Introduction & Purposes

This Privacy Notice (“Notice”) explains how Prize Logic LLC (“PrizeLogic”, “our”, “us”, “we”), a full-service promotions and loyalty agency, collects, uses and handles personally identifiable information that individuals (“users,” “you,” or “your”) share with us, with our clients and other information we collect during your participation in various activities we manage.

We are committed to protecting the privacy of your personally-identifiable information that you provide to us. This is your PII that (i) you choose to provide to us when you decide to engage in client promotions and marketing activities that we manage; (ii) we gather when you visit our website at www.prizelogicstg.wpengine.com or other websites we own or manage (the “Website”); (iii) we gather when you interact with PrizeLogic directly (e.g., our website, mailboxes, points of entry offline); or (iv) we possess and process.

If you have any questions about this Notice, please email us at privacy@prizelogic.com or call (855) 951-5262. Additional contact information is provided in the Contacting Us section below.

This Notice consists of the following main sections:

Information We Collect
How We Use the Information We Collect
Additional Services and Third-Parties
Security of PII
Special Note About Children
Client Privacy Notices and Opting-Out of Client use of PII
Opting Out of PrizeLogic Use of PII
Contacting Us
Third Party Links
International Users
California Residents Privacy Policy
Changes to this Notice

1. Information We Collect

A. Personally Identifiable Information (“PII”)
PrizeLogic, on behalf of our clients and for its own purposes, may collect PII. This information includes, but is not limited to: your name, date of birth, marital status, street address, e-mail address, credit card information, social security number, telephone number, and social media information. PII collected by PrizeLogic, on a client’s behalf, will be used by the client in accordance with that particular client’s privacy policy.

B. Personal information that is not PII.
PrizeLogic, on behalf of our clients and for its own purposes, may also collect or generate non-personally identifiable information about your use of PrizeLogic services or client promotions. This information includes, but is not limited to, browser type and version, operating system, referral source, length of visit, page views, demographics, interests, online habits, geographical location, analytical data, receipts, images, social posts, video, audio, information collected by website visitor tracking tools such as “cookies,” “web beacons,” “pixels,” Internet tags and other navigational data. More information about our online activity tracking tools is provided below.

C. Website Visitor Tracking Tools That We Use
“Cookies” are small pieces of information that are stored by your web browser on your computer’s hard drive or temporarily in your computer’s memory. The use of cookies is now an industry standard and you will find them on most major web sites.

PrizeLogic may place and store Internet cookies on your hard drive. The use of cookies provides benefits to you by saving your name, information supplied at registration, and other information that may make the use of our promotions easier. Although most web browsers are initially set up to accept cookies, if you prefer, you can decline the placement of a cookie on your hard drive by using the appropriate feature(s) of your web browser software (if available) to block or delete the cookie. Please note, however, that certain areas on a web site may not function properly if your web browser does not accept cookies. When you visit our Website, engage in one of our promotions or open an email you have received from us, we may place or recognize a unique cookie on your browser. These cookies, which do not contain PII, enable us to send you ads about our services, customize our services and gather insight analytics about our client’s customers and consumers.

Additionally, emails we send to you may contain a bit of code known as a “web beacon” or “pixel.” This code helps us understand the time and date that you opened an email and when you used a link within the email to visit a website, allowing us to collect analytics about our traffic, customize our services, and send you ads about our services. You can disable our web beacons by turning images “off” in your email client (e.g., Outlook, Outlook Express).

2. How we Use the Information We Collect

Generally, we may use your information that we collect for: (i) analytical purposes, including the creation of recognition databases; creation of common event data databases; development and use of benchmarking, indexing, and analytics; product development, testing, analytics, modeling and algorithm development (e.g., machine learning, artificial intelligence, and fraud mitigation); (ii) providing and fulfilling services ordered by our clients (including SMS and email messaging); (iii) internal and third-party fraud detection, data matching, validation and recognition use, including, for example, use of PII for recognition database, matching to external services and augmentation with third party information and (iv) the promotions entered by you. More information about how we use the information we collect is provided below.

A. To Operate Promotions and Personalize Your Experience
Our promotions may include features that personalize your experience. To that end, we use your PII and non-personally identifiable information to operate and benchmark the promotions, including, without limitation, to process transactions with you and validate the information you provided. We may also use your email domain to ensure your eligibility or your affiliation with a particular organization or industry or to personalize the content and experience you receive.

Where you use multiple promotion platforms (such as, website, mobile website, or mobile app), we may combine information about you and your activities to provide an integrated experience, such as to allow you to seamlessly engage from the various platforms we make available.

B. For Development and Improvement of our Promotions and Services
We continually strive to improve our promotions and services to make them more engaging, secure, rewarding, and useful to you and our clients. We use the information we collect to better understand how our users engage with our promotions, to troubleshoot and to identify areas for improvement.

C. To Communicate With You About The Services
We use your PII to send transactional communications to you by email, text messages, mobile app messaging, and other means to access a promotion. We also remind you of promotion deadlines, respond to your comments, questions and requests, provide customer support, and may send you notices, updates, and administrative messages using your PII. We also provide personalized communications based on your activity and interactions with a promotion. For example, certain actions you take in a promotion may automatically trigger communications related to the promotion engagement, such as loyalty points in your account. Transactional communications are part of the promotion and in most cases, you cannot opt-out of them and continue to participate in the promotion. If an opt-out is available, you will find that option within the communication itself. Importantly, if you do enter into a promotion and opt-out of transactional communications, we will have no way to reach you if you are a potential winner or otherwise eligible for something of value. For more information about opting out, please see Sections 7 and 8.

D. To Market, Promote, and Drive Engagement With The Services
We will use your information about how you engage with promotions to send communications that may be of specific interest to you, including by email, and by displaying PrizeLogic ads on other companies’ websites and applications, as well as on platforms like Facebook and Google. These communications are aimed at driving engagement with our promotions and may include information about new programs and sites we think may be of interest to you. We may also communicate with you about new product and service offers, promotions and contests. You can control how and whether you receive these communications as described below in Sections 7 and 8.

E. Fraud Detection and Prevention; Safety and Security
We will use your information to detect and prevent fraud and as may be otherwise necessary to help ensure the integrity of our promotions and to identify violations of the promotion rules or the policies of PrizeLogic or those of our clients.

F. To Protect our Legitimate Business Interests and Legal Rights
Where required by law or where we believe it is necessary to protect the legal rights and interests of PrizeLogic, our clients, or others, we may use your PII in connection with legal claims, compliance, regulatory, and audit matters.

G. With Your Consent
We also use your PII where you have provided consent for PrizeLogic or our client to do so for a specific purpose not listed above. For example, with your consent, we may post contest entries or other user generated content to social media platforms.

H. Customer Support
We use your PII and non-personally identifiable information to resolve technical issues you encounter, to respond to your requests for assistance, to analyze crash information, and to repair and improve the promotions.

I. Legal Bases for Processing (for EEA Users)
If you are an individual in the European Economic Area (EEA), we collect and process your PII only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the promotions you enter, how they operate, and how you use them. This means we collect and use your PII only where:

– We need it to operate the promotion, provide customer support and personalized features, help prevent fraud, and to protect the safety and security of our platforms and promotion services;
– It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for our internal development of improved services, to market and promote the promotions, and to protect our legal rights and interests;
– You give us consent to do so for a specific purpose; or
– We need to process your PII to comply with a legal obligation or where the processing is necessary to the establishment, exercise or defense of legal claims.

If you consented to our use of your PII for a specific purpose, you have the right to change your mind at any time but note that this will not affect processing that has already taken place.

Where PrizeLogic is using your PII because our client and/or PrizeLogic have a legitimate interest to do so, you have the right to object to that use although this may mean no longer participating in a promotion. If we are unable to manage your participation in a promotion without the PII you provided (such as your registration information), you will no longer be able to participate in the applicable promotion. To learn how to opt-out of allowing use of your PII, please refer to Sections 7 and 8.

3. Additional Services and Third-Parties

PrizeLogic may also offer social sign-on services that allow you to register for a promotion using a third-party social networking site such as Facebook, Twitter, Instagram, YouTube, etc. By using these services, we may share PII with that service about you and we will access the available PII from your third-party social network profile such as your name, age, gender, location, email address, and list of friends. This PII may be used by PrizeLogic to administer the technical and operational aspects of the Website, or make your experience on our promotions and services more personal and social. PrizeLogic does not control the privacy practices of these (or any other) third-party services. We encourage you to read the privacy policies of these services before connecting to them.

4. Security of PII

Although no computer network is invulnerable to attack, PrizeLogic uses reasonable physical, electronic, and procedural security measures designed to protect your PII from unauthorized disclosure.

5. Special Note About Children

Unless otherwise specifically indicated, PrizeLogic promotions are not available to anyone under the age of thirteen. PrizeLogic does, however, operate some promotions and platform solutions on behalf of its clients that collect PII from children under the age of thirteen. In each such instance, PrizeLogic complies with the Children’s Online Privacy Protection Act (“COPPA”) when operating the promotion, collecting the PII itself, and subsequently using the data collected. PII will not be collected from children under the age of thirteen without parental consent in compliance with the COPPA guidelines. If you have questions concerning PrizeLogic’s information collection and use practices with respect to children, or if you would like to review, have deleted, or stop the further collection of your child’s PII, you may contact PrizeLogic as set forth in Section 9 below.

6. Client Privacy Notices and Opting-Out of Client use of PII

You should read the client’s privacy policy to learn how that client uses, discloses, and limits disclosure of your PII, as well as to understand your choices for opting-out of its collection, amend it for accuracy, or have it deleted. Your desire to opt-out of receiving marketing or other information from that client will be handled in accordance with that particular client’s privacy notice. Please note that opting-out of a client’s marketing program will not opt you out of PrizeLogic’s marketing programs. To learn how to opt-out of PrizeLogic’s use of your PII, please see Section 8.

7. Opting Out of PrizeLogic use of PII

In general, “opting out” means that you want PrizeLogic to limit the PII it collects and stores about you and to not target ads that are based on your interests to your browser or device. Your opt-out is applicable only to PrizeLogic marketing material and will not opt you out from platforms provided by third-party companies or client promotions. If you use multiple browsers, computers or mobile devices, and wish to limit the PII and non-personally identifiable information PrizeLogic collects and stores or do not wish to receive PrizeLogic interest-based advertising on any of them, you must opt out from each browser, computer, and mobile device individually. Please note that if cookies are not enabled in your browser, or if you use certain ad-blocking tools, our opt-out mechanism may not work properly. Please also note that deleting your cookies does not opt you out. To opt-out of PrizeLogic using your PII, you need to contact us using the contact information provided below.

8. Contacting Us

It is PrizeLogic’s goal to keep all PII that you provide to us accurate. You may contact us to correct or update your PII, deactivate your PII or opt-out (if PrizeLogic is holding on to your PII as explained above), and to ask general questions regarding this Notice or any other privacy related issues. PrizeLogic’s Information Security Director can be reached at:

Prize Logic, LLC
25200 Telegraph Rd, Suite 405
Southfield, MI 48033
Telephone: (855) 951-5262
or faxing or emailing the details of your request to:
Fax Number: (480) 270-3020
Email: privacy@prizelogic.com

If you are based in the European Economic Area (“EEA”), you may contact our Data Protection Officer/Information Security Team at privacy@prizelogic.com.

9. Third Party Links

Hypertext links which redirect you to third-party websites may be encountered while browsing the Website. These hypertext links are maintained or operated by third-parties, not PrizeLogic. These third-party websites are not under our control, and we are not responsible for the contents, links, or any changes or updates to these websites. Further, the inclusion of any hypertext links on the Website does not imply endorsement by us of the related third-party website, that website’s contents or security, or any association or affiliation with its operators. PrizeLogic is not responsible for data and information collected by these third-party websites.

10. International Users

PrizeLogic is based in the United States, and, regardless of where you use PrizeLogic solutions or otherwise provide PII and non-personally identifiable information, that information may be transferred to and maintained on servers located in the U.S.

11. California Residents Privacy Policy

This California Resident Privacy Policy disclosure (“Disclosure”) is provided pursuant to the California Consumer Privacy Act (“CCPA”) as amended, and applies only to California residents. Any terms defined in the CCPA have the same meaning when used in this Disclosure. Terms defined in the Notice maintain the same meaning when used in this Disclosure.

This Disclosure is effective as of January 1, 2021.

The Personal Information (defined in Cal. Civ. Code §§ 1798.140(o)) that we collect and the manner we use it is covered in sections 1 and 2 above.

A. Categories. Below is a summary for the preceding 12 months of the Personal Information categories (as identified and defined by the CCPA) that we collected in the course of providing our clients with promotions and services:

B. Categories Shared. We may use or disclose Personal Information in the following categories in the course of providing our clients with promotions and services (the “Business Purpose Disclosures” in the table below).

C. No Sale. In the 12 months prior to the effective date of this Disclosure, PrizeLogic has not sold (as the term “sell” is defined in the CCPA) your Personal Information.

D. Requests Regarding Personal Information. You may have the right to request information about our collection of your Personal Information, to access it, or instruct us to delete it (subject to the exceptions below). To do so, please contact us using the information provided in section 8. Note that we may ask you to verify Personal Information we already have on file for you. If we cannot verify your identity based on the Personal Information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes. If we cannot comply with your request, we will provide you with an explanation.

E. Timing. We will use reasonable efforts to respond to your request within 45 days of receipt. If we require additional time, we will inform you of the reason and the extension period in writing.

F. Exceptions. We may deny your deletion request if retaining the Personal Information is necessary for us to:

– Complete the transaction for which we collected the Personal Information;

– Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;

– Identify and/or repair errors that impair the functionality of our services;

– Make other lawful uses of the Personal Information that are compatible with the context in which you provided it; and

– Comply with a legal obligation.

G. Content. Any Personal Information we provide you with will only cover the 12-month period preceding our receipt of your request. Once we receive your request, validate your identity (and unless one of the exceptions above apply) we will disclose to you:

– The categories of Personal Information we collected about you;

– The categories of sources for the Personal Information we collected about you;

– Our business purpose for collecting that Personal Information and whether it was sold;

– The categories of third parties with whom we shared the Personal Information;

– If we sold or disclosed your Personal Information for a business purpose, we will provide you with information about those sales and disclosures along with the Personal Information categories that were provided and each recipients category.

– The specific pieces of Personal Information we collected about you (also called a data portability request, as detailed below).

H. Data Portability. For data portability requests, we will select a data format that is readily useable and should allow you to transfer the Personal Information to another entity without difficulty.

I. No Charge. We do not charge a fee to process or respond to your Personal Information request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

J. No Discrimination. PrizeLogic will not discriminate against any consumer for exercising their rights under the CCPA.

12. Changes to this Notice

This Notice was last updated on March 31, 2021. However, this Notice will change over time, for example to comply with legal requirements or to meet changing our business needs. The most up to date version can be found on the Website. In case there is a change that we want to highlight to you, we will also inform you in another appropriate way (for example, via a pop-up notice or statement of changes on our Website).