Introduction

This Privacy Notice (commonly referred to as a “Privacy Policy”) explains how Bonfire Loyalty LLC (“Bonfire”, ”us”, “we”, or “our”), and its affiliated companies, process the Personal Information of website visitors, users of our apps, users of our platform, and the transactional information of persons who make purchases from merchants that have subscribed to our Platform.

You should read and understand this Notice because it constitutes the core of our obligations to you when you use this website, when you provide your Personal Information to us either directly or through automated processes. For your convenience we have summarized several of the most important points, which are:

• We collect and process your personal information in order to provide services to you, either as a direct customer of Bonfire, or as a customer of one of the businesses for whom we provide services.
• We also use your personal information for our own legitimate and lawful business interests, including (but not limited to): improving our websites and services, communicating information about our services through direct advertising (such as email) and indirect advertising (such as ads appearing on other websites), conducting fraud detection and prevention activities, maintaining records and communicating notices that are required by law.
• We do not sell your information.
• We may share your information with the service providers needed to deliver our services to you, but those service providers are bound by law and contract to only use your information for the purposes we specify.
• We may receive your information when we function as a service provider for other companies; we are bound by law and contract to only use your information for the purposes they have specified.
• This Notice applies to websites and mobile applications operated by Bonfire, and covers your personal information whether provided via those channels as well as any information you might provide to us when you call, email, or send postal mail to our Customer Service.
• For websites and apps that we operate on behalf of other companies, those companies will provide their own privacy notices. If they provide their own privacy notice, that company’s notice will govern how your information is processed. Please be sure to review the notice provided on the site you are using.

You are strongly encouraged to read this Privacy Notice in its entirety, not just the above highlights, so that you will fully understand Bonfire’s commitment to responsible data governance and the protection of your personal information. Please also note that this Notice may have changed since the last time you read it, so you should make sure that you have familiarized yourself with any terms that may have changed since the last time you read it.

Scope of Practices

Who

This Privacy Notice (“Notice”) applies to the activities of Bonfire Loyalty LLC, and its affiliates (“Bonfire”, “we,” “us,” or “our”). It applies to our usage of your personal data, whether you are an individual consumer (“business to consumer”) or you are interacting with us as part of your job (“business to business”).

What

This Notice describes how we collect and process your personal information (which includes “personal data” or “personal information” as defined under applicable data protection laws) and the rights you have regarding such data.

Where

This Notice applies to our collection and processing of personal data about users of our websites, mobile applications, and the services and features therein (together the “Sites”), as well as the data we collect during the course of providing our services (the “Services”). It also applies to those channels through which individuals communicate with us about our Sites and Services, whether in person, by telephone, by postal mail, e-mail, or other means.

When

On some Sites (including, but not limited to bonfireloyalty.com), we function as a Controller of your data. This means we define the purposes for which your personal information is processed, and we control the means by which your information is processed. When we act as a Data Controller, we bear the primary responsibility to you, the Data Subject, for protecting your information and honoring your rights.

When we act as a Data Processor on behalf of another Data Controller, we collect, use, and disclose certain personal information only under the Controller’s instruction, and our processing of your personal information is subject to their instructions and privacy policies. For any Site operated by us on behalf of another company, their privacy notice will appear on the site and that privacy notice will be the applicable policy.

Some of Bonfire’s Services are offered through third parties, such as restaurants and retail stores. In those cases, you will see privacy notices provided by those companies alongside the Bonfire Privacy Notice. The Bonfire Privacy Notice will apply to your usage of that Site while the privacy notice provided by the third party will apply to their use of their customers’ personal information in the delivery of their services. Please read both notices carefully to understand the differences between the applicability of one policy versus the other.

Please note: Links to third-party websites are provided solely for your convenience; when you go to those sites, your experience there is subject to the privacy notices and terms of use of those third-party sites, not ours, unless you are explicitly told otherwise.

Personal Information We Collect

We collect personal information directly from you, through third parties, or automatically through our Sites and related to our Services, subject to applicable laws as set out below. Where the personal information we collect is needed to comply with law, or to enter into or perform an agreement with you, we will inform you at the time of such data collection. If we cannot collect this data, we may be unable to register you as a client, to complete certain transactions, or provide products or services to you.

Personal Information We Collect Directly from You

• Contact information, such as name, email address, mailing address, and phone number;
• Payment and financial information, such as credit or other payment card information, and billing address;
• Shipping address and related details;
• Your resume, employment and education history, name and contact details, background details, and references when you apply to job postings or contact us about employment opportunities;
• Company and employment information when you contact us on behalf of your employer or when your employer uses one of our services;
• Unique identifiers such as username, account number, or password;
• Preference information such as product lists, order history, or marketing preferences;
• Information about your business such as company name, size, logo, or business type; and
• Demographic information, such as when you provide your age, gender, and ZIP or postal code.

Comments, Posts, Chats, and Submissions

When you submit online forms, participate in surveys, contests, promotions, or sweepstakes, join online chat discussions or post on a blog, request customer support, or submit testimonials, we collect your personal information, such as contact information, and other information you choose to share. Any information you provide in these areas may be read, collected, and used by others who access them.

Testimonials

Some of our Sites make available the ability for you to provide reviews or testimonials. With your consent, we may use your testimonial and your name, e.g., to display personal testimonials of satisfied customers on certain Sites and in print advertisements.

Location

On some Sites we collect geolocation-based information for fraud prevention purposes. With your consent, we may also collect your precise location-based information for purposes such as to help you locate a store offering our products and services in your area. You may withdraw your consent to the processing of location-based information at any time by changing the settings on your device. If you do, you might not be able to use certain features, especially when we use location-based information to prevent fraud.

Personal Information We Collect from Third Parties

Sometimes, we may collect personal information from third-party sources. For example, subject to applicable law, we may confirm your address with the postal service, or we may receive personal information about you from our clients who use our Services to provide you with incentives. Similarly, if our users choose to send a gift to a friend through our Sites, we will ask for the friend’s name and contact details.

Certain websites also may offer a referral service where users may refer other people they know to our Services, subject to restrictions under applicable local laws. If you choose to use our referral service to tell your friends about our Services, we will provide you with a referral code and signup instructions that you can share with your friends. Where permitted by local law, we conduct such referrals on an opt-out basis. If personal information about you has been provided to us and you want us to delete it, you may email us at privacy@bonfireloyalty.com.

Personal Information We Collect Automatically

We and our service providers automatically gather information about your use of the Sites and Services through cookies, web beacons, java script, log files, pixels, and other technologies, which include: your domain name, browser type, browser language preference, device type and operating system, page views and links you click within the Sites, IP address, device ID or other identifier, location information, date and time stamp, and time spent using the Services, referring URL, your activity within the Sites, and device geolocation information (where permitted by your device settings). We also collect information from analytic services, including Google Analytics, to compile and analyze information derived from the use of our Services, such as aggregate usage patterns, user preferences, peak demand times, preferred content and other information. See the “Cookies and Online Tracking” section below for details.

Use of Your Personal Information

We may use the personal information we collect for the following purposes:

• Provide Our Services: To provide our Services, operate our Sites, respond to your enquiries and fulfill your requests, process your payments, for bug and error reporting and resolution, to perform upgrades and maintenance;
• Customer Service and Support: To send you important information, such as changes to terms, conditions, and policies and/or other administrative information;
• Personalization: To personalize your experience on a Site or using the Services, such as by tailoring the content we send or display to you in order to personalize help and instructions, and to otherwise personalize your experience using the Services;
• Alerts and Required Notices: To send you messages that you have requested such as service-related alerts and any notices required by contract or applicable law;
• Marketing and Promotions: To send you marketing communications you have signed up for;
• Advertising and Referrals: To assist in advertising the Services on third-party websites and to track referrals from partner websites;
• Analytics and Improvement: To better understand how our users access and use the Services, and for other research and analytical purposes, such as to evaluate and improve the Services;
• Verify Identity and Detect Fraud: To verify your identity and/or location in order to allow access to your accounts, conduct transactions, and secure your personal information, and for risk control, fraud detection and prevention, and compliance with laws and regulations;
• Protect Our Legal Rights and Prevent Misuse: To protect the Services, prevent unauthorized access and other misuse, and where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, or violations of our Terms of Use or this Privacy Notice.
• Comply with Legal Obligations: To comply with the law or legal proceedings such as when required to disclose information in response to lawful requests by public authorities, including responding to national security or law enforcement disclosure requirements; and
• General Business Operations: Where necessary to the administration of our general business, accounting, record-keeping and legal functions.

Aggregated and Anonymized Information

We may also generate aggregated, pseudonymized, and/or anonymized information about users for marketing, advertising, research or similar purposes.

How We Disclose Personal Information We Collect

In this section, we describe the types of disclosures we make and the categories of third parties to whom we may disclose your personal information. All third parties to whom your personal information is disclosed are subject to contractual agreements that govern how your information can be used and must be protected.

Sale of Data

We do not sell your personal information to third parties. Because we do not sell your personal information, we do not provide any further detail regarding such sales, nor do we provide a process for opting out of such sales.

Affiliated Bonfire Companies

We disclose personal information among our affiliated and subsidiary companies in furtherance of the purposes set out in this Notice; their processing of your personal information is subject to the requirements and limitations contained in this Notice.

Service Providers

We disclose your personal information to certain companies that provide services to us and on our behalf and subject to our written instructions, such as payment, hosting, and other support services; these companies may be located in the United States, EU, and other jurisdictions. As noted above, we may also disclose your information to service providers who assist us in the detection or investigation of fraudulent or illegal activities, for verification of identity, and for compliance activities, such as required transaction-related reporting or to verify your address in order to accurately calculate or process tax-related matters.

Clients and Partners

Where we process personal information on behalf of our clients or partners, we process and share your personal information with that entity subject to its instructions. In such cases, the client or partner is the Controller of your personal information and we are a Processor. When we process personal information on behalf of a Controller, that Controller’s privacy notice will be presented, and their notice will apply instead of this Notice. In certain circumstances, we may operate a site jointly with another entity and both will function as Controllers; in those instances, you will see both the Bonfire Privacy Notice and the other entity’s privacy notice, and both will apply with respect to the activities of each Controller individually.

Referral Partners

We offer referral-based commission systems through third-party partners so that publisher websites may refer users to our pages to make purchases. These partners will be identified when you sign up.Your personal information collected in such cases will be owned and controlled by both Bonfire and the partner as independent data controllers. This Notice governs only Bonfire’s use of such data. The partner’s own privacy notice governs its use of the data.

Additional Disclosures

We may also disclose your personal information under the following circumstances:

• As permitted or required by law, such as to comply with a subpoena or court-issued discovery order, a warrant, a government request, or similar legal process;
• When we believe in good faith that disclosure is necessary to respond to claims asserted against us; to protect our rights; to protect your safety or the safety of others; or, to investigate or prevent fraud.
• If Bonfire is involved in a merger, acquisition, or sale of all or a portion of its assets, or in the event of a bankruptcy or dissolution of our business, your personal information may be transferred to an acquiring business or third party, including in contemplation of or related to due diligence for such business transactions, subject to any applicable restrictions under applicable laws. You will be notified by email and/or by a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
• We may disclose your data to any other third party with your prior consent.

Aggregate and Anonymized Information

We may share aggregate and anonymized information about users with certain third parties, including for marketing, advertising, research or similar purposes.

Use of Cookies and Other Tracking Technologies

We and our third-party service providers collect information automatically through cookies, beacons, pixels, tags, scripts, and HTML5, as well as log files. We, or our service providers, may combine this information with other information, including personal information we collect about you, to record your preferences, gather information about the use of our Services, identify when our emails are viewed, personalize content and ads and track information about the performance of our advertisements.

Cookies

These are small files with a unique identifier that are transferred to your browser through our websites. These technologies allow us to collect information such as browser type, time spent on our Sites, pages visited, language preferences, and your relationship with us. We can use this information to analyze trends, administer the website, track users’ movements around the website, measure the effectiveness of our communications, tailor our advertising to you, and gather demographic information about our user base as a whole. These technologies may provide us with information about devices and networks you utilize to access our Services, and other information regarding your interactions with our Services.

Pixels, Web Beacons, Clear GIFs

These are tiny graphics with a unique identifier, similar in function to cookies that we use to track the online movements of users of our web pages and our Ad Services, and to personalize content, and to identify when our emails are viewed or forwarded. Our third-party partners may use Local Shared Objects, such as Flash cookies, to embed features on our sites.

“Do Not Track” Preferences

Our Site does not recognize do-not-track signals; however, we do not use your personal information to track your online activities across different Sites. We only track your activity within a Site to the extent you log into your account. Therefore, our practices remain the same whether or not you enable the “Do Not Track” feature. In addition, some of our advertising partners, may use standard technologies, such as cookies, pixel tags, and web beacons, to collect information about your Internet activities across websites. We do not share your personal information with those services; any information we provide is in an anonymized or de-identified format.

Third-Party Analytics

We also use automated devices and applications, such as Google Analytics to evaluate use of our Services. We use these tools to gather non-personal information about users to help us improve our Services and user experiences. These analytics providers may use cookies and other technologies to perform their services on our behalf.

Marketing and Targeting Advertising

We partner with third-party ad networks and third-party ad companies to manage our advertising on other sites. Our third-party partners use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you personalized advertising based upon your browsing activities and interests.

Marketing and Newsletters

If you subscribe to our newsletters, we will use your name and email address to send them to you. You may choose to stop receiving our newsletter or marketing emails at any time by following the unsubscribe instructions included in these emails.

Third Party Targeting and Custom Audiences

We partner with certain third parties so that we can better target ads and content to our users, and others with similar interests, on these third parties’ platforms or networks (“Custom Audiences”). Subject to applicable laws, we may disclose certain information (such as your email address) with third parties and we may work with third-party ad networks and marketing platforms that enable us and other participants to target ads to Custom Audiences submitted by us and others.

Opting Out

The Service will automatically send you SMS messages with updates and other information. You may stop receiving SMS messages by replying STOP in response to any received SMS message. If you opt-out of receiving SMS messages, you may not be able to use certain Service. If you do not want to receive marketing emails from us, click the unsubscribe link in the footer of such emails.

Social Media Widgets

Our Sites include social media features, such as the Facebook “Like” and “Share” buttons, either hosted by a third-party or hosted directly on our website (“Widgets”). Please refer to the privacy policies of the relevant third-party websites or services to find out more about the collection, use, and disclosure of your information through such features. We will comply with any legal obligations placed on the use of these technologies by certain jurisdictions, which may affect how these Widgets function.

Security

The security of your personal information is important to us. We have implemented safeguards designed to protect the personal information submitted to us. Please note that no data transmission over the Internet can be guaranteed to be 100% secure. As a result, we cannot guarantee or warrant the security of any personal information that we process.

Retention

It is our policy to retain your information only for as long as is necessary to fulfill the purpose for which it was collected and processed. We will retain your information for as long as your account is active or as needed to provide you services and for as long as may be required to comply with our legal obligations, resolve disputes, maintain appropriate business records, and enforce our agreements. Even if you request for your information to be deleted, laws and regulations may require us to retain a copy of your information in our files for a longer period of time. Unless a specific applicable law requires a different retention period, most data will be retained for no longer than seven (7) years.

Image Submissions and Public Directories

Some of our sites offer you the ability to upload your own image to be used to create a personalized product. You may have the option to make these images available in publicly accessible directories. You should be aware that any information you provide in these areas may be read, collected and used by others who access them. Depending on the site, you may be able to remove that information yourself at any time. If not, you may request removal of your personal information at any time by contacting the Customer Service team for that site or App.

Your Rights

Withdrawal of Consent

Where we process your personal information based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of the processing that occurred based on your consent before its withdrawal. Please keep in mind that certain services are directly dependent upon our ability to process your personal information, so if you withdraw your consent, request for your information to be deleted, or if you otherwise object to our processing of certain personal information, those services may no longer be functional.

Object to Marketing

You have the right to object to our use of your personal information (including profiling) for direct marketing purposes.

Exercising your Rights

To exercise your rights as described in this Notice, you may contact us via the following methods:

Bonfire Loyalty LLC
ATTN: Privacy Requests
3214 N University Ave Ste 615

Provo, UT 84604
privacy@bonfireloyalty.com

We will respond to your request in accordance with applicable law, and if we are unable to comply with your request, we will provide information regarding why.

When Submitting a Privacy Request

Depending on the nature of your request, we may request further proof of your identity in accordance with applicable law. When sending a request, you can expedite this process by providing the following information with your initial inquiry:

• Full name;
• Email address associated with the relevant transaction(s);
• Postal address associated with your account or transaction;
• Product or service (for example, which Bonfire site you used); and,
• WARNING: For security reasons NEVER send any sensitive personal or financial information associated with you.

If the nature of your request in unclear we may ask you for further clarification. In the event that we require additional time to process your request (if allowed by applicable law), we will advise you of that. If you are unable to or refuse to provide satisfactory verification information, we may deny your request in accordance with applicable law. If you do not follow the procedures described in this Notice, including failure to lodge your request through the channels or processes specified above, there may be significant delays in responding to your request.

Please note that we will only respond directly to you, or your duly authorized agent (with authority documented in strict accordance with applicable law), in cases where we are the Controller of your personal information.

Protecting Children’s Privacy Online

Our Sites are not directed to children and we do not knowingly collect personal information from children under the age of sixteen (16). We request that such individuals do not provide personal information through our Sites. We reserve the right to delete the personal information and terminate the account of anyone violating this age policy.

Updates to this Notice

This Notice is subject to change, so if this is your first time reading it, please make sure it is not the last. If we make any changes to this Notice, we will post those changes on this page and revise the “Last Updated” date at the top. If we make any changes to the ways in which we process your information that could reasonably be considered material or substantial, we will make additional efforts to notify you of those changes, either by email or via a prominent notice on this Site prior to the change becoming effective. Where required by law, we will obtain your consent or give you the opportunity to opt out of such changes. Any changes will become effective when we post the revised Notice.

Contact Information

If you have any questions or concerns regarding this Privacy Notice, the ways in which your personal information is being processed, or wish to exercise any of the rights described above, please reach out to us using the contact information below:

Privacy Inquiries

Bonfire Loyalty LLC
ATTN: Privacy Requests
3214 N University Ave Ste 615

Provo, UT 84604
privacy@bonfireloyalty.com