When you sign up for your Account or use our Services (either on your mobile phone/device through the Application or though other devices), our servers may (i) automatically record information that your mobile phone/device sends or transmits, including your device type, your device ID number (for example, your UDID), user settings, your geographical location (if you consent to that) (for example, when you check-in or walk-in to a location) and information about your use of the Services such as offers viewed and/or used, stores visited, information you entered, (ii) record which search terms you used, or which referring/exit pages brought you to our page, and date/time information, (iii) record certain non-personally identifying information record information provided by you, such as your gender or date of birth, (iv) record, determine or use information about or from another content delivery platform, and (v) record information derived from such above information and other sources such as entries and offers viewed on our website or on our social media presence, or information provided by Affiliated Partners (collectively, “Non-Personally Identifiable Information”).
When you use our Services, we may ask that you provide us with some personally identifiable information—information about you that can be used to contact or identify you, and information on your use or potential use of the Services and related services (“Personal Information”). Personal Information that we might collect may include things like your name, mobile phone number, other phone numbers, email address, home address, and, if you elect to share this information with us Personal Information may also include other information you supply to us concerning your preferences and interests expressed in the course of using the Services.
We may also use additional methods to collect your Personal Information when you are physically visiting the store of one of our Affiliated Partners, such as when a device with your Application and user ID active scans product barcodes or checks in, or based on presence location data gleaned from a mobile device with your Proximate user ID active. If you do not wish to have your Personal Information collected by these methods, you may not be able to get notifications and earn or redeem rewards as part of the Services.
We may also receive Personal Information from Affiliated Partners provided by you in the course of your using their services, or from third parties (e.g., white pages listings providers), subject to the limitations of the Privacy Policies of those Affiliated Partners or third parties.
The terms “using” and “processing” information, as used in this policy, include using cookies or other storage means on a computer or mobile device, subjecting the information to statistical or other analysis and collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our subsidiaries within the United Arab Emirates or internationally.
We use Personal Information only for the following purposes: (i) to administer the Services, (ii) to provide, improve and optimize the Services, (iii) to personalize your experience, (iv) to provide you with software updates and/or product announcements, (v) to better understand users' needs and interests, and (vi) to provide you with further information and offers from us that we believe you may find useful or interesting, such as targeted advertising and promotional campaigns.
We may match data from your transactions with Affiliated Partners and/or the content information with our usage data in a personally identifiable form in order to perform accounting reconciliation and/or provide targeted offers and/or rewards or discounts to you; but to protect your privacy, our Affiliated Partners and Proximate will perform this matching in a protected environment that does not allow our Affiliated Partners to gain Personal Information you have not opted in to disclose to them, unless you choose to identify yourself at the Affiliated Partner’s store as a Proximate user to use an offer or redeem a reward (e.g., by telling the store’s cashier your cell phone number, or by using a loyalty account that has been linked to your Proximate account). By enabling an Affiliate Partner to identify you as a Proximate user, you are allowing them to identify and store that transaction as a Proximate-related transaction along with your Proximate identifier.
Information about our users generally, and thus, for example, to improve features and functionality of the Services and to make more relevant. We may use Non-Personally Identifiable Information for a few purposes. We may analyze trends through aggregated demographic and psychographic offers to users. We may also share this Non-Personally Identifiable Information with our Affiliated Partners to allow them to assist us in delivering tailored advertisements, promotions, sweepstakes, discounts, and other incentives to you when you use the Services. Any information shared with Affiliated Partners in this context will not contain nor be linked to your Personal Information unless you have given us your explicit consent through an “opt-in” mechanism on the Application. For example, an Affiliated Partner may want to offer a discount on its products to a certain audience (for example, men ages 18-34) or audience segment (for example, women ages 25-40 who have viewed certain content). If the Non-Personally Identifiable Information that we have collected about you meets this description, you would be able to view and use the discount offered by the Affiliated Partner.
If you have entered a store loyalty card number of a participating store or other affiliated partner who the Services are being sponsored by, or whose brand, product or service name(s) are included on the Services, or for whom the Services are provided in partnership with (“Affiliated Partner”), we may share Personal Information with that Affiliated Partner, including your loyalty card number (but as to data regarding your usage of Services, only the usage data that relates to that Affiliated Partner will be shared). In addition, we may request your permission to allow us to share your Personal Information with Affiliated Partners; you are not required to grant such permission in order to use the Services, but if you do consent, we may share Personal Information with one or more Affiliated Partners (as to data regarding your usage of Services, though, only the usage data that relates to a particular Affiliated Partner will be shared with that Affiliated Partner). In all other cases, we will only share data with Affiliated Partners in an aggregated (i.e., not personally identifiable) form for analysis and marketing purposes, with the goal to improve the Services further, or to permit the Affiliated Partner to analyze the effectiveness of its marketing efforts. If we share Personal Information with an Affiliated Partner, we will require in our agreement with that Affiliated Partner that this information not be shared outside the Affiliated Partner except to contractors or service providers for use solely to supply operational or analysis services to that Affiliated Partner, but we cannot ensure our Affiliated Partners’ compliance with these agreements.
We may use “cookies” (a cookie is a small data file that is kept in your device’s memory for record-keeping purposes), and/or other storage on your device to help us collect, maintain, and use this information, for two purposes. First, to make the interactions easier and more personalized for you, we may utilize persistent cookies to save information relating to your Account and/or activity for future interactions with the Services. Second, to better understand how you interact with the Services and to monitor aggregate usage by Proximate users and web traffic routing on the Services, we utilize session ID cookies to enable certain features of the Services. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Services and then close your browser. Third party advertisers on the Services may also place or read cookies on your browser. At any time, you can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Please understand that if you do not accept cookies, you may not be able to use all portions or all functionality of the Services.
We will not share your Personal Information with anyone else except to provide the Services, when we otherwise have your permission, or under the following circumstances:
As discussed above, we may share with third parties or the public (e.g., through white papers or press articles) aggregated information in a form that does not disclose your Personal Information, nor be reasonably likely to allow you to be personally identified, for industry analysis, demographic profiling and similar purposes. We share this aggregated information so that our partners also understand how interested our users are in their products and services, so that they may also provide you with an optimal online experience, and so that additional retail or brand partners can see the opportunity in Proximate and may also become partners and further enrich the Services and offers for our users.
We may employ or partner with third party companies and individuals to process your payments, facilitate our Services, to provide all or a portion of Services on our behalf, to perform Services-related services (e.g., without limitation, maintenance services, database management, web analytics, download provisioning and improvement of the Services' features) or to assist us in analyzing how our Services are used. These third parties may have access to your Personal Information but only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. In some instances, these third parties will be able to make use of Non-Personally Identifiable Information for other purposes.
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We reserve the right to track IP addresses for the purposes of fraud prevention, and to release IP addresses to legal authorities. We will disclose information about you to government or law enforcement officials or private parties when we believe reasonably necessary to comply with law, to protect the property and rights of Proximate or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity.
We may sell, transfer or otherwise share your Personal Information in connection with a merger, acquisition, reorganization or sale of our company (or our assets) or in the event of our bankruptcy; this is the only case in which we may sell Personal Information we collect from you or from your use of the Services.
You may review, update, correct or delete your Personal Information in your registration profile by contacting us or by making the appropriate modifications in your Account preferences. If you completely delete all such information, then your account may become deactivated. If you would like us to delete your Account and/or remove your records from our system, please contact us and we will delete your account within 45 days if we do not have any legal obligation to retain the record.
We employ administrative and electronic measures designed to safeguard and protect your information from unauthorized access and disclosure. In addition, we will delete information after it is no longer useful for providing the Services.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "personal data" (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on the Services in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
The Services are not directed to children. We do not knowingly collect personally identifiable information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, please contact us. If we become aware that a member is under the age of 13 and has provided us with Personal Information without verifiable parental consent, we will delete such information from our files.
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Last updated as of: (Month) X, XXXX.