Saltwater Privacy Policy

Saltwater Software, Inc. (together with its affiliates, "Saltwater," "we", “us” or "our") is a software company that hosts loyalty programs on behalf of local organizations and others, among other lines of business.

This “Privacy Policy” describes how we collect, use and share personal information in connection with our websites and services to which this Privacy Policy is posted (collectively, the “Services”). Except as expressly provided in this Privacy Policy, it does not apply to information you provide to us offline or through other means.

 

Personal Information We Collect

Information you provide to us. Personal information about you that we collect from you may include:

Data from other sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

Data collected automatically. We, our service providers and third party partners may automatically log information about you, your computer or mobile device, and your activity over time on the Services and other online services, such as:

 

How We Use Your Personal Information

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

Service delivery. We use your personal information to:

Research and development. We may use your personal information to administer surveys and other market research and for other research and development purposes, including to analyze and improve the Services and our business. As part of these activities, we may create anonymous data (including aggregated and/or de-identified data) from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Marketing. We may send you Saltwater-related and or other marketing communications via email and other channels as permitted by law. We also work with third party advertising partners who use cookies and similar technologies to help us advertise our services. These advertisements are delivered by our advertising partners and may be targeted based on your geographic area and activity on the Services and other online services. To learn more about your choices in connection with advertisements, please see the section below titled targeted online advertising.

 

How we use your transaction data

We collect transaction data from service providers, including the companies that match your credit card transactions to your Saltwater loyalty account, who provide us with transaction-level data regarding your purchases. Some data, including your credit card information, may be directly collected by our service providers on our Services. Our service providers use that information to verify relevant transactions as part of our loyalty program Services. For more information about the privacy policies of our service provider, Fidel LTD, please visit: https://fidel.uk/legal/privacy/

Notwithstanding anything to the contrary in the Terms or Privacy Policy, Company and its Service Providers (including Fidel) will use transaction information solely as follows:

You authorize the sharing, exchange and use of transaction data described above and herein by and among Company and Company’s Third Party Service Providers, applicable Payment Card Networks and applicable Merchants.

Compliance and operations. We may use your personal information to:

 

How We Share Your Personal Information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection:

Affiliates. Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers. Companies and individuals that provide services on our behalf or help us operate the Service or our business, such as customer service and support providers; technology providers (including technology support, web hosting providers, email and text communications providers, and mobile app developers); survey and market research providers; advertising and marketing partners; and analytics services providers.

Advertising partners. Third party advertising companies that collect information about your activity on the Services and other online services to help us advertise our services.

Professional advisors. Professional advisors, such as lawyers, auditors and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, central banks and private parties, as we believe necessary or appropriate for the compliance and operations purposes described above.

Business transferees. Relevant third parties in the event of a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business, assets, or equity interests in Saltwater or our affiliates (including, in connection with a bankruptcy or similar proceedings).

Please keep in mind that whenever you voluntarily make your personal information available for viewing by third parties on our Services, that information can be seen, collected and used by others besides us. We cannot be responsible for any unauthorized third-party use of such information.

 

Your Choices

Opt out of marketing emails. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email. You may continue to receive Service-related and other non-marketing emails. You may also change your email newsletter preferences via the “Newsletter” section of the site.

Text message alerts. We may offer text news alerts for your phone or wireless device via short message service ("SMS") or similar technology. You must register with us to receive this service, which may require providing us your name, telephone number, and other personal information. You can cancel or modify your alerts by accessing your account through the Services or by texting "STOP" to the number associated with the text news alert. Message and data rates may apply for this service.

Opt out of targeted online advertising. We use Google’s online advertising services. You can view Google’s privacy policy at https://policies.google.com/privacy and opt out-out of personalized ads from Google at https://adssettings.google.com.

Google and many of our other advertising service providers are members of the Network Advertising Initiative (NAI) and are subject to the Self-Regulatory Principles for Online Behavioral Advertising published by the Digital Advertising Alliance (DAA). You can obtain more information about these advertising service providers' information collection practices, and opt out of receiving targeted advertising from some participating NAI and DAA members, at http://www.networkadvertising.org/managing/opt_out.asp and/or the DAA's website at http://optout.aboutads.info. Mobile app users may opt out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available at https://www.youradchoices.com/appchoices, and selecting the user's choices. Please note that we also may work with companies that offer their own opt-out mechanisms and/or may not participate in the opt-out mechanisms described above.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Cookies. Most browsers let you remove and/or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, our Services may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit http://www.allaboutcookies.org.

Declining to provide information. We need to collect personal information to provide certain Services. If you do not provide the information requested, we may not be able to provide those Services.

 

Other Sites and Services

The Services may contain links to other websites and online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or other online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions.

We also make our third party partners’ content, products or services available through our Services, whereby our partners’ brands appear on the Services in connection with such content, products or services. We may share with our partners information you provide, or that is collected, in the course of visiting any pages that are made available in cooperation with our partner. In some cases, the partner may collect information from you directly, in which cases the privacy policy of our partner applies to the partner’s use of your information. The privacy policy of our partners may differ from ours. If you have any questions regarding the privacy policy of one of our partners, you should contact the partner directly for more information.

 

Security

The security of your personal information is important to us. We employ organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

 

International Data Transfers

Our Services are intended to be used only by residents of the United States.

We are headquartered in the United States, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective.

 

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail or another manner through the Service. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

 

How to Contact Us

Please direct any questions or comments to:
Saltwater Software
201 Wilshire Blvd, 2nd Floor, Santa Monica, CA 90401
info@saltwaterware.com

 

Important Information for California Residents

This section applies only to California residents. It describes how we collect, use and share Personal Information of California residents in operating our business, and their rights with respect to that Personal Information. For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA.

Your California privacy rights. As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted or required by law. For example, the CCPA prohibits us from providing certain sensitive Personal Information in response to an access request. If we deny your request, we will communicate our decision to you.

 

How to exercise your rights

You may exercise your California privacy rights described above as follows:

We will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

California residents may also empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority.

 

Personal information that we collect, use and share

The chart below summarizes how we collect, use and share Personal Information by reference to the categories specified in the CCPA, and describes our practices during the 12 months preceding the effective date of this Privacy Policy.

Categories in the chart refer to the categories described above in the general section of this Privacy Policy.

We have not sold your personal information in the preceding 12 months.

Category of personal information (PI) (click for details) PI we collect Source of PI Business/ commercial purpose for collection Categories of third parties to which we “disclose” PI for a business purpose Categories of third parties to whom we “sell” PI
Identifiers
  • Contact data
  • Identity data
  • Data about others
  • You
  • Public sources
  • Business partners
  • Service delivery
  • Research & development
  • Marketing
  • Compliance & Operations
  • Affiliates
  • Advertising partners
  • Professional advisors
  • Authorities and others
  • Business transferees
None
Commercial Information
  • Contact data
  • Identity data
  • Transaction data
  • Communications
  • Marketing data
  • You
  • Service delivery
  • Research & development
  • Compliance & Operations
  • Affiliates
  • Professional advisors
  • Authorities and others
  • Business transferees
None
Online Identifiers
  • Device data
  • Identity data
  • Automatic collection
  • Service delivery
  • Research & development
  • Marketing
  • Compliance & Operations
  • Affiliates
  • Professional advisors
  • Authorities and others
  • Business transferees
  • Advertising partners (to facilitate online advertising)
Internet or Network Information
  • Device data
  • Online activity data
  • Automatic collection
  • Service delivery
  • Research & development
  • Marketing
  • Compliance & Operations
  • Affiliates
  • Professional advisors
  • Authorities and others
  • Business transferees
  • Advertising partners (to facilitate online advertising)
Geolocation Data
  • Device data
  • Automatic collection
  • Service delivery
  • Research & development
  • Marketing
  • Compliance & Operations
  • Affiliates
  • Professional advisors
  • Authorities and others
  • Business transferees
None
Inferences May be derived from your:
  • Device data
  • Online activity data
       

We describe:

• the sources from which we collect this information in the section above entitled Personal Information We Collect; and • the business and commercial purposes for which we collect this information in the section above entitled How We Use Your Personal Information.

Please note that we may also disclose Personal Information to (a) comply with federal, state, or local laws; (b) comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (c) cooperate with law enforcement agencies concerning conduct or activity that we believe may violate federal, state, or local law, (d) when we sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction), or (e) to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us. These disclosures are not “sales” under the CCPA.

Glossary
Statutory category Definition (categories may overlap)
Commercial Information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Geolocation Data Precise location, e.g., derived from GPS coordinates or telemetry data
Identifiers Real name, alias, postal address, unique personal identifier, customer number, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
Inferences The derivation of information, data, assumptions, or conclusions from any other category of Personal Information to create a profile about a person reflecting the person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
Internet or Network Information Browsing history, search history, and information regarding a person’s interaction with an Internet website, application, or advertisement.
Online Identifiers An online identifier or other persistent identifier that can be used to recognize a person, family or device, over time and across different services, including but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, mobile ad identifiers, or similar technology; customer number, unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers (i.e., the identification of a person or a device to a degree of certainty of more probable than not) that can be used to identify a particular person or device.

 

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