Privacy Policy

Effective date: July 1, 2023

What does this Policy cover?

Suozziforny (“suozziforny,” “we,” “us,” or “our”). When we talk about our “Services”, we mean all of the websites, apps, and products we provide through our brands and other means.

This Policy tells you how we collect and use your personal data (also known as personal information). It also informs you about how we keep your data safe and the choices you may have, so please make sure you read it.

We want this Policy to be easy to read. Please note, all parts of this Policy apply to all the things we do. We may give further notices for some Services and places, and these should be read in conjunction with this Policy.

Our Services may contain links to other sites. We do not control these sites and we encourage you to read their privacy notices.

Our Services should not be used by individuals who are less than 16 years old.

What data do we collect, use, and share? (summary)

This section constitutes our notice at collection pursuant to the CCPA. During at least the past 12 months, we have disclosed personal data for the following business or commercial purposes:

Other disclosures: We may share your personal data with your consent or to comply with laws or other legal processes.

Sale of Personal Data: We do not sell, rent, or loan your personal data to third parties for money. However, subject to your privacy choices, we may share your data (Identifiers, Internet or Network Activity Data, and Geo-location Information sections of the above chart) to social media platforms, analytics providers, and advertising companies, and this may be treated as a “sale” under certain laws. See the How Can You Control Your Data section of this Policy for more detail on your privacy choices.

Data Retention: We keep your data for as long as we need to in order to provide you Services and to comply with our business and legal obligations. To work out how long we need to keep your data, we consider the amount of data, the type of data, the risks that unintended use or disclosure could bring, and whether we can do what we need to by using less data, and other legal reasons. When we no longer need your data for our stated purposes, we securely delete it.

Collection of Data from Children: We recognize the importance of protecting the privacy and safety of children. Our Services are not directed towards children. We do not knowingly collect data about children under the age of 16 or minors otherwise defined in local law or regulation without verifiable parental consent. If we learn that someone under 16 has given us their data, we will use reasonable efforts to remove that data from our databases.

What data do we collect?

When you use our Services, we collect and use data.

We collect this data in four main ways:

1. You give us data when using our Services (such as your name or email).
2. Data is collected automatically as you use our Services (such as your IP address).
3. We obtain data from other parties to help run our Services.
4. We use or combine the data we get to infer things about you (such as, what appears to interest you).

We collect the data needed for our legitimate purposes.

See below for more detail.

To provide our Services to you, we use data. Some of this data is personal data. That means it relates to someone we may be able to identify. We collect some of this data from you and others, and some of it we create.

Some personal data is sensitive, this includes data about race, politics, religion and beliefs, health, as well as SSN. Generally, we do not collect sensitive data but it may be necessary to use some of our Services. Where this is the case, you have a choice to provide the data (and use the Services) or not.

Data you provide to us

To use some of our Services, you need to share some of your data with us, using online forms or other means. What data we need will depend on the Service you wish to use, but it may include the following:

• Name or username
• Email
• Postal address
• Billing address

• Phone number
• Payment card
• Car make and model
• Education

Sometimes, the data we need to offer our Services is sensitive, such as:

• Military service
• National identifier, such as SSN
• Credit history
• Income and account balances

You may choose to share other data with us, such as your status, images, comments, interests, likes and dislikes, and survey answers. When giving us feedback or asking for help, you may provide us with the data you think is needed so that we can respond.

Having obtained any consent that may be needed, you may also share the data of others with us (for example, if you refer a friend to receive one of our email newsletters).

Data collected automatically

When you use our Services, we and our business partners may collect some data automatically.

The data we collect will depend on the Service you use, but it may include:

• ISP
• Source (how you got to our site)
• Clicks, page views, and other actions
• Visit length
• Cookie and other IDs

• IP address
• Device and browser data
• Replays of your sessions
• Emails you have opened

With your consent, we may also collect more precise location data.

Data we get from other sources

Depending on the Service you are using, we may obtain data from other parties. The data we get will depend on the Service you use, but it may include:

• Name
• Email
• Address
• Phone number
• Business
• Role
• Age
• Gender

• Family size
• Education
• Likely interests
• Purchases
• Off site actions (e.g., banner ads clicked)
• Public data (e.g., online posts)
• Credit reports

We may also ask for your consent to obtain data about you from other sources (e.g., financial service providers)

Data we create

We may use or combine any data we get to create new data. The data we create about you will depend on your use of our Services, but it may include:

• Approximate location
• Inferences about your interests and preferences
• Interest cohorts
• Linked devices

Please note: We do not use the data we collect to infer sensitive data about you.

Anonymous data

We may combine your data with the data of others (e.g., count of the total number of website users per day). This data we create by doing this cannot be used to single you out, it is not considered to be personal, and we do not try to re-identify you from this data.

How do we use your data?

We use your data to serve you and operate our business.

Depending on the Services you use and the choices you make, we will use your data to:

• Provide our Services and carry out your requests.
• Improve and promote the Services of us and others.
• Operate and secure our business.

See below for more detail.

Providing our Service and carrying out your requests.

When providing our Services we may use your data (as applicable):

• To register and secure your account.
• To receive and respond to calls and messages from you.
• To check your identity and eligibility for our Services.
• To help you get the best pricing and products we have.
• To direct you to the websites of our partners.
• To process transactions between you and us, or our partners.
• To personalize the Service you get.
• To keep your data updated with the best information we have.
• To provide customer service and support.
• To complete data rights requests you have made.
• To enable you to use social sharing tools.
• To track sales and get paid by our partners.

Improving and promoting the Services of us and others.

To help improve and promote our Services, and the Services of our partners, we may use your data:

• To carry out analysis and market research.
• To help present our Services clearly and in the most effective way.
• To run sweepstakes and surveys.
• To help us and our partners create better products for you.
• To process any rewards we may offer to you.
• To send updates and Service messages about your products and services.
• To let you know about our services and promotions by email, social media (e.g., Facebook), and using push notifications (where you agree).
• To let you know about the Services of other Red Ventures’ brands.
• To build, train, and augment models which help us understand your likely interests and those of other consumers.
• To target advertising to you, on this and other websites, based on data we have collected or created.
• To help us understand if and how our and others marketing works.

Please note: We do not use profiling in a way that could have legal or similar effects. 

Operating our business.

In the course of running our business we may use your data:

• To conduct tasks necessary for running our Services and business.
• To help secure our business and prevent fraud.
• To create reports for internal or external purposes.
• To comply with legitimate legal requests.
• To audit our business and processes.
• To protect the interests of our business, and those of our partners.

For other purposes not described in this Privacy Policy that you consent to (from time to time) and as otherwise permitted by law.

How do we use cookies?

Cookies are small text files and are widely used when you visit websites. We use cookies and other similar tools on our websites. They help us to see returning visitors, store data for later use, and target our advertising.

You can adjust the settings in your browser to stop the use of cookies, but some of our Services may not work if you do so. To learn more about the cookies we use and why we use them, please read our Cookie Policy.

When do we share data with others?

To offer our Services and run our business, we must share some data.

We may share data with third parties to provide our Services. For example, with the partners whose products you have selected.

We may share data with third parties whose services we use to run our business. For example, we pay for a third party to host our databases for us.

We may share data with third parties to comply with the law and defend our interests, and those of our partners. For example, we share data with lawyers, external advisors, and other professionals.

See below for more detail.

We might also share your data with third parties when:

Buying and selling assets: Sometimes we may need to share your data with a party that wants to buy our company or an asset that we own, or when we buy the assets of others. Before we do this we will make sure we appropriately safeguard your data.

Client businesses: When we collect data on behalf of our clients, we will share your data with them.

Service Providers: We may share your data with parties whose services we use to run our business. Where we use these third party services, our providers are not allowed to use our data for their own purposes.

Partner Promotions: We may offer contests, sweepstakes, or other events with third party partners. If you enter one of these, your data will be shared with the third party. Please note that they will have their own rules for using your data and you should read their policies.

Audience Measurement: We may share your data with companies who help us to learn about who is using our Services, and how they are used.

Watching videos: With appropriate consent, we might share data about what videos you watch with other companies, like advertisers or social media sites, but only if it’s allowed by the law.

Ads and marketing: With your permission (as needed), we might share data with companies that show ads, like Google, Live Ramp, The Trade Desk, and Facebook. This helps us to show you ads that match your interests. We also help other people advertise their products, so you might see their messages on our sites or other places online.

Legal requirement: We may share your data with others, if we believe the law says we have to do it, or if the government asks for it. We also need to protect our rights and the rights of our clients, so we might also share your data to get advice from lawyers and experts.

Emergencies: If we believe someone is in danger, we reserve the right to share data to help protect them.

Other people and messages: When you agree, some Services might share your data with other companies that want to send you messages about their services. They might contact you by email, phone, mail, or other ways. Please note that they have their own privacy rules too.

Anonymous data: We create and share general data about our consumers – you cannot be singled out within this data.

Data transfer 

Red Ventures has offices in different countries and we share data between and among them. This means that your data may be stored and used in another country. When this happens, we use legal controls to help ensure your data is treated in keeping with the rules of the country it was collected. However, your data may also be subject to the local laws of the country in which we are using it. This may mean that courts, the police, or other agencies may be able to access it, if their law permits.

Please note: we only share sensitive data when providing you with Services and for other purposes permitted by law.

Social features

Some of our Services let you use “Social Features” that are offered by third parties. For example, you may be able to ‘like’ or ‘share’ things on Facebook / Instagram, Google / YouTube, Linked In, Snapchat, Tik Tok, and Twitter. To use these features you may need to have an account with the provider, and you should make sure you understand their privacy practices.

If you choose to use Social Features on our Services or access our Services from Social Features, both we and the provider may have access to data about your use. If you are logged in to a provider’s services, they may be able to connect your visit with other personal data they hold about you. We (and others) may use this data to place ads based on your interests on these providers’ services. In addition, we may ask you if we can access and collect data from your accounts, and post content to your contacts for you.

When you link a Social Feature provider with an account for one of our Services, you grant us access to certain data about you to provide content and services. This access is governed by the privacy policy and choices you make with that provider.

Why we can use your data

To collect and use your data, we must have a valid reason.

These reasons vary based on what we are doing but they will normally be because:

• you have given us your consent to use your data.
• we need fulfill a contract we have with you or take steps towards forming a contract,
• it is our legal duty to use your data in certain ways, or
• using your data for certain reasons is legitimate.

See below for more detail.

We need to have good reasons to collect and use your data. Our key reasons are:

Contract: We use your data when we have an agreement with you, or when we need to do things before making an agreement.

Consent: You give us your consent to use your data in certain ways (you can change your mind later if you want).

Legal requirement: We (or another company) must use your data to follow the laws or regulations to which we are subject.

Other legitimate purposes: We have good reasons to use your data to better serve you, to help us make our services better, or to keep our business running well. Some examples include:

• Sharing data with our partners as part of our Services.
• Sharing data with partners who help us offer rewards and benefits.
• Sending you emails of your results when you use our Services.
• Getting in touch to let you know about our Services, and changes to them.
• Doing research to learn more about what people like (or don’t like) about our Services.
• Checking and improving our processes to make sure everything is done right.
• Keeping our services safe and available online.
• Stopping fraud to protect you and others.

Sometimes, we might use your data if we think it will help protect an individual (either you or another consumer)

How long do we keep your data?

We keep your data for as long as it is needed to provide you with our Services.

To determine how long we need to keep your data, we consider:

• the amount of data,
• the type of data,
• the risks that unintended use or disclosure could bring, and
• whether we can do what we need to by using less data.

In addition, we may also keep and use your data for as long as it is needed for legal or contractual reasons, dispute resolution, fraud prevention, and security.

See below for more detail.

We keep your data for as long as we need it to offer our Services to you, and for other valid business reasons, such as:

• Financial record-keeping
• Complying with the law or other regulatory requirements
• Ensuring the security and availability of our Services

When we decide how long to keep your data, we think about how much we have, what kind of data it is, the risks that unintended use or disclosure could bring, and what the law says. This means we may keep some of your data for longer than we hold other data. Of course, you have choices too – you may request that we delete or correct your data.

At any time, we may make your data anonymous, which means it can’t be linked with you.

When we no longer need to keep data for our purposes, or when we get a valid request to delete, we begin a process to safely delete the data from our systems.

How do we keep your data safe?

We take the protection of your data very seriously.

We use best practices to help keep your data safe. However, there is always some risk when storing data or sending it over the internet. As such, we cannot guarantee the security of your data, and you should know that sharing it is done at your own risk.

To the extent we store and use de-identified data, we will not attempt to reidentify the data unless permitted by law.

We work hard to keep your data safe and secure. We use tools and techniques to monitor and protect the data we collect and use about you. We also have rules in place to make sure that your data can only be used by those who have valid business reasons, such as providing our Services to you.

While we work hard to protect your data, it’s important to know that no method of sending data online or storing it is perfect. Sometimes things can happen beyond our control. If we ever need to tell you about a problem with your data, we will let you know as best we can using messages, letters, or phone calls.

If you create an account on our websites, you may need to create a password. It’s really important to keep this password to yourself and not share it with anyone. You are responsible for making sure nobody else can access your account using your password or device. If you ever think someone else might be using your account, please tell us right away so we can help.

Manage Your Information

You can make the following choices using our online form here regarding your Personal Information:

• Access to Your Personal Information. You may request access to your Personal Information that we collect on our own behalf. If required by law, upon request, we will grant you reasonable access to the Personal Information that we have about you.
• Changes to Your Personal Information. We rely on you to update and correct your Personal Information. Note that we may keep historical information in our backup files as permitted by law. If our Services do not permit you to update or correct certain information, contact us at the address described below. If we are processing your Personal Information on behalf of one of our clients, we will respond that we are operating as a Service Provider and are unable to act on your request.
• Deletion of Your Personal Information. When we collect information on our own behalf, we typically retain your Personal Information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. You may, however, request information about how long we keep a specific type of information, or request that we delete your Personal Information by contacting us at the address described below. If required by law we will grant a request to delete information, but you should note that in some situations we must keep your Personal Information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes. If we are processing your Personal Information on behalf of one of our clients, we will respond that we are operating as a Service Provider and are unable to act on your request.
• Objection to Certain Processing. When we process information on our own behalf, you may object to our use of your Personal Information by contacting us at the address described below. For example, California residents may be entitled to object, or opt-out, of having their Personal Information sold to third parties. If you are a California resident and would like to opt-out of having your information sold, please visit the following link: Do Not Sell or Share My Personal Information. We do not discriminate against California consumers who exercise any of their rights described in this policy.
• Revocation of Consent. If you revoke your consent for the processing of Personal Information, then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below.

As required by law, we will require you to prove your identity for us to process your request. Depending on your request, we will require you to provide your name, phone number, and email address at the minimum. We may require additional information to verify your identity dependent upon the sensitivity of the personal information related to your request .

If you do not want to make requests for access, deletion, or Do Not Sell using our online form, you may contact us at contact@suozziorny.com

An authorized agent may make any of the requests above by using our online form or contacting us as noted above.

We will make an appeal form available in our response to you if you are not satisfied with our decision on your request.

You can also make the following choices regarding communications preferences:

• Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to deliver newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive. If you decide not to receive promotional emails, we may still send you service-related communications.
• Promotional Mailings. If at any time you do not want to receive offers and/or circulars from us you can remove yourself from our mailing lists by emailing us (our contact information is below) with “NO SNAIL MAIL” in the subject line along with your name, address, and zip code. Please note that our mailings are prepared in advance of their being sent. Although we will remove your name from our mailing list after receiving your request, you may still receive mailings from us that had been initiated prior to your name being removed.
• Text Messages and Push Notifications. If you receive a text message from us that contains promotional information you can opt-out of receiving future text messages by replying “STOP” or “UNSUBSCRIBE.” You control on your device whether you receive push notifications.
• Cookies. You can review your settings by clicking the “cookie settings” link in the footer of most sites. Our Cookie Policy also provides more information on setting you control.

Region and Service specific notices

For additional region-specific information about our privacy practices and additional rights you may have, please see the applicable notice below:

AUSTRALIA

We acknowledge that our related companies, parents, subsidiaries, and affiliates formed under the laws of Australia or otherwise operating in Australia (including, without limitation, the entities listed below) are subject to the Australian Privacy Principles (APPs) as set out in the Privacy Act 1988 (Privacy Act).

These privacy laws place requirements on us to treat your personal information collected in line with those principles, including to disclose to you what personal information we collect about you and how we use it, to store your information securely and to allow you to exercise the following rights:

• Right of access to the personal information held about you; and
• Right of correction to correct your information when it is incorrect.

These principles and rights are reflected throughout this privacy policy. To exercise these rights, either complete this form or contact us at dpo@redventures.com and referencing your Australian privacy rights.

Third-party online advertising

In Australia, the Australian Digital Advertising Alliance (“ADAA”) has developed the Australian Guideline for Third Party Online Behavioural Advertising. More information and an opt out page to manage online behavioral advertising preferences with ADAA member companies are available at https://www.youronlinechoices.com.au/.

CANADA

Information for visitors from Canada

This Privacy Policy complies with the requirements of the Personal Information Protection and Electronic Documents Act (PIPEDA). Under Canadian law, you have a right to access any personal information we hold about you. You may ask us to access and/or correct your information by writing to us at the address below or by completing this form. Please note that we may require you to send us proof of your identity before providing you with access to your personal information. If you send us a request to access or correct information, then we will contact you within 30 days (although it may take us longer to fully respond to your request).

Our general privacy policy makes clear that we may share information with third parties, such as co-branded partners and authorized third parties. However, we will only share your information with such parties where we have your express or implied consent to do so. If you object to our sharing your information with such parties, or if you do not wish to receive marketing communications (such as emails) from us or our third party partners, then you may contact us to let us know your objection at any time.

EUROPEAN UNION / UNITED KINGDOM

European Union / United Kingdom Addendum

The following Addendum applies to users who reside in the European Economic Area (“EEA”) and the United Kingdom, the provisions of which shall prevail over conflicting provisions in this Privacy Policy for EEA/UK residents only

1. Data controller

For the purposes of data protection law, the controller is suozziforny (“we,” “us,” or “our”), and its affiliated companies, as appropriate.

2. Addendum to the types of data we collect

Generally, we collect information from people in the EEA/UK in a similar manner, and for similar legitimate business purposes, as described here as “What data do we collect?”. These include:

In addition to the information specified above, we also derive aggregated data from personal information which is used for a number business purposes. This data does not directly or indirectly reveal your identity and is not considered personal information.

3. Our legal basis for processing

Our legal basis for processing your personal data will typically be one of the following:

• Consent: You have actively given your informed consented to our processing of your personal data by completing a form on the site, or have indicated your consent with another affirmative act.
• Legitimate Interests:We have a Legitimate Interest in processing your personal data, and our reasons for it do not override your data protection rights. Our Legitimate Interests in processing your personal information are:
  • To ensure our website(s) meets the high standard of usability and security you would expect;
  • To help us identify areas for improvement;
  • To enable us to communicate effectively regarding services we offer; and
  • To enable us to process candidate applications, contacts, queries, or complaints.
• Legal Obligation: It is necessary for us to process your personal data for us or another Red Ventures company to comply with our legal or regulatory obligations.
• Contractual Obligation: It is necessary for us to process your personal information to perform the tasks associated with a contract to which you are a party, or to take steps at your request prior to you entering into a contract.

4. Your data rights

In addition to your rights of access, correction (rectification), and deletion described above in “How can you control your data?”, EEA and UK residents have certain other rights defined in the General Data Protection Regulation (GDPR) and the UK GDPR / Data Protection Act 2018.

• Consent Withdrawal:You have the right to withdraw your consent in relation to our processing of your personal data based on your consent.
  • You can unsubscribe from our marketing e-mails at any time using our e-mail preferences page, or by clicking on the “unsubscribe” link.
  • If located in the United Kingdom or European Union, you can opt out of EDAA members online advertising networks and behavioral advertising through the European Interactive Digital Advertising Alliance (EDAA)’s consumer opt-out page here.
• Restriction of processing: You have the right to request that we restrict the processing of your data in certain circumstances.
• Object to Processing: You have the right to object to the use or disclosures of your personal data.
• Data Portability: You have the right to request we transmit your personal data to you or another company in certain circumstances.

We process all requests in accordance with the law, and there may be legal reasons why we cannot fulfill all requests.

Please contact us at contact@suozziforny.com if you wish to make a request. We have one month to respond to you. You are not required to pay any charge for exercising your rights.

5. International transfers

We operate in the United States and transfer, store and process personal data outside of the EEA/UK, using applicable approved data transfer mechanisms (for example, the EU Standard Contractual Clauses and the Data Privacy Framework) to ensure your personal data are adequately safeguarded.

Data Privacy Framework

Red Ventures complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), and the UK Extension to the EU-U.S. DPF, as set forth by the U.S. Department of Commerce. Red Ventures has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

6. Cookies

As described above (“Information We Collect Automatically”), with your consent, we use cookies to help us analyze, improve, secure, and market our website and services, and to support functionality which enhances your browsing experience. You can read more about how and why we use cookies on our cookie policy.

For additional Service-specific information about our privacy practices, please see applicable notice below:

GLBA

Please click here to read our Gramm-Leach-Bliley Privacy Notice

Complaints

We would appreciate it if you gave us a chance to address any complaints you may have. You can use the details below to submit a complaint and you may also be able to raise a complaint with your local regulator.

How can you contact us?

Contact us using the details below if you have any questions about our this Policy, or would like to make a complaint.

• Email: contact@suozziforny.com

Changes to this Policy

Sometimes we need to make changes to how we collect, use, and protect your data. When we do, we will let you know by updating this policy. If the changes we make are important, we’ll also post a special notice on our website.

Any changes will usually only affect the data we collect after the new policy has been published. Any data we collected before the changes will still be covered by the old policy.

We will also let you know when we last made these changes by publishing the date we last changed it.

10/13/2023, 10:36:53 PM