Privacy Policy

We are pleased to offer for your use loyalty program products and services, which we refer to as Services, for your use to engage with us and find products available at our stores that we hope will be of interest to you. In connection with your use of the Services, we will obtain a variety of information about you. We refer to information that is linked to your identity as “Personal Information”. We want to assure you that we respect your privacy, so we have prepared this privacy policy to explain to you how we treat your Personal Information that we obtain in connection with your use of the Services.

Please read this privacy policy so that you can make an informed decision about using the Services. If you do not agree to this privacy policy, then do not use the Services. By registering an account to use the Services and by using the Services, you are agreeing to this privacy policy and providing your consent to our collection, use and disclosure of your Personal Information as described in this privacy policy.

The Services are provided by the retailer providing the loyalty program and its affiliates and service providers. In this privacy policy, words like "we", "us" and "our" refer to the retailer providing the loyalty program and its affiliates and service providers, collectively. We will disclose information, including your Personal Information, to these other entities in connection with providing the Services, as described further below in the “Disclosure of Personal Information” section, and these other entities may use and disclose information as provided in this privacy policy.

This privacy policy was last modified on August 23, 2018.

Personal Information

We obtain Personal Information about you in the following ways:

· Information collected automatically . We may obtain information about you through the use of cookies, web beacons, web logs, IP address, and other technologies that receive and store certain types of information whenever you interact with us by using the Services. These technologies may collect your IP address, mobile device identification, the type of device or operating system in use, the type of browser being used, the number and frequency of uses of our application, or request access to information regarding installed applications and or use of your device features such as the camera to operate, and similar technical information that does not identify you personally. If you enabled location sharing on your device, we will automatically collect the location of your device. If you wish to disable access to the location services, you can do so by making changes in your device using the settings feature.

Use of Personal Information

We use your Personal Information to provide the Services to you, to understand usage of the Services so that we can make improvements to the Services, to provide relevant coupons and marketing messages to you in connection with your use of the Services, to analyze in an effort to better understand our products, services and business in general, to handle user support requests, and to understand your behavior and preferences so we can offer additional products, services and other opportunities that we believe will be of value to you.

Disclosure of Personal Information

We have several affiliates that provide services to us and we may disclose Personal Information to these affiliates. The affiliates are either wholly-owned subsidiaries or entities that we control.

We use third parties to provide services to us in connection with the Services, and we may provide Personal Information to these third parties, including, without limitation, GroceryPress LLC and its affiliates, which are our principal service providers with respect to our program and which we refer to collectively as GroceryPress. However, we will share Personal Information with third parties only if they agree to maintain the confidentiality of your Personal Information and to use your Personal Information only in connection with providing the Services and other services to us. These other entities may use and disclose information as provided in this Privacy Policy. GroceryPress provides several services and applications to consumers, and if you use more than one of its services and applications, GroceryPress may combine and use your Personal Information from these various services and applications.

We may derive information from your Personal Information that is not personally identifiable to you. For example, we may aggregate certain information regarding use of the Services so that your usage of the Services is not discernable from the aggregate usage of the Services. We may use and share with third parties any information that we derive from Personal Information that is not personally identifiable to you.

We may disclose Personal Information if compelled to in connection with a legal or regulatory proceeding, or in connection with enforcing our rights or defending ourselves in a legal or regulatory process.

We may obtain your consent to disclose your Personal Information to a third party, in which case we will limit our disclosure and the use of your Personal Information only to the purposes for which we obtain your consent. If we disclose your Personal Information to a third party with your consent, then your Personal Information will become subject to the privacy policy or other privacy commitments, if any, of that third party. For example, we may enable you to post Personal Information to a social media account, in which case that Personal Information will become subject to the privacy policy of that social media platform. It is your responsibility to understand the third party’s privacy policy or other privacy commitments.

Your Personal Information Rights

We limit access to your Personal Information to people and entities that have a need to use your Personal Information for our business purposes.

You may access your Personal Information and correct any inaccurate or incomplete information. You may access some items of Personal Information through your account profile, as well as change or correct those items of Personal Information through your account profile. If you need access to additional Personal Information that is not provided via your account profile, you may request access to such information, or request to correct, amend or delete any Personal Information that is inaccurate or incomplete, by contacting us at privacy@spins.com.

You may request to receive a copy of your Personal Information in machine-readable format and to have such information transferred to another controller. You may limit our use of your Personal Information, request that your Personal Information be erased, or object to the processing of your Personal Information. If you have previously provided us with consent to process your Personal Information, you may withdraw consent you have previously provided us at any time. If you decide not to provide or to limit your Personal Information, it may diminish the functionality of the Services, you may not be able to use certain features of the application, and we may not be able to provide certain services to you.

To exercise the rights listed above, please contact us at privacy@spins.com. If you do not want to receive email offers or other notices from us in the future, you may opt out of receiving email communications by following the opt out instructions located within an email received from us. Please note that you may not opt out of receiving service-related email communications or other email communication necessary to provide the Services as specified in various portions of this privacy policy. These email communications are not promotional in nature and if you wish to opt out of receiving them, you have the option to deactivate your account.

Retention of Personal Information

We will retain your Personal Information for so long as necessary to meet our business needs and to comply with applicable legal and regulatory requirements. Your Personal Information is primarily stored in digital media, and when we no longer need to retain your Personal Information we will dispose of your Personal Information, whether stored in digital media or in hard copies, in a secure manner.

Usage of the Services

We monitor your use of the Services so that we can understand how you use the Services, products that are of interest to you, store locations that are relevant to you, and other information that we may use to improve the Services and otherwise use in our business.

Data Security

We use industry standard security measures to protect your Personal Information and require our service providers to do the same. However, you must understand that no data transmission over the internet or information storage technology can be guaranteed to be 100% secure. In addition, we limit access to your Personal Information as explained above in the section on Your Personal Information Rights.

Third Party Email Addresses

You may provide us with an email address for a friend, family member or other third party so that we can send information that you request to that email address. We will use that email address to send an email to that address for the purpose you provided the email address. The recipient of the email may contact us to remove the email address from our systems, and we provide information regarding how to remove the email address in the email that we send.

No Use by Children

The Services may be used only by adults who are a United States resident and of sufficient age and otherwise able to enter into a legally binding contract. In no event may the Services be used by a child under the age of 13. If we learn that we have collected the Personal Information of a child under the age of 13, we will take reasonable steps to delete such Personal Information from our system.

Transfer of Personal Information

We reserve the right to transfer all Personal Information in our possession to a successor organization in the event of a merger, acquisition, bankruptcy or other sale of all or a portion of its assets. Subject to legal requirements, the use and disclosure of all Personal Information will be subject to this privacy policy, or to a new privacy policy, so long as you are given notice of the new policy and provided with the opportunity to opt-out of it.

Contact for Questions or Complaints

If you have questions or concerns regarding this privacy statement, our privacy practices or your Personal Information, you may contact our Data Privacy Officer at privacy@spins.com. You can also send us mail to:

SPINS LLC

222 W. Hubbard Street Suite 300

Chicago, IL 60654

Attn: General Counsel

Notice of Changes

We reserve the right to change, modify or add to this policy at any time, and to apply any such change, modification or addition to Personal Information that we have already collected. We may provide you with notice of a change, modification or addition by posting a notice or a revised privacy policy via the Services. You agree to review the Services from time to time to review the current policy and any changes, modifications or additions.