Perkville Privacy Policy

Updated and Effective as of:  March 9, 2024

This Privacy Policy explains how Perkville, Inc. (“Perkville”, “we”, “us”, “our”) collects, uses, and shares information and the options available to you. If you have any questions, you may contact us. See the “Contacting Us” section below.

We may change this Privacy Policy from time to time. Please consult this Privacy Policy regularly for updates. See “Modifications to this Privacy Policy” below for more information.

User Consent: You consent to the practices described in this Privacy Policy by using or accessing our Services, and you represent that you are at least 18 years old.

California, Virginia, Colorado, Connecticut, and Utah Users: If you are a resident of California, Virginia, Colorado, Connecticut, or Utah, see the Additional US Privacy Notice for additional information about your rights and our disclosures. 

California Employees, Job Applicants, Owners, Directors, Officers, and Contractors: If you are a resident of California and you are an employee, job applicant, controlling owner, director, officer, or independent contractor of ours, see the Privacy Notice for California Company Workforce.

WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy covers the information that we may collect or receive: (1) from users who: visit www.perkville.com, https://middle.app/, and other websites owned and operated by us (including our client and user interfaces), use our software applications, use our social media pages such as Facebook and LinkedIn, and receive email messages from us (collectively, the “Perkville Pages”); and (2) through our technologies and platforms used by our business customers and third parties, including our referral and loyalty platform and our Middle integration platform (collectively with the Perkville Pages, the “Services”).

This Privacy Policy does not cover, and we are not responsible for, the privacy or data practices of or the processing of data by any third parties (except as required by applicable law), such as our business customers and any service providers. See “Third Parties” below for more information.

Choice and Opting Out: see “Choices” below for information about your choices regarding opting out of email marketing communications, opting out of Perkville’s cookies, opting out of interest-based advertising by third parties from cookies, and opting out of the use of precise location. For information on deactivating your Perkville account or your accounts with business customers via the Services, please see “Access and Rights regarding Personal Information.Access and Rights: see “Access and Rights regarding Personal Information” below for information about how to review, correct, update, suppress, or delete the personal information that Perkville maintains about you and to exercise other data subject rights.

International Transfers: see “International Information Transfers” below for information on the transfer of your personal data.

COLLECTION OF INFORMATION

Middle Integration Platform Collection:

Our Middle integration platform is used and accessed by our business customers and their employees and representatives only. Our Middle platform allows our business customers to integrate with various third party service providers and platforms.

The Middle integration platform does not directly collect information about any consumers. However, our business customers may use the Middle integration platform for the purpose of collecting personal information about its customers. This privacy policy does not cover our business customers’ collection or processing of their customers’ information through the Middle integration platform. Please review the applicable business customer’s privacy policy for information about its data practices.

We may collect the following personal information about you as an employee or representative of our business customer:

name

email address

phone number

physical address

time spent on the Services and your activities on the Services, including pages visited, requested URL and referring URL, date and time on the Services, information about interactions with our emails, and other anonymous traffic-related data,

unique identification numbers, including IP address and your location derived from IP address,

information provided by you,

information to enable and authorize your logging in to the Services,

browser information, including browser type and language,

device information, including screen dimensions, device brand and model, and mobile device identifier, and

aggregated information.

Some of this information is provided by you, and is optional. However, if you elect not to provide such information, you will not be able to access the information you had requested to access or use.

Perkville Referral and Loyalty Platform Collection:

Our referral and loyalty platform is used and accessed by our business customers, their employees and representatives, and their customers. This platform allows our business customers to create custom loyalty points for their customers and referral offers for their customers to send to their friends.

For our referral and loyalty platform, we may collect the following personal information from you:

name

email address

phone number

Perkville user identification account number

business customer identification number

unique identification numbers, including IP address and your location derived from IP address,

your staff identification number at the business customer of our referral and loyalty Services

physical address

Twitter user ID

your Tweets for loyalty points through our referral and loyalty Services,

time spent on the Services and your activities on the Services, including pages visited, requested URL and referring URL, date and time on the Services, information about interactions with our emails, and other anonymous traffic-related data,

transaction-related data relating to the referral and loyalty Service such as: date, time and location a transaction took place (e.g., when and where a class was attended), description and/or classification of the transaction (e.g., yoga class attended, gym check-ins, personal training sessions, referrals made, amount spent, etc.), quantity of items sold or services associated with the transaction, number of loyalty points added or redeemed in connection with the transaction,

information about the Perkville business terms or referral offer terms that you agreed to,

unique identification numbers, including IP address and your location derived from IP address,

demographic information (e.g., date of birth, gender) as provided by you or the business customer,

information provided by you,

information to enable and authorize your logging in to the Services,

browser information, including browser type and language,

device information, including screen dimensions, device brand and model, and mobile device identifier, and

aggregated information.

Some of this information is provided by you, and is optional. However, if you elect not to provide such information, you will not be able to access the information you had requested to access or use.

For both our Middle integration platform and our Perkville referral and loyalty platform, we may collect some of this information through: your browser or device; your mobile device identifier; your use of our Services; your IP address; the aggregation of information; and the use of cookies and other similar technologies (see Cookies and Similar Technologies below). We may also collect your personal information when you request information about the Services, or you sign up to use the Services through our client login and user interfaces, or you request access to our resources.

For our referral and loyalty platform only, we may collect your information when a friend or family member has referred you through the referral and loyalty Services, or when a business customer has identified you as their customer through the referral and loyalty Services. You may also provide the names and emails of friends and family on the pages of the Service where you can refer people to our business customers. Referring friends and family is optional. In addition, some of the personal information may be provided by our business customers’ staff members when they sign up for our referral and loyalty Service as a business customer.

Please see “Access and Rights regarding Personal Information” to see more information about your rights regarding your personal information.

USE OF INFORMATION

Middle Integration Platform Uses:
We may use your personal information as an employee or representative of our business customer:

to respond to your inquiries and fulfill your requests and process your business customer account,

to send you communications that we believe may be of interest to you, including any communications for purposes of marketing to the business customer you are associated with,

for our business purposes, such as data analysis, fraud monitoring and prevention and security, developing new products, enhancing, improving or modifying our Services, identifying usage trends, and determining the effectiveness of our Services

to measure and report on the success of marketing campaigns, and in other ways with your consent.

Referral and Rewards Platform Uses:
We may use personal information:

to respond to your inquiries and fulfill your requests and process users’ accounts,

to track loyalty points in the loyalty program of the referral and loyalty Services and to reward the points,

to send you communications that we believe may be of interest to you, including any communications for marketing purposes related to the Services,

to contact friends and family members referred through our referral and loyalty Services,

to allow business customers’ staff to log in and manage their business’ loyalty program in our referral and loyalty Services,

to allow our business customers to engage developers to retrieve data for business intelligence, loyalty point redemption, and displaying loyalty program information in other applications,

to allow our business customers to share your information with their partners and service providers at the business customer’s direction or request,

for our business purposes, such as tracking conversion of prospective customers into actual customers, data analysis, fraud monitoring and prevention and security, developing new products, enhancing, improving or modifying our Services, identifying usage trends, and determining the effectiveness of our Services,

to show you the closest establishment to redeem an offer that you are considering for redeeming your points, 

to measure and report on the success of marketing campaigns, including to track conversion of prospective customers to actual customers, and in other ways with your consent.

For both our Middle integration platform and our Perkvill referral and loyalty platform,
we use your information:

to send administrative information to you,

to operate, improve, analyze and manage the Services,

to ensure the Services function properly,

to track your use of the Services to improve the design and functionality of the Services,

to diagnose server problems and administer the Services via your IP Address (a number automatically assigned to the computer or device that you are using by your internet service provider), and

as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process and our legal obligations; (c) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (d) to enforce our terms and conditions; (e) to protect our operations and the security of our Services; (f) to protect our rights, privacy, safety or property, and/or that of you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.

For both our Middle integration platform and our Perkville referral and loyalty platform, we may partner with certain third parties to collect other information to engage in analysis, research, and reporting of Service usage patterns. These third parties may also deliver advertising to you on other websites and applications, based on your activity on our website and other websites over time. These third parties may set and access cookies on your computer or other devices, and may also use web logs or web beacons. See “Cookies and Similar Technologies” and see “Choices” to opt out of interest-based advertising by third parties from cookies.

INFORMATION DISCLOSURE

Middle Integration Platform Disclosure:
Your personal information may be disclosed:

to our third-party service providers who provide services such as email management, hosting and storage, web serving, technical services, marketing analytics and other services, and

directly by you in your account and other services to which you are able to post information and materials yourself.

Perkville Referral and Loyalty Platform Sharing:
Your personal information may be disclosed:

to our business customers and their employees and services providers to use our Services and to analyze the effectiveness and performance of our Services,

to our third-party service providers who provide services such as email management, transaction management, campaign measurement, hosting and storage, web serving, performance tracking and reporting, technical services, marketing analytics and other services,

directly by you in your account and other services to which you are able to post information and materials yourself (including, without limitation, our and your social media pages), and

to our business customers’ partners and service providers at their direction or request.

to our business customers’ partners and service providers at their direction or request.

to our business customers’ partners and service providers at their direction or request.

Perkville’s business customers may direct Perkville, as their processor and service provider, to disclose your information to the business customer’s partner or service provider in order to facilitate targeted advertising by the business customer and their partner or service provider. Perkville relies on the business customer to provide you with legally required disclosures and opt outs or obtain legally required consents for such disclosure and targeted advertising. 

For both our Middle integration platform and our Perkville referral and loyalty platform, we may disclose information:

among our affiliates for the purposes described in this Privacy Policy (Perkville, Inc. is the party responsible for the management of the information jointly used by it and its affiliates),

to another business at our business customer’s direction or request,

to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), 

as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process and our legal obligations; (c) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (d) to enforce our terms and conditions; (e) to protect our operations and the security of our Services; (f) to protect our rights, privacy, safety or property, and/or that of you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity, and

to other companies with your consent.

We may also disclose other information that we collect, including aggregate information such as total number of Perkville users of our various Services and total number of Perkville business customers of our various Services, as we consider necessary to develop, grow, and provide our Services.

We ask our service providers to confirm that their privacy and security practices are consistent with ours, we provide our service providers with only the information necessary for them to perform the services we request, and we ask our service providers not to use such information for any purpose other than as specified by Perkville.

Our third party service providers who provide usage analytics for our Services may also use your information to provide you with more personalized advertising content on other websites and applications. To opt out of interest-based advertising by third parties, see "Choices.”

Perkville may offer online resources that facilitate communications among the Perkville community and others. Whenever you voluntarily post information to any public forum offered by Perkville, such information along with your user name can be accessed by other users of the forum, including members of the public if the forum is open to the public.

COOKIES AND SIMILAR TECHNOLOGIES

We and our service providers use cookies in connection with our Services. A cookie is a small data file that is stored on your computer’s or mobile device's memory. Some cookies help you navigate our Services, including setting a cookie to remember your login details. Our cookies are linked to your login information so that you can use the Services on your device throughout the day without logging in each time you visit the Services. Cookies also help us better understand the effectiveness of our Services (for example, by tracking the way in which you respond to, select and interact with our Services and tracking the conversion of our prospective customers into actual customers). Other cookies collect information about how you use our Services, which highlights areas we can improve, including navigation. If you submit an inquiry through our Service and provide your name and email and similar information, that personal information will not be tied back to you for interest-based advertising purposes across websites and applications, however, you may receive email marketing communications from us, and you may receive interest-based advertising from third parties based on cookies dropped on your device by our third party service providers. To opt out of marketing communications and interest-based advertising by third parties, see “Choices.”

We and our service providers may also use "pixel tags," "web beacons", "clear GIFs" or similar means (individually or collectively "Pixel Tags") to analyze usage patterns of consumers. A Pixel Tag is an electronic image, often a single pixel, which is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a web page or in a mobile application and may be associated with cookies on your hard drive. Some Pixel Tags are used to drop cookies on users’ devices. Pixel Tags allow us to count users who have visited certain websites and applications of our business customers, and pages within such websites and applications, and to help determine the effectiveness of marketing campaigns.

Third parties may use cookies or similar technologies on visitors of our Services to serve interest-based advertisements to such visitors when they visit other websites and mobile applications. Our business customers that participate in the Services may also utilize cookies or similar technologies to monitor the performance of their referral and loyalty program in our Services and to engage in targeted advertising or allow their partners, service providers or other third parties to engage in targeted advertising. The collection of information through cookies or similar technologies by such third parties will be governed by such third parties’ own privacy policies and principles, which Perkville does not control.

For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.eu. To read about your choices with regard to Perkville’s and third parties’ uses of cookies in our Services, please see “Choices.”

We do not track users when they cross to third party websites, and we do not provide targeted advertising to them, and therefore we do not respond to Do Not Track (DNT) signals.

LEGAL BASIS RELIED ON FOR PROCESSING PERSONAL INFORMATION OF EUROPEAN DATA SUBJECTS

Data Processor. Perkville is a data processor with respect to personal data collected or received by us when we receive such information from our business customers (the data controllers) that make their data available for use via our Services, or you after you have signed up for our Service via our business customers.

Where we operate as a data processor, we are processing the data on behalf of our business customers (the data controller(s) of the data) based on their instructions, and it is the responsibility of the data controller to establish an appropriate legal basis for the processing of the data. For example, we may process data when the individual has consented to such processing. On certain occasions we may rely on another lawful basis as a basis for processing, such as when it is in our business customers’ and our legitimate interests to do so and when these interests are not overridden by the individual’s data protection rights. Those legitimate interests include performing our obligations with respect to providing the Services and improving our Services.

Data Controller. On certain occasions, Perkville is a data controller. Perkville is a data controller with respect to any personal data collected or received by us when we receive personal information (such as name, phone number, and email address) through our Perkville Pages without being connected to any business customer. In this case, the data controller is Perkville, Inc. Where Perkville operates as a data controller, we rely on legitimate interests to process personal data to provide our Services. On certain occasions, we may also rely on the consent of the individual to process personal information (for example, in some jurisdictions, when the user inputs personal information into the Perkville Pages and consents to receive marketing communications). On other occasions, we may process personal information when we need to do this to fulfill a contract or where we are required to do so by law.

RETENTION

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law, or an individual requests deletion in accordance with applicable law. See “Access and Rights regarding Personal Information.”

CHOICES

Opting Out of Marketing

We give you choices regarding our use and disclosure of your personal information for marketing purposes.

You may opt-out from receiving electronic communications from us. If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these marketing related emails by contacting us at privacy@perkville.com or by clicking on the opt-out link within the email message that you receive from us.

Please also note that if you do opt-out of receiving marketing-related emails from us, we may still be required to send you administrative messages relating to the Services from time to time.

Opting Out of Perkville’s cookies

You may disable cookies, including Perkville’s cookies, by modifying the settings in your browser. However, please note that if you delete or disable cookies, you will not be able to stay logged in to the Services to interact and earn loyalty points and, as a result, the Services will no longer be available to you. Our cookie is required to provide our Services. Our cookies are linked to your login information so that you can use the Services on your device throughout the day without logging in each time you visit the Services.

Opting Out of Interest-Based Advertising by Third Parties from Cookies 

Some third parties who use cookies when you visit our websites, have opt out mechanisms either directly from their website or through an industry-developed web page. If you go to optout.aboutads.info or www.aboutads.info/choices, you can learn how to exercise choice regarding the collection of information about your online activities over time and across multiple third-party websites, online services, devices, and applications for interest-based advertising purposes. When you opt out of receiving interest-based advertising from third parties, note that the opt out only applies to the applicable browser in which you set it.

For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.eu.

Third parties may also combine and use information from websites or applications on your current browser or device with information from your other browsers or devices for advertising purposes. To opt out of such practices, please follow the instructions above for opting out on each of your browsers, and also opt out on each of your mobile devices. Please note that you will need to opt out separately on (1) each of your browsers and (2) each of your mobile devices to ensure that information collected on a particular browser or device is not used on another browser or device.

Opting Out of Use of Precise Location

To disable the collection of precise location information from your mobile device through mobile applications,

you can access your mobile device settings and choose to limit that collection.

ACCESS AND RIGHTS REGARDING PERSONAL INFORMATION

If you would like to access, correct, or delete the personal information that Perkville maintains about you, you may contact us at privacy@perkville.com.

California, Virginia, Colorado, Connecticut, and Utah Users: If you are a resident of California, Virginia, Colorado, Connecticut, or Utah, see the Additional US Privacy Notice below.

Europe: If you are a resident of the European Economic Area, the United Kingdom or Switzerland, you have specific legal rights in regard to the handling of your information. You have the following rights with respect to your personal information:

The right to be informed,

The right of access,

The right to rectification,

The right to erasure,

The right to restrict processing,

The right to data portability,

The right to object,

The right to lodge a complaint with a supervisory authority, and

Rights in relation to automated decision-making and profiling.

To exercise these rights as a resident of the European Economic Area, the United Kingdom or Switzerland, email privacy@perkville.com or contact our applicable European or UK representative under “Contacting Us” below.

For data that we process on our business customers’ behalf, you may also go directly to the business customer and exercise these rights.

For customers using our referral and loyalty program, you may deactivate your account by changing your preferences in the user settings page of those Services. You may also disconnect or reconnect to each business customer via the user settings page of those Services.

For employees or representatives of business customers that use our Middle integration platform, you may also email us at support@perkville.com.

THIRD PARTIES

This Privacy Policy does not cover, and we are not responsible for, the privacy or data practices of or processing of data by any third parties (except as required by applicable law), including any third parties operating any site or service to which our Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates. These third parties are bound by their own privacy policies.

Except as required by applicable law, we are also not responsible for the privacy or data practices of or the collection, processing or use of data by our business customers and their partners and service providers, or our service providers, app developers, app providers, ad servers, social media platform providers, operating system providers, wireless service providers or device manufacturers, including any personal information you disclose to other organizations through or in connection with the Services.

SENSITIVE INFORMATION

We ask that you not send us, and you not disclose to us, any sensitive information (e.g., social security numbers or other government identifiers, information related to racial or ethnic origin, political opinions, religion or other beliefs, medical or health conditions, criminal background, trade union membership, or sexual orientation) on or through the Services or otherwise to us, except where such information is legally required.

CHILDREN

Our Services are not intended for, nor directed to, individuals under the age of 18, and we request that these individuals, and any other individual considered a minor under applicable law, not provide personal information through any of our Services. 

Some of our business customers who use our loyalty platform may disclose personal information of minors to us when those minors’ information is included with their parents’ or guardians’ account information at the business customer. We ask our business customers not to share personal information of minors with us, but if they do, the business customer is responsible for obtaining any required authorized from the parents or guardians of the minors. 

If you become aware that your child has provided us with personal information without your consent or a business customer of ours has provided us with personal information of your child without your consent, or you otherwise wish to withdraw your consent, please contact us at privacy@perkville.com. If we become aware that a child under 18 (or under the legal age under applicable law) has provided us with personal information without parental consent, we take steps to remove such information.

SECURITY

We have implemented reasonable physical, organizational, administrative, and technical security measures appropriate to the nature or sensitivity of the personal information processed, the purpose of the processing, the quantity and distribution of the personal information processed, and the medium on which personal information is stored, in order to protect the personal information from unauthorized or illegal access, destruction, use, modification, copying, or disclosure and to protect the confidentiality, integrity, and accessibility of personal information

INTERNATIONAL INFORMATION TRANSFERS

Please be aware that the information we collect, may be transferred to and maintained on servers or databases located outside your state, province, country, or other jurisdiction, where the privacy laws may not be as protective as those in your location. Please be advised that we process and store information in any country where we have facilities and/or employees, including the United States, or in which we engage service providers. Your consent to this Privacy Policy or your use of any of the Services or your submission of your information to us or any of our business customers, represents your consent to such transfer, storage and processing outside of your country of residence, including the United States, which may have different data protection rules than those of your country of residence.

Standard Contractual Clauses. If you are located in the European Economic Area, the United Kingdom or Switzerland, we will protect your personal information when it is transferred outside of your jurisdiction by (a) processing it in a territory that provides an adequate level of protection based on its data protection laws; or (b) implementing appropriate safeguards to protect your personal information, such as relying on the European standard contractual clauses.  Perkville currently relies on these European standard contractual clauses for data transfers.

MODIFICATIONS TO THIS PRIVACY POLICY

We reserve the right to make changes to our Privacy Policy. Please look at the date at the top of this page to see when this Privacy Policy was last revised. Where required by law, we will obtain your consent to make these changes.

CONTACTING US

For any questions about this Privacy Policy or Perkville’s privacy practices, please contact us by email at privacy@perkville.com, or by mail at:

Perkville, Inc.
Attn: Privacy
C/O Port Workspaces
344 Thomas L. Berkley Way
Oakland, CA 94612
USA

General Data Protection Regulation (GDPR) – European Representative

Perkville has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to GDPR:

by using EDPO’s online request form: https://edpo.com/gdpr-data-request/

by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium

UK General Data Protection Regulation (GDPR) - UK Representative

Perkville has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to UK GDPR:

by using EDPO’s online request form: https://edpo.com/uk-gdpr-data-request/

by writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom

CALIFORNIA’S “SHINE THE LIGHT” LAW

California's "Shine the Light" law permits users of our properties 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 contact us at the contact information under Contacting Us.

Additional US Privacy Notice

If you are a California, Virginia, Colorado, Connecticut or Utah resident and we collect your personal information, this privacy notice (“Additional US Privacy Notice”) applies to you ("consumers" or "you"), except as stated below. This Additional US Privacy Notice is in addition to the information in our privacy policy above.

California individual business information: If you are a California resident, this Additional US Privacy Notice also applies to individual business information (e.g., information in your capacity as an employee or representative of any of our business customers or vendors). Workforce Policy: If you are part of Perkville’s California workforce (e.g., employees, job applicants, contractors, owners, directors, and officers of Perkville who reside in California), please see the Privacy Notice for California Company Workforce below.  Collection of Information

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, device or household ("personal information").

We may collect the following categories of personal information from  consumers:

Category
Identifiers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Protected classification characteristics under California or federal law.
Commercial information.
Biometric information.

Internet or other similar network activity.
Geolocation data.
Professional or employment-related information.

Inferences drawn from other personal information.
Sensitive personal information.


Sensitive personal information.
Examples
For example, name, email address, physical address, cookie ID, IP address, and account information.
For example, name and phone number.
For example, age and gender.
For example, consuming tendencies and histories.
For example, exercise data for users who use our loyalty program for their gym visits.
For example, browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
For example, physical location or movements.
For example, current or past job history of employees and representatives of our business customers.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
A consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.
A consumer’s precise geolocation.
Sensitive information

We collect the following categories of sensitive personal information from consumers:

your loyalty account information with Perkville as an customer of our business customer,

your account information with Perkville as an employee of our business customer,

a referred prospect’s account information with Perkville,

your location provided by your browser, your location data from IP address, and

your location when you earn and redeem transactions.

We use your loyalty account information or business account information and location-related information for the purpose of providing our services to you. 

We do not use sensitive information for the purpose of inferring characteristics about you. We do not sell your sensitive information, and we do not process or otherwise disclose sensitive information for the purpose of behavioral advertising.

To learn how to opt out of the use of your precise location generally, see “Opting Out of Use of Precise Location” under “Choices” in the general privacy policy above. 

To request that we delete your precise location, you may email us your request at privacy@perkville.com

Use of Information

We may use the personal information for one or more of the following purposes:

Fulfilling your requests.

Providing and improving the Service, including tracking loyalty points.

Sending you communications.

For our business purposes.

As we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process and our legal obligations; (c) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (d) to enforce our terms and conditions; (e) to protect our operations and the security of our Services; (f) to protect our rights, privacy, safety or property, and/or that of you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.

As described to you when collecting your personal information or as otherwise permitted in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Categories of Sources:

We obtain the above categories of personal information from the following categories of sources:

Directly from you,

Automatically collected information,

Our business customers,

Our business customers’ partners and service providers,

Our service providers, and

Information when you log in with a third party’s single sign-in.

Commitment Regarding Deidentified Information

We commit to maintain and use deidentified information in deidentified form only and we will not attempt to reidentify the information, except we may attempt to reidentify the information solely for the purpose of determining whether our deidentification process satisfies this commitment.

Information Disclosure

Disclosures of Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We disclose your personal information with the following categories of third parties:

Our affiliates.

Our business customers and our business customers’ partners and service providers.

Our service providers.

A buyer of our business.

The public, voluntarily by you.

Other third parties with your consent.

Our affiliates.

Our business customers and our business customers’ partners and service providers.

Our service providers.

A buyer of our business.

The public, voluntarily by you.

Other third parties with your consent.

We may also share your information as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process and our legal obligations; (c) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (d) to enforce our terms and conditions; (e) to protect our operations and the security of our Services; (f) to protect our rights, privacy, safety or property, and/or that of you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.

We may disclose the following categories of personal information:

Identifiers.
California Customer Records personal information categories.
Protected classification characteristics under California or federal law.
Commercial information.
Biometric information.
Internet or other similar network activity.
Geolocation data.
Professional or employment-related information.
Inferences drawn from other personal information
Sensitive personal information

No Sales of Personal Information
We do not sell your personal information.

No Targeted Advertising or Sharing for Behavioral Advertising

We do not use your information for targeted advertising. We do not act as a data controller or business of your information and then share your information to other companies for their cross-context behavioral advertising purposes. Perkville’s business customers (as data controllers and businesses) may direct Perkville, as their data processor and service provider, to disclose your information to the business customer’s partner or service provider in order to facilitate targeted advertising by the business customer and their partner or service provider. Perkville relies on the business customer to provide you with legally required disclosures and opt outs or obtain legally required consents for such disclosure and targeted advertising. 

No Profiling

We do not profile you in furtherance of decisions that produce legal or similarly significant effects concerning you.

Your Rights and Choices

California, Virginia, Colorado, Connecticut and Utah residents have specific rights about their personal information. See below for information about these rights.
If we received your information from a business customer, you will need to make the request directly with the business customer, unless the business customer has authorized us (as their service provider or data processor) to respond directly to you. 

Know, Access, and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your verifiable consumer request (see Exercising 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 share that personal information.

The specific pieces of personal information we collected about you (which will allow you to exercise your data portability right).

Correction

You have the right to request that we correct any of your personal information that we maintain about you. Once we receive and confirm your verifiable consumer request, we will correct your personal information.  

You must contact our business customers directly to correct your information that they maintain about you.

Deletion Request

You have the right to request that we delete any of your personal information that we collected from you and still retain, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Rights), we will delete your personal information from our records, unless an exception applies.

Right of No Discrimination and No Retaliation

We will not discriminate or retaliate against you for exercising any of your rights under applicable law. You have the right not to receive discriminatory treatment for the exercise of any of your privacy rights under applicable law.

Appeal Right – Virginia, Colorado, and Connecticut Residents

Virginia, Colorado and Connecticut offer their residents certain appeal rights. If we decline to take action regarding your request, we will inform you of that decision and our reasons. If we decline to take action at the direction of our business customer, you must contact business customer directly to appeal the decision.

If you reside in Virginia, you have the right to appeal our decision no later than 30 days after we inform you of our decision. Send your appeal to us via email at privacy@perkville.com with “Appeal” in the subject line of your email.  Within 60 days after we receive your appeal, we will inform you of any action taken or not taken in response to the appeal. If the appeal is denied, you may contact Virginia’s Attorney General to submit a complaint at https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint.

If you reside in Colorado, you have the right to appeal our decision no later than 30 days after we inform you of our decision. Send your appeal to us via email at privacy@perkville.com with “Appeal” in the subject line of your email.  Within 45 days after we receive your appeal, we will inform you of any action taken or not taken in response to the appeal. We may extend this period by 60 additional days if reasonably necessary. If the appeal is denied, you may contact Colorado’s Attorney General to submit a complaint at https://coag.gov/file-complaint/.

If you reside in Connecticut, you have the right to appeal our decision no later than 30 days after we inform you of our decision. Send your appeal to us via email at privacy@perkville.com with “Appeal” in the subject line of your email.  Within 60 days after we receive your appeal, we will inform you of any action taken or not taken in response to the appeal. If the appeal is denied, you may contact Connecticut’s Attorney General to submit a complaint at https://portal.ct.gov/AG/Common/Complaint-Form-Landing-page.

Exercising Rights

To exercise your rights above, please submit a verifiable consumer request to us by either:

Emailing us at privacy@perkville.com and providing your full name and email address and the request that you are making.
Submitting a web form located on our support portal and providing your full name and email address and the request that you are making.

California Individuals Acting in Business Capacity

If you are a California resident and acting in a business capacity (e.g., as an employee or other representative of one of our business customers or vendors), you may submit a verifiable consumer request by emailing us at privacy@perkville.com and including your full name and email address (including your business email address) and the type of request you are making. As a website user, you should also submit a request via the web form above to cover your personal information as a website user.

Creating an Account Not Required

Making a verifiable consumer request does not require you to create an account with us. But if you have an account with us, we may require you to make your request through your account. We consider requests made through your password-protected-account sufficiently verified when the request relates to personal information associated with that specific account.

Privacy Notice for California Company Workforce

This Privacy Notice for California Company Workforce (“California Workforce Notice”) applies solely to employees, job applicants, controlling owners, directors, officers, and independent contractors of Perkville who reside in California (“you” or “Company Workforce”).

Category
A. Identifiers.




B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).






C. Protected classification characteristics under California or federal law.






D. Commercial information.

E. Biometric information.



F. Internet or other similar network activity.
G. Geolocation data.
H. Sensory data.
I. Professional or employment-related information.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

K. Inferences drawn from other personal information.


L. Sensitive personal information.





Examples
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.

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. Some personal information included in this category may overlap with.
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).

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
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.
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
Physical location or movements.
Audio, electronic, visual, thermal, olfactory, or similar information.
Current or past job history or performance evaluations.
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 records.
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Deidentified or aggregated consumer information is not personal information under CCPA.
Social security, driver’s license, and other IDs.
 Account log in information. 
Precise geolocation.
Race, ethnic origin, religious beliefs.
Contents of emails. 
Health information.
Sexual orientation.

Sensitive Information

We collect the above examples of sensitive personal information from our Company Workforce.

We use this sensitive information for the purposes set forth in “Use of Personal Information” below. We do not use sensitive information for the purpose of inferring characteristics about you. We do not sell your sensitive information, and we do not process or otherwise disclose sensitive information for the purpose of behavioral advertising.

Sources of Collection

These are the categories of sources of your personal information that we collect:

Directly from you

Automatically

Health From service providers (e.g., third party recruiters, background check service providers, etc.)

Use of Personal Information

We may use the personal information of the Company Workforce for one or more of the following purposes:

Employees, directors and officers: We may use your information for the following purposes: identifying you, verifying work authorization, administering taxes and health, medical and other benefit plans, keeping track of your records, contacting you, facilitating payment to bank accounts, contributing to 401(k) plans, garnishing wages required by law, evaluating performance, tracking efficiency and productivity, protecting against disclosure of confidential information and trade secrets, and ensuring compliance with applicable laws and company policies.

Job applicants: We may use your information for the following purposes: identifying you, keeping track of records, contacting you, evaluating your candidacy, performing background and reference checks, and onboarding you.

Independent contractors: We may use your information for the following purposes: identifying you, administering taxes, keeping track of your records, contacting you, facilitating payment to bank accounts, evaluating performance, tracking efficiency and productivity, protecting against disclosure of confidential information and trade secrets, and ensuring compliance with applicable laws and company policies.

Legal and Other Uses: We may also use your information if we believe it is required or appropriate: (a) to prevent or stop activity that we may think is, or is at risk of being, illegal, unethical or legally actionable activity; (b) to protect our rights, privacy, safety or property, and that of you and others; (c) to protect our operations and the security of our Services; (d) under applicable law; (e) to comply with legal process and our legal obligations; (f) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (g) to enforce our terms and conditions; and (h) to allow us to pursue available remedies or limit potential damages.

We may use your information as described to you when collecting your personal information or as otherwise set forth in the CCPA.

The Company will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Disclosing Personal Information

We disclose the above categories of personal information to the following categories of third parties:

Affiliates.

Service Providers.

Buyer of our Business.

Public (voluntarily by you).

Legal and other Disclosures.

Other third parties with your consent.

No Sale or Sharing of Personal Information
We do not sell personal information and we do not share personal information to other companies for their cross-context behavioral advertising purposes. 

Your Rights
Your rights include the following:

Right to know.

Right to access

Right to data portability

Right to correction

Right to deletion

Right not to receive retaliatory or discriminatory treatment


Know, Access and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your verifiable consumer request,
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 to whom we disclosed that personal information.

The specific pieces of personal information we collected about you – you can then copy and port that information.

Correction

You have the right to request that we correct any of your personal information that we maintain on you. Once we receive and confirm your verifiable consumer request, we will correct your personal information.   

 Deletion

You have the right to request that the Company delete any of your personal information that the Company collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies under applicable law.

Right of No Discrimination and No Retaliation

We will not retaliate or discriminate against you for exercising any of your rights under the CCPA. You have the right not to receive discriminatory treatment for the exercise of any of your privacy rights under the CCPA.

Exercising Your California Rights

To exercise the rights described above, please submit a verifiable consumer request as follows:

emailing us at hr@perkville.com and including your full name and email address and the type of request you are making (e.g., right to know, access, portability, correction, or deletion), or

calling us at (650) 814-0812‬.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.