. Any updates will be reflected in this Privacy Policy.

If you are a European individual with a privacy-related complaint, concern, or question about Coupon Hulk’s privacy practices, please contact us through our Privacy Portal at www.couponhulk.com/privacy. Under certain conditions, more fully described on the Data Privacy Framework website, European individuals may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Where we transfer your personal information from the EEA to recipients located outside the EEA who are not in a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for personal information, we do so on the basis of standard contractual clauses. You may request a copy of the relevant standard contractual clauses using our Privacy Portal. Please note that when you transfer any personal information directly to a Coupon Hulk entity established outside the EEA, we are not responsible for that transfer of your personal information. We will nevertheless process your personal information, from the point at which we receive the data, in accordance with the provisions of this Privacy Policy.

Enforcement Authority

The Federal Trade Commission has jurisdiction over Coupon Hulk’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF).

Complaints Mechanism

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Coupon Hulk commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact Coupon Hulk at privacy@couponhulk.com.

In compliance with the DPF frameworks, Coupon Hulk commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to TRUSTe (or an equivalent alternative dispute resolution provider). The services of the dispute resolution provider are provided at no cost to you. For further information, please visit https://trustarc.com/dispute-resolution/.

Under certain conditions, a binding arbitration option may be available to you in order to address complaints not resolved by any other means. For further information, please see Annex I of the EU-U.S. Data Privacy Framework Principles at: https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction.

In compliance with the DPF frameworks, Coupon Hulk commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the DPF in the context of the employment relationship.

Our privacy practices described in this Policy comply with the Asia-Pacific Economic Cooperation (“APEC”) Cross Border Privacy Rules System. To learn more about this program, please visit https://cbprs.org/.

8. Data Security and Breach Handling

We implement appropriate technical and organizational security measures to protect your personal information against unlawful destruction, loss, alteration, misuse, or unauthorized access while in our possession. These measures include, but are not limited to, encryption of data in transit and at rest, access controls, regular security audits, and employee training on data protection practices.

All parties we contract with must agree to provide reasonable data security measures for the customer information we share with them, in compliance with applicable laws and regulations.

If we learn of a security breach that affects our users, we may send an email or other direct communication to you, or post a notice on our Website to notify affected users. If you have any reason to believe that your data with us has been compromised (for example, there has been unauthorized access to your account), please contact us immediately at privacy@couponhulk.com.

9. Data Retention

We will retain your personal information for as long as is necessary in connection with the purposes set out in this policy, and in accordance with applicable laws. For more details on how long specific categories of data are retained, please see the table in Section 3.

When your personal information is no longer necessary for the purposes for which it was collected, we will securely delete or anonymize it in accordance with our data retention policies and applicable legal requirements.

10. Your Rights with Respect to Your Personal Information

Many privacy regulations afford consumers a number of specific rights. If you are a resident of the EU (under GDPR), UK (under the UK GDPR), Brazil (under the LGPD), several U.S. states including California (CCPA/CPRA), Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), or another jurisdiction with similar privacy requirements, you have certain rights which may include those listed below.

Your Rights

• Right to Withdraw Consent: Where you are requested to consent to the processing of your personal information, you have the right to withdraw your consent at any time.
• Right to Know/Access: You have a right to know what personal information we collect, process, and share or sell. This policy is meant to provide transparency with regard to your data. If you have additional questions, you can email us at privacy@couponhulk.com.
• Right to Delete/Erase: You can request that we delete all the information we have collected about you. Please note that by exercising your right to deletion, you may lose access to your account and any features associated with it. If you wish to cancel your account or request that we no longer use some or all of your information to provide you services, contact us at privacy@couponhulk.com.
• Right to Request Rectification: If you find that any of your information that we are processing is inaccurate, you can contact us to have your information corrected. We may retain and use copies of your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
• (California) Right to Opt-Out of the Sale or Sharing for Targeted Ads: Under some circumstances we may sell or share the personal data you provide to us to deliver ads that align with your interests. You can opt out via our Privacy Portal at www.couponhulk.com/privacy or by emailing privacy@couponhulk.com.
• (California) “Shine the Light” Request: In accordance with the California Online Privacy Protection Act, California residents may request information about personal information disclosed to third parties for direct marketing purposes. Please submit your request in writing to privacy@couponhulk.com.
• Right to Object to Processing: You can object to our processing of your personal information via our Privacy Portal under certain circumstances. By objecting to processing, you may not be able to access some or all of our services. This right is limited to personal data processed for commercial purposes.
• Right to Object to the Use of Sensitive Personal Information: You have the right to object to our use of your sensitive personal information, such as information about your health, race, religion, sexual orientation, gender identity, political opinions, or philosophical beliefs. You should always be mindful about the personal information you share online, especially when it is sensitive in nature.
• Right to Object to Automated Processing: You have a right to object to the processing of your data for the purposes of automated decision-making about you.
• Right to Not Be Discriminated Against: You have a right to not be discriminated against for exercising your privacy rights.
• Right to Complain (EU, UK, Switzerland): You have the right to lodge a complaint with your local data protection authority without prejudice to any other rights you may have.
• Right to an Authorized Agent (California): You may make a request on behalf of a California consumer by providing (1) a signed, written permission from the consumer and verification of the consumer’s identity directly with us; or (2) proof of power of attorney pursuant to Probate Code sections 4000 to 4465. We may deny a request from an agent that does not submit proof of authorization.

To make privacy requests, please visit our Privacy Portal at www.couponhulk.com/privacy and fill out the form. You can also email us at privacy@couponhulk.com. You may be required to verify your identity before we can give effect to these rights. If you are making a request on behalf of a user, we require a signed authorization letter from the consumer.

11. How to Change Your Preferences

You can change your preferences at any time. Below are some of the actions you can take:

Changing Your Own Information: Keeping your personal information current helps ensure that we provide you with the best possible experience. You can log into the Website and visit the “Profile” or “Account Settings” page to update or delete the information you provided. We may retain and use copies of your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Newsletter and Email Subscriptions: You can opt out or unsubscribe from any newsletter or email list at any time by following the instructions at the end of the emails you receive. Please allow five to ten business days for changes to take effect. On some services, certain service-related communications are an integral part of the service and you may continue to receive such emails unless you cancel your account. If you have provided more than one email address, you may need to unsubscribe each email address separately.

Location-Based Services: You may opt out of having your precise location data collected at any time by editing the appropriate setting on your mobile device (usually located in the Settings area of your device).

12. Contact Details

You can submit privacy-related inquiries through our Privacy Portal at www.couponhulk.com/privacy.

For any additional questions, you can contact us by emailing privacy@couponhulk.com or at the following address:

Coupon Hulk

Attention: Legal Department

[Your Business Address]

[City, State, ZIP Code]

 

If you have any questions or concerns about our privacy practices, we encourage you to contact our Data Protection Officer (DPO) at dpo@couponhulk.com or at the following address:

Coupon Hulk

Attention: Data Protection Officer

[DPO Address]

 

13. Children

Our services are not intended for use by children, especially those under 16. We do not knowingly collect personally identifiable information from children under the age of 16. We reserve the right to remove a user’s account at any time if we discover that a user is under the required age limit for the service.

If you have reason to believe we have collected personal information from someone under 16, please report it to us at privacy@couponhulk.com so we can take appropriate steps to rectify this.

14. California Consumer Rights Metrics

Pursuant to California privacy regulations, Coupon Hulk’s consumer rights metrics, including the number of requests received, complied with, and denied, are published annually on our Regulatory Information page at www.couponhulk.com/regulatory-info.

15. TCF Compliance Attestation

Coupon Hulk, Inc. is deeply committed to data protection, transparency, and ethical data handling practices. By adhering to the guidelines of the IAB Europe Transparency and Consent Framework (TCF), we ensure that our digital advertisements meet the highest standards of data protection and respect for users’ rights. We affirm our dedication to promoting transparency and empowering users to make informed choices about their online advertising experiences.

Our commitment to the IAB Transparency and Consent Framework includes but is not limited to:

• Transparency: We openly communicate with users about the purposes of data collection and use, as detailed in this Privacy Policy and the privacy policies of our subsidiaries and affiliates as applicable.
• Data Collection Minimization and Purpose Limitation: We only collect necessary data and process it for as long as needed, always respecting purpose specificity. Our data collection is exclusively for measuring the performance of advertisements and content recommendations, and for enhancing user experience. Based on consent, we place a single cookie in the browser, which helps in identifying users, avoiding repetitions, and reinforcing relevance in advertising and content recommendations.
• Data Accuracy and Accountability: We ensure the accuracy and protection of data, safeguarding against unauthorized access, loss, or misuse. We maintain clear records of data processing activities and regularly review our data handling practices for compliance.
• External Data Partners: We encourage our third-party partners to follow the high-level data protection standards we adhere to. We contractually require our partners to comply with applicable data protection regulations.
• Legal Compliance: We fully comply with relevant data protection and advertising laws and regulations, including but not limited to GDPR, CCPA/CPRA, ePrivacy Directive, and applicable national implementations.
• Continuous Training and Awareness: We continuously inform our employees, partners, and stakeholders about the importance of data protection and ethical data handling practices through regular training programs and policy updates.

By adopting the TCF framework, our goal is to establish a trustworthy and user-centric advertising environment, always keeping ourselves updated with the developments in data protection and transparency.

16. How This Privacy Policy May Change

This policy may be amended or updated from time to time at our discretion. Any updates will be effective at the time of publication on our Website, unless specified otherwise. Your continued use of our services after the publication of a policy update constitutes your consent to the changes.

We will notify you prior to making policy updates that materially change the way we treat your personal data, and will not use your data in a materially different manner without your consent. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting your information.