Effective Date: September 22, 2016
1. Your Agreement to this Policy
2. Intended Users of our Mobile App and Website
3. What kind of information do we collect and store?
(a) Your Personal Information
Personal Information includes the following categories of information:
- Contact Data, including your name, email address, physical address, home and/or mobile phone numbers, other information that could be used to contact you or identify you personally, and your password used to create an account on the Chinook Book app;
- Credit card information; and
- Other information you actively enter into the app and/or our websites, or otherwise provide to us through offline contacts, such as email, letter, or phone call.
(b) Automatically-Collected Information we receive from your use of our Chinook Book app and/or our websites
- Your mobile device and network identifiers, such as MAC or IP addresses;
- Your mobile device's unique device ID;
- Geo-Location Data: Our app doesn't work without geo-location data. We use both precise geo-location data and very non-precise general market location (i.e. a major metropolitan area, like Portland) in different ways to provide an optimal app experience while respecting your privacy.
- We record your general location whenever you use the app.
- We use your precise geo-location every time you use the app to identify the market you are in and display merchants near you.
- We only record your precise geo-location at these limited times:
- when you set up an account
- When you redeem a coupon
- When you go into offline mode.
- There is an optional setting in the app that will send you a push notification when you are near a merchant you have designated as a Favorite. For this service to work we use your precise geo-location in the background at all times and send you a push notification when our system has determined you are likely nearby a Favorite merchant. When you have this setting enabled we will also record your precise location when you enter, stay in and exit the geofence around a Favorite merchant.
We collect and aggregate this geo-location data to provide only the de-identified and aggregated coupon redemption data to merchants for their analysis so they can, for example, determine how often a coupon is redeemed at a given store location. We do NOT provide your specific geo-location data nor your identity to any third party; rather, we only provide the aggregated redemption data to our merchants.
The following data is de-identified and aggregated to provide data for both internal analysis and reporting to our merchants:
- Your coupon history, including purchases, unlocks, redemptions, favorites, and savings;
- Domain server;
- Type of mobile device accessing the app;
- Type of operating system your mobile device uses;
- Date and time you access the app and date and time you use the app to redeem specific coupons;
- Amount of time you spend on each app feature;
- Order in which you view the app features and pages, and the order in which you take actions in the app; and
- Other similar information about the interaction between your browser and the app.
We automatically collect and store the following types of information when you use chinookbook.com and our other websites:
- Your MAC addresses or IP addresses, including the optional disclosure of your location for use in seeing nearby merchants.
- Domain server;
- Type of computer and web browser used to access our websites;
- Type of operating system your computer uses;
- Date and time you access our websites;
- Referring source, i.e., the website you used to access our websites;
- Amount of time you spend on each page of our websites and the features you use;
- Order in which you view the features and pages on our websites, and the order in which you take actions on them; and
- Other similar information about the interaction between your browser and our websites.
(c) Information we do NOT collect: When you use our Chinook Book app or our websites, we do NOT (i) track your activity across multiple applications or websites, and we do not allow targeted advertising based on your activity across multiple applications or websites; (ii) access or store your contacts, call logs, calendar appointments, text messages, photos, videos, or other information stored on your mobile device; (iii) access or store your usernames or passwords (other than that which you use to set up your account through the Chinook Book app), such as username and passwords for your Facebook, Twitter, or other social network or email accounts; (iv) share your information with social networks, advertising networks, or other third parties for their own marketing or other independent purposes. In order to provide the services offered through the app, however, the app may interact with some features of your mobile device, such as your email account, but all of this processing occurs on your mobile device itself, and this information is not transferred through the app to us.
4. Cookies and Web Beacons
We collect Automatically-Collected Information through commonly-used information gathering tools, such as cookies and web beacons.
(b) Web Beacons: We may also use "web beacons" to collect Automatically-Collected Information about your use of the Chinook Book app and/or our websites, and your viewing and use of emails we send to you. Web beacons are graphic image files imbedded in a web page, app feature, or email that provide a presence on such web page, feature, or email and send back to its home server information from the user's browser. The information collected by web beacons allows us to statistically monitor how many people are using the app and our websites and opening our emails, and for what purposes. For example, we might place a web beacon in a marketing email to notify us when a user clicks on the link in the email. We do not collect Personal Information with web beacons.
5. How We Use Your Information
(a) Personal Information and Automatically-Collected Information
When you supply us with your Personal Information, we will use it for the express purpose stated when we ask for such Personal Information (e.g., we use your Personal Information to fulfill any transaction you initiate, such as the purchase of a Chinook Book), to respond to any requests you may have about use of the Chinook Book app or our websites, to contact you regarding your account or your use of the app or our websites, and to provide required notices.
Credit card information: We use your credit card information to fulfill purchase orders you initiate. We provide data encryption during the entire payment process. We will only use your credit card information to charge you for a Chinook Book or Full Access subscription if specifically ordered by you.
If you use the Chinook Book app to order a Full Access Subscription, we use a third-party intermediary to manage credit card payment processing. We only share your credit card information with this third-party intermediary, your credit card provider, and our banking partners, to process payments. We provide an auto-renew feature that will automatically renew your Full Access Subscription. We will provide a notice at least one week prior to the auto-renew occurring to remind you that you are about to be charged and what the amount charged will be. If this feature is enabled, our third-party intermediary will store your credit card information, but this third-party can only use your credit card information to process payments for your purchase of a Full Access Subscription. Because we collect credit card information (and because it's generally a good idea), we recommend that you lock your mobile device. If you lose your mobile device or if it is stolen, we recommend that you immediately contact your mobile device carrier to have the device and the Chinook Book app disabled. We shall have no responsibility or liability to pay for any unauthorized or fraudulent transactions.
IP Addresses: We use IP/MAC addresses to track and aggregate Automatically-Collected Information. We also collect IP/MAC addresses and mobile device IDs from our app users when they log into their accounts in order to confirm the applicable user's identity.
Your coupon history, including purchases, unlocks, redemptions, favorites and savings: For app users, we store coupon history information on our server so the app can be deleted from your device without losing coupons, favorites, or savings. This allows coupon account information to be transferred to new devices, such as a replacement or upgraded device.
Other Uses of Your Personal Information and Automatically-Collected Information: We may use your Personal Information and Automatically-Collected Information to customize and tailor your experience using the app and/or our websites, displaying content we think you might be interested in and according to your preferences (but we do not track your activity across multiple websites or mobile applications for the purposes of serving targeted advertising to you).
We may use Personal Information and Automatically-Collected Information to help diagnose problems with the app and our websites , to make the app and our websites more compatible with the technology used by our users, to analyze statistical use patterns, and to otherwise improve our app and our websites. For example, we may use Automatically-Collected Information to track what our users look at most so we can recognize and provide more of the desired features.
(b) Marketing Communications: We may use your Contact Data to provide you information about other products or services that may be of interest to you (including those we may offer jointly with other companies). We may also send your mobile device notifications from time to time to alert you to new coupons, expiring coupons, nearby coupons, Full Access subscription sales, or new available versions of the app. We will never share your Contact Data with any third party for their own marketing or other independent uses. If we use your Contact Data to send marketing communications to you, we will provide you with an easy mechanism to opt-out of receiving future marketing communications (see Section 7(a) below for more information). If you request that we not contact you for marketing purposes (either by using the opt-out mechanism or contacting us), we reserve the right to contact you for non-marketing purposes relating to your account or other use of the app or our websites. We respect your privacy and your right to limit the ways in which we contact you.
6. Sharing Your Information
(a) Merchants: From time to time, we share de-identified and aggregated coupon redemption data (including the date, time, and location of redemptions) and favorite coupon data with our merchants to help them improve their offers. We share this aggregated, anonymous redemption information with merchants to help them track redemptions. Celilo will never give merchants Contact Data, specific device information, network identifiers, or information that personally identifies you.
(b) Third-Party Service Providers: We share Personal Information and Automatically-Collected Information with our third-party service providers who assist us by performing services related to our operation of the Chinook Book app or our websites (such as hosting, data storage, transaction processing, and security). These third-party service providers are not authorized to use your information in any way other than as described here and are required to keep the information confidential.
(c) Third-Party Analytics Services: We may use third-party analytics services in connection with the Chinook Book app and our websites to assist us in better understanding our app and website users. For example, we use these services to track and analyze certain Automatically-Collected Information, such as feature usage. We only ever provide these service providers with (or allow these service providers to collect on our behalf) Automatically-Collected Information. The recordings will never identify you personally, though they can identify your IP/MAC addresses and mobile device IDs. We use the information collected from these service providers to find usability problems to make the app and our websites easier to use. The information we receive from these third parties may be re-associated with your Personal Information after we receive it back from these third parties. These third parties are not authorized to use your information in any other way and are required to keep the information confidential.
(e) Required by Law: Celilo reserves the right to and will release Personal Information and/or Automatically-Collected Information, without your consent and without additional notice to you, if Celilo believes in good faith that (i) such release is required to comply with any law, rule, or regulation, or any search warrant, subpoena, court order, or similar legal process; or (ii) disclosure is necessary to protect or enforce Celilo's rights or property, to protect the rights or property of others, to protect your safety or the safety of others, in emergency situations, to defend against legal claims, or to take action regarding illegal activities or suspected fraud.
7. Controlling Your Information; Opt-Out Rights
(a) How can I opt out of marketing communications?
Marketing emails from Celilo will always include an unsubscribe link at the bottom. To opt out of marketing email, please unsubscribe using this link. Or you may contact us via the contact information shown in Section 13 to unsubscribe. To opt out of device notifications, disable the push notification preference inside the Chinook Book app.
(b) Stop Future Collection of Information: You can stop all future collection of Personal Information and Automatically-Collected Information that is collected through your use of our websites by discontinuing use of the website (but see below regarding data retention of earlier-collected data). You can stop all future collection of Personal Information and Automatically-Collected Information that is collected through your use of the Chinook Book app by uninstalling the app (but see below regarding data retention of earlier-collected data). You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. Please note that we will not be notified if you uninstall the app or discontinue use of the website. If you want us to remove your Personal Information from our records, please see the paragraph below.
(c) Review and Modification of Information; Deleting Your Information: You can review or modify the Personal Information you have included in your Chinook Book app account or change your password by logging in and accessing your account, or by contacting us at email@example.com. Please note that your account and all features of the app may not function properly if we remove any or all of your Personal Information. If you want to close your app account and/or ask us to delete your information from our databases (whether such information was provided through the app or through our website), please contact us at firstname.lastname@example.org. But we will not be notified if you merely uninstall the app, and we will not know that you want us to remove your information from our databases. Upon receipt of your request, Celilo will use commercially-reasonable efforts to delete your account and remove your Personal Information from our databases; however, it may be impossible to remove residual Personal Information and Automatically-Collected Information, such as information tracked in our web server log files and information that may reside in backup files. This residual information is retained to preserve the integrity of backed-up files and for business continuity purposes. Further, we may retain Personal Information and Automatically-Collected Information to comply with our retention policy described in Section 8 below.
8. Retention and Storage
See Section 5(a) above regarding our retention of your credit card information that you provide to complete purchases you initiate through the Chinook Book app or chinookbook.net. We will retain all other Personal Information and Automatically-Collected Information in our databases until you contact us and ask that we remove your information from our databases. Please note that it may be impossible to remove some Personal Information and Automatically-Collected Information, such as information tracked in our web server log files and information that may reside in backup files. We may also retain Automatically-Collected Information even after you request that we remove your information from our databases, for use in the aggregate and to analyze and improve the app and our websites. Further, even after you request that we remove your information from our databases, we may retain Personal Information and Automatically-Collected Information in accordance with our document management and retention policy and to comply with applicable laws, rules, regulations, or guidelines; to prevent fraudulent activity; to protect ourselves against liability; to resolve disputes; to permit us to pursue available remedies and limit any damages that we may sustain.
10. Security of Information
We have generally-accepted industry standard physical, electronic, and procedural security measures in place to protect against the loss, misuse, alteration, or unauthorized access of Personal Information and Automatically-Collected Information we collect and store. These safeguards include secure login authentication for accounts on the Chinook Book app, encryption during transmission with the use of Secure Sockets Layer for processing transactions securely, firewalls, and other security measures. All Personal Information and Automatically-Collected Information is subject to restricted access to authorized employees and contractors who need to know the information in order to operate and improve our Chinook Book app and our websites.
Please promptly notify us if you become aware that your Personal Information is lost, stolen, or used without permission. If you notify us of such an event, we may disable access to your app account in order to prevent an unauthorized third party from accessing your account.
11. Legal Disclaimer
13. Contact Us
Address: Celilo Group Media, Inc., 208 SW First Ave., Suite 260, Portland, OR 97204
Please see Sections 7(c) and 8 above regarding our retention of your information, even after you request that we change or delete your information.
©2016 Celilo Group Media, Inc. All Rights Reserved.