Fetch Rewards State Privacy Rights and California Notice at Collection
Effective date: Aug 2, 2023
Fetch Rewards, Inc. and its affiliates and subsidiaries ("Fetch," "we," "us," or "our") provide this State Privacy Rights and California Notice at Collection (the "State Specific Privacy Notice") to supplement the information contained in the Fetch Privacy Policy. This State Specific Privacy Notice sets forth our privacy practices and your privacy rights as required by the California Consumer Privacy Act of 2018 ("CCPA") and privacy laws in Colorado, Connecticut, and Virginia (collectively, “State Privacy Laws”).
The State Specific Privacy Notice applies only to individuals residing in California, Colorado, Connecticut, and Virginia who are considered "Consumers" and from whom we collect "Personal Information" under applicable State Privacy Laws. If you are a California employee, employee applicant, or contractor, please refer to our Fetch Rewards Privacy Notice for California Employees.
California Notice at Collection
Collection and Use of Personal Information
We may collect Personal Information from you in a variety of different situations, including, but not limited to on our website, your mobile device, through voluntary surveys, through email, through the mail, and/or over the telephone. More specifically, Fetch collects the following categories of Personal Information from its Consumers, which will depend on the particular Business Purpose for which we collect it:
| Category | Examples of Personal Information Collected |
|---|---|
| Identifiers | A real name, user name, mobile phone number, mobile device ID, postal address, Internet Protocol address, email address. |
| Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | A name, address, telephone number, date of birth, gender. |
| Protected classification characteristics under California or federal law | Age, date of birth, gender, and other information described in the sensitive personal information section below. |
| Commercial information | Products or services purchased. |
| Biometric information | None. |
| Internet or other similar network activity | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. |
| Geolocation data | Physical location or movements. |
| Sensory data | None. |
| Professional or employment-related information | None. |
| Education information, as defined by the Family Educational Rights and Privacy Act. | None. |
| Inferences drawn from other personal information | Profile reflecting a person’s preferences, characteristics resulting or relating to points acquired and Rewards redeemed. |
| Sensitive Information | Account log-in; password or credentials allowing access to account; precise geolocation. Racial or ethnic origin, religious or philosophical beliefs; contents of consumer’s mail, email, and text messages unless business is the intended recipient; consumer health information; information collected and analyzed concerning a consumer’s sex life or sexual orientation collected as part of voluntary surveys or as further explained below in the Sensitive Personal Information section. |
Personal information does not include deidentified or aggregated consumer information.
Fetch obtains the categories of Personal Information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and services you purchase.
- Indirectly from you. For example, from observing your actions on our website or from information your computer or mobile device transmits when interacting with our website or mobile applications, among other things.
How We Use Personal Information
We may use the Personal Information we collect from you or about you for the following business purposes:
- To act in accordance with your direction. For example, where you intentionally interact with our program and direct Fetch to share personal information, we use your personal information in accordance with your direction and share your personal information you provide to us by registering and earning rewards with all our participating brands, regardless of your actual interaction with each. In addition, by uploading receipts, participating in Challenges or taking Surveys offered by a participating brands, you are using Fetch to intentionally interact with all our participating brands who provide points in our Program.
- To fulfill or meet the purpose for which you provided the information. For example, if you provide your personal information to become a member, scan receipts, [make a payment] or redeem a reward, we will use that information to provide you member benefits or process your transaction.
- To determine whether you are an eligible age or meet other qualifications to purchase certain products or services.
- To contact you and to inform you about products, services, promotions, special offers, and/or events that may interest you.
- To inform you about rewards you have redeemed products and services you have purchased from us.
- To create, maintain, customize, and secure your account with us, including to determine the language to use for products, services, and communications.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- As part of a voluntary survey to better understand our members, products, and/or services.
- If you provide your information in the context of an employment application or your employment, we will use your information to serve those purposes and as further described in our Privacy Notice for California Employees
- To personalize your App or Website experience and to deliver content and product and service offerings relevant to your interests, including customized offers and ads through our website, mobile applications, third-party sites, and via email or text message (with your consent, where required by law).
- To help maintain the safety, security, and integrity of our App or Website, products and services, databases and other technology assets, and business, and to prevent fraud.
- For research, analysis, and business development, including to develop and improve our Website, products, and services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or subsequently agreed to by you.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Fetch assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Fetch about our Consumers is among the assets transferred.
How We Disclose Personal Information
Fetch may disclose your Personal Information to a third party for a business purpose, including to our service providers.
We disclose your personal information with the following categories of third parties:
- Service providers.
- Third parties with whom you intentionally interact through our program or direct us to share your personal information, including our participating brands.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Fetch has disclosed the following categories of personal information for a business purpose to the following recipients:
| Category of Personal Information | Category of Recipients |
|---|---|
| Identifiers | Service providers such as web hosting and internet service providers; information technology, customer service, cloud service, data analytics, marketing and advertising service providers.
Business such as our participating brands to whom you direct us to share Personal Information or with whom you intentionally interact through our Program. |
| Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | Service providers such as web hosting and internet service providers; information technology, customer service, cloud service, data analytics, marketing and advertising service providers. Contractors that provide us payment processing services and fraud detection. Business such as our participating brands to whom you direct us to share Personal Information or with whom you intentionally interact through our Program. |
| Protected classification characteristics under California or federal law | Service providers such as web hosting and internet service providers; information technology, and cloud service providers. Contractors that provide us payment processing services and fraud detection. |
| Commercial Information | Service providers such as web hosting and internet service providers; information technology, customer service, cloud service, data analytics, marketing and advertising service providers. Contractors that provide us payment processing services and fraud detection. Business such as our participating brands to whom you direct us to share Personal Information or with whom you intentionally interact through our Program. |
| Internet or other similar network activity | Service providers such as web hosting and internet service providers; information technology, customer service, cloud service, data analytics, marketing and advertising service providers. |
| Geolocation | Service providers such as web hosting and internet service providers; information technology, customer service, cloud service, data analytics, marketing and advertising service providers. |
| Sensitive Information | Service providers such as web hosting and internet service providers; information technology, customer service, cloud service, data analytics, marketing and advertising service providers. Business such as our participating brands to whom you direct us to share Personal Information or with whom you intentionally interact through our Program. |
Sales of Personal Information
In the preceding twelve (12) months, Company has not sold personal information.
Sensitive Personal Information
Fetch does not use or disclose sensitive personal information for purposes other than to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services or as directed by a consumer and other purposes allowed by applicable law that do not include creating customer profiles, which include to resist deceptive, fraudulent, and illegal actions directed at Fetch; for short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a consumer’s current interaction with Fetch, which is not used to build a consumer profile; to maintain or service accounts, provide customer service, process or fulfill orders and transactions, and verify customer information; and to improve, upgrade, or enhance our products or services. To the extent Fetch collects sensitive personal information, it does not use that information to infer characteristics about you.
Notice of Financial Incentive
Under the CCPA, because your participation in our Program enables you to earn points, it is considered a financial incentive program. In order to provide you points, you direct us to use and share the personal information you provide when you register along with your activity information with all our participating brands so that you can interact with them and earn points. The value you receive in participating in our Program is calculated by and depends on the amount and nature of your interaction with our participating brands to obtain points. Points do not have monetary value, but each point can generally be redeemed for approximately $0.001 in rewards, but this may vary from time to time.
Note that participation in Fetch Rewards is completely voluntary and you can withdraw or opt-out at any time. For further details of the Program and its terms, including how to withdraw or terminate your participation, please refer to our Terms of Service.
Your State Consumer Privacy Rights and Choices
Subject to certain limitations, you have the right to (1) request to know more about the categories and specific pieces of Personal Information we collect, use, disclose, and sell, and to access your information, (2) request deletion of your Personal Information, (3) request correction of your Personal Information and (4) not be discriminated against for exercising these rights, (5) limit processing of Sensitive Personal Information.
Access to Specific Information and Data Portability Rights
You have the right to request that Fetch disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Your Privacy Rights), 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 or commercial purpose for collecting that Personal Information.
- The categories of third parties with whom we disclose that Personal Information.
- The specific pieces of Personal Information we collected about you.
- If we disclosed your Personal Information for a business purpose, a list disclosing the disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that Fetch delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Your Privacy Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
In accordance with applicable law, we may deny your deletion request under certain circumstances, and will inform you of the basis for the denial, which may include, but is not limited to, if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us
- Comply with a legal obligation.
Right to Limit Processing of Sensitive Personal Information
In California, you have the right to limit our processing of Sensitive Personal Information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such goods or services. In certain other states, we might require your consent before collecting Sensitive Personal Information. When we collect your Sensitive Personal Information, we collect and use that information in order to perform the services or provide the goods for which that information is necessary and as reasonably expected by you. Moreover, we do not use your Sensitive Personal Information for the purpose of inferring any characteristics about you. We will notify you if we use your Sensitive Personal Information for purposes where you have a right to limit or opt-out of that processing and will provide a method for exercising that right. We will obtain your consent or opt-in to collect or process Sensitive Personal Information where we are required to do so by applicable law.
Right to Correction
You have the right to correct inaccurate Personal Information maintained by us. Once we receive and confirm your verifiable consumer request (see Exercising Your Privacy Rights), we will correct (and direct our service providers to correct) your inaccurate Personal Information we are reasonably able to determine is inaccurate about you from our records, unless an exception applies.
Exercising Your Privacy Rights
To exercise the access, data portability, correction, and deletion rights described above, please submit a Privacy Request Form.
Only you or a person authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.
We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
If we deny your request, you may appeal our decision by contacting us at privacy@fetch.com. Please clearly denote that it is an appeal.
Response Timing and Format
We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional 45 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we may deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
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.
Other California Privacy Rights
California’s "Shine the Light" law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@fetch.com or write us at:
Fetch Rewards, Inc.
1050 E. Washington Ave. 2nd Floor
Madison, WI 53703
Changes to Our State Specific Privacy Notice
This State Specific Privacy Notice was last updated on the date indicated above. We reserve the right to amend this Policy from time-to-time. Any material change to our privacy practices will be reflected in this State Specific Privacy Notice, and we may in some instances notify you in other ways of updates. By continuing to use the Website or App after the date last updated, you agree to the privacy practices contained in the updated State Specific Privacy Notice. We encourage you to review this notice regularly to stay informed about our information practices and the choices available to you.
Contact Us
If you have any questions or comments about this State Specific Privacy Notice, the ways in which Fetch collects and uses your information described above and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under state privacy law, please do not hesitate to contact us at:
Email: privacy@fetch.com
Postal Address:
ATTN: Privacy Team
Fetch Rewards, Inc.
1050 E. Washington Ave. 2nd Floor
Madison, WI 53703