This Privacy Notice (“Notice”) explains how Clarus Commerce LLC dba ebbo (“ebbo”, “our”, “us”, “we”), an all-in-one engagement and loyalty company, collects, processes, and uses 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 the information that you provide to us. This is your information that (i) you choose to provide to us on behalf of our clients when you decide to engage in client promotions and marketing activities that we manage and/or operate (“Engagement and Loyalty Services”); (ii) we gather when you visit our website at ebbo.com or other websites we own or manage (the “Website”); (iii) we gather when you interact with ebbo directly (e.g., our website, mailboxes, points of entry offline); we possess and process; or (v) is provided to us by a client or service provider.
By accessing or using the Site, you signify your agreement to be bound by our Privacy Notice. If you do not agree to this privacy notice, you may not access or otherwise use our site.
If you have any questions about this Notice, please email us at firstname.lastname@example.org or call (860) 358-9198. Additional contact information is provided in the Contacting Us section below.
1.0 Information We Collect
1.1 Personally Identifiable Information (“PII”)
In addition to the information you may provide directly, we may analyze your browsing behavior to draw inferences and create profiles about your personal preferences and behaviors. We may then use such information for the purposes described in this notice.
1.2 Personal information that is not PII.
ebbo, on behalf of our clients and for its own purposes, may also collect or generate non-personally identifiable information about your use of our 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, 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.
1.3 Website Visitor Tracking Tools That We Use
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 present you with relevant ads about our services, customize our services, gather insight analytics about our client’s customers and consumers, and honor preferences about advertising and communications.
1.3.2 Web Beacons and Pixels
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 present you with relevant ads about our services. You can disable our web beacons by turning images “off” in your email client (e.g., Outlook, Apple Mail, or Gmail).
1.3.3 Third Party Tools
We have opted-in to ‘The LeadLander Contact Network’. LeadLander is a web analytics tool, similar to Google Analytics. However, The LeadLander Contact Network pools together contact information collected through any forms or email campaigns of ours and any other LeadLander opted-in website forms or email campaigns to identify a visitor to this Site. Whenever a visitor goes to any LeadLander opted-in website, LeadLander can display the visitor by their name and email address in its reports.
2.0 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 website hosting, 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, (iv) the promotions entered by you and (v) client sites where you maintain a membership. More information about how we use the information we collect is provided below.
2.1 To Operate Engagement and Loyalty Services and Personalize Your Experience
Our Engagement and Loyalty Services may include features that personalize your experience. To that end, we use your PII and non-personally identifiable information to operate and benchmark the Engagement and Loyalty Services, including, without limitation, to process transactions with you and validate the information you provide. 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. We may use your IP address to serve you state or region-specific content, and to comply with relevant regulatory requirements.
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.
2.2 For Development and Improvement of our Engagement and Loyalty Services
We continually strive to improve our Engagement and Loyalty 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.
2.3 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 “Opting Out of ebbo use of PII” and “Contacting Us” (Sections 6.0 and 7.0).
2.4 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 ebbo 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 “Opting Out of ebbo use of PII” and “Contacting Us” (Sections 6.0 and 7.0).
2.5 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 ebbo or those of our clients.
2.6 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 ebbo, our clients, or others, we may use your PII in connection with legal claims, compliance, regulatory, and audit matters.
2.7 With Your Consent
We also use your PII where you have provided consent for ebbo 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.
2.8 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.
2.9 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 at least one legal basis for doing so under applicable EU laws. The legal bases depend on how you interact with ebbo promotions and services. For example, the promotions you enter, how they operate, and how you use them may impact which bases apply. This means we collect and use your PII only where:
– We need it to provide service, 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 ebbo is using your PII because our client and/or ebbo 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 an applicable promotion or access a service that requires that information. To learn how to opt-out of allowing use of your PII, please refer to “Opting Out of ebbo use of PII” and “Contacting Us” (Sections 6.0 and 7.0).
3.0 Third Parties and Additional Services
ebbo may share or otherwise transfer your personally identifiable information (PII) to trusted third parties who assist us in operating our Site, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
As we develop our business, we may transfer any information we have about you in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Clarus Commerce LLC or as part of a corporate reorganization or equity sale or other change in corporate control.
3.1 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 ebbo. 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. Third-party sites linked on our Site have separate and independent privacy policies. 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. ebbo is not responsible for data and information collected by these third-party websites. Nonetheless, we seek to protect the integrity of our Site and welcome any feedback about these sites.
3.2 Social Networking
ebbo 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 may access the PII you make available through 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 ebbo to administer the technical and operational aspects of the Website or make your experience on our promotions and services more personal and social. ebbo 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.
4.0 Children’s Online Privacy Protection Act Compliance
Unless otherwise specifically indicated, ebbo promotions are not available to anyone under the age of thirteen. ebbo 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, ebbo 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 ebbo’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 ebbo as set forth in “Opting Out of ebbo Use of PII” (Section 6.0).
5.0 Security of PII
Although no computer network is invulnerable to attack, ebbo uses reasonable physical, electronic, and procedural security measures designed to protect your PII from unauthorized disclosure.
6.0 Opting Out of ebbo use of PII
In general, “opting out” means that you want ebbo 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 ebbo 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 ebbo collects and stores or do not wish to receive ebbo 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 ebbo using your PII, you need to contact us using the contact information provided below.
6.1 Client Privacy Policies and opting out of Client use of PII
7.0 Contacting Us
It is ebbo’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 ebbo is holding on to your PII as explained above), and to ask general questions regarding this Notice or any other privacy related issues. ebbo’s privacy team can be reached at:
500 Enterprise Drive
Rocky Hill CT 06067
If you are based in the European Economic Area (“EEA”), you may contact our Data Protection Officer/Information Security Team at email@example.com.
9.0 International Users
ebbo is based in the United States, and, regardless of where you use ebbo 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.
10.0 Changes to This Notice
This Notice was last updated on October 1, 2022. 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).
11.0 California Resident Privacy Notice
This California Resident Privacy Notice 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 1.0 and 2.0 above.
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:
|Category||Examples||Processed by ebbo|
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||Yes|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license, or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.||Yes|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||Yes|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Yes|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||No|
|F. Internet or similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||Yes|
|G. Geolocation data.||Physical location or movements.||Yes|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||No|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||No|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary codes.||No|
|K. Inferences drawn from other personal information.||Profile a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||No|
11.2 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).
|Category||Category of Third-Party Recipients|
|Business Purpose Disclosures||Sales|
|B. Personal information categories listed in the California Customer Records statute||Yes||No|
|C. Protected classification characteristics under California or federal law.||Yes||No|
|D. Commercial information.||Yes||No|
|E. Biometric information.||No||No|
|F. Internet or similar network activity.||Yes||No|
|G. Geolocation data.||Yes||No|
|H. Sensory data.||No||No|
|I. Professional or employment-related information.||No||No|
|J. Non-public education information||No||No|
|K. Inferences drawn from other personal information.||No||No|
11.3 No Sale
In the 12 months prior to the effective date of this Disclosure, ebbo has not sold (as the term “sell” is defined in the CCPA) your Personal Information.
11.4 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 “Contacting Us” (Section 7.0). 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.
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.
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.
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).
11.8 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.
11.9 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.
11.10 No Discrimination
ebbo will not discriminate against any consumer for exercising their rights under the CCPA.