Privacy Policy

Privacy Policy – iSponsor USA, Inc

This policy (“Privacy Policy”) sets out how and why iSponsor USA, Inc. (and, as applicable, iSponsor Australia Pty Ltd) (“we,” “us,” or “our”) collect, use, hold and disclose your personal information ( “information”).  

This policy applies to information we collect in iSponsor’s mobile app (“App”) and/or our website (“Website”). Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use this App or access and/or use our Website. By downloading, registering with, or using this App, or accessing and/or using our Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this App after we revise this policy means you accept those changes, so please check the policy periodically for updates.

 

Our commitment to you

We are committed to being transparent about our management of your information and take all reasonable steps to ensure our practices and procedures relating to our activities comply with any applicable state and federal privacy laws and regulations.

We do so by striving to adhere to the following principles:

  • your information will be collected, stored, used and disclosed in accordance with all applicable privacy laws;
  • your information will generally only be used where necessary for us to deliver our services or perform other necessary business functions and activities.

We will not use or disclose your information for purposes unrelated to our business’ services and activities, unless we first obtain your consent or where doing so would not breach applicable privacy laws.

By engaging with our business or by providing your information to us, you consent to our collection, storage, use and disclosure of your information, in accordance with this Privacy Policy.

Why is your information important to us?

Your information is important to us as we may require it in order to conduct our business and provide our services to: (a) customers who sign up to our App (Customers); (b) Organizations and charities that we facilitate donations to (Organizations) ; and (c) businesses/sponsors who promote their products with us and donate to Organizations  (Sponsors).  Some of the key services (“Key Services”) we provide include (but are not limited to) the following:

  • making our App available to Customers to facilitate donations from Sponsors to Organizations when the Customer purchases products at the Sponsor – in this regard, we will collect information from Customers when they create accounts in our App, set their preferences in the App and provide us other information via the App;
  • providing marketing services to Sponsors who sign up with us – in this regard, we will collect information from Sponsors when they sign up with us (whether via our website, by email, or in-person and potentially via the App in the future), when Customers purchase products at the Sponsor and when the Sponsor interacts with the App or contacts us to assist in marketing activities;
  • facilitating donations by Sponsors to Organizations when Customers purchase products from Sponsors – in this regard, we will collect information from Organizations  and Sponsors to facilitate these payments and will pass on information relating to Customers to the Organizations  so that they know who is donating money to them;
  • continually enhancing and improving our offering to our Sponsors, Organizations and Customers and contacting them to let them know of any new product offerings or benefits we can provide to them –  in this regard, we strive to continually improve our business and the services we offer and will collect information from Sponsors, Organizations  and Customers via the App, in person, over the phone and via email to achieve that goal;
  • complying with all applicable laws and regulations and our obligations to Sponsors, Organizations and Customers; and
  • engaging with service providers or Sponsors as needed, from time to time, to allow us to conduct our activities, including those referred to above.

Our Key Services may also include any functions or purposes that we may specify to you at the time of requesting the information, as well as any other functions or purposes for which you provide us the relevant information.

We may also need information to perform functions that are incidental to, or are otherwise reasonably necessary for, us to operate our business or provide our Key Services.

In order to achieve the above, we rely on you to provide us with the most accurate information to enable us to provide you with continually improving services and support.

Collecting your information

The types of information we may collect, hold, use or disclose will depend on your dealings with us.  Examples of the types of information we collect are set out below.

Information you provide to us directly:  we may collect and hold information you provide to us directly.  For example, such information may include:

  • Contact information: names (such as a Customer’s name who creates an account via our app), addresses (such as postal or email addresses), phone numbers and details of any social media or networking profiles;
  • Payment information: bank accounts details, credit or debit card details (such as for Customers who provide their credit card details via the App so that we can match purchases made by them with a Sponsor and facilitate a donation from the Sponsor to the Organization) and associated transaction details.
  • Demographic information: sex, gender, dates of birth, age, nationality, titles or languages.

Information from Third Parties.  We may collect information about you from third parties, such as where a Customer purchases a product at a Sponsor’s business and our payment providers notify us that the Customer purchased a product at the Sponsor’s business (as this is how we match Customer purchases to the relevant Sponsor and the desired Organization).

Information we create using your information:  We may develop information using your information.  For example, where you make a complaint, we may develop a record relating to the complaint which may contain your information.

Information we collect automatically: We may collect information about you automatically when you visit our websites or access the App, such as your IP address and device type.

Public information:  We may collect information from publicly available sources.

How do we collect your information?

Information we request

Ordinarily, we may collect information from you through in-person discussions (e.g. when we speak to a Sponsor about marketing matters), email, telephone, web queries (e.g. when you interact with our website), via the App, online application forms, contracts, event registration platforms, and social media networking platforms (such as Instagram and Facebook). We may also collect information if and when you report a problem or seek technical support with the Website or App.

You have the option not to provide any information that we request.  Depending upon what information you do not want to provide, we may not be able to deal with you further on a particular matter or permit you to access particular services we offer, including but not limited to Key Services.  If you make a complaint but refuse to provide your contact information, then we may not be able to process or escalate your complaint. Where you provide us with information on request, we do so on the understanding that you consent to our collection because you have this option to refuse to provide that information.

You may have the option not to identify yourself or identify yourself by a pseudonym.  However, this is not generally practical for us as we need to know who you are in order to contact and liaise with you and to ensure that you are authorized to provide credit card information to us.  For example, if you wish to use our App, we will need to know who you are so that we can allow you to access the App to its fullest extent, but we have designed the App so that you can include a nickname (which may be a pseudonym) where your name appears on donation leader boards or the like.  However, we still need your legal name when you create an account with us, otherwise we may not know who to contact in the event of a dispute.

Where we collect information about you from someone other than you, this is generally because it would be unreasonable or impracticable for us to do so.

Information we do not request

Sometimes you may voluntarily provide us with information that we have not requested.  If this happens, we may use and disclose the information in order to determine whether we could have collected the information had we requested it.  If we consider that we could not have collected the information, then we may either destroy or de-identify that information as soon as reasonably practical where required by law.

Please be aware that, based on the other apps on your mobile device, software on your computer, or other websites accessed, third parties may use tracking technologies to collect information about you when you use our App or visit our Website in a manner that is not authorized by us. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content, or use it for other purposes. 

By using our Website and/or App, you acknowledge that we do not control third parties’ tracking technologies (e.g. third party “cookies”) or how they may be used, and waive any claims against us related to third-party use of information that are outside of our reasonable control. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Holding your information

Your information may be stored in hard copy, electronically or both.  We do not adopt or use any identifiers that a government agency may have assigned to you.

Electronic information may be stored on our computer systems and networks and on our customer relationship management platform, our accounting platform and our email platform.  Our digital systems are protected by mechanisms which may include firewalls, audit logs, scheduled password changes, internal access limitation processes and internal monitoring, depending on the relevant system. 

Where we store your information, we take reasonable steps to ensure it is protected from misuse, interference, loss or unauthorized access, modification or disclosure.  However, we cannot guarantee that this will never occur.  If a serious data breach occurs, and we believe your information has been compromised, we will assess the breach as soon as we become aware of it and take all reasonable and necessary steps as prescribed under applicable privacy laws. 

We also take reasonable steps to destroy or permanently de-identify information that we no longer need for any purpose where and to the extent required by law.

Retention of information

The amount of time we may keep your information will depend on the circumstances and whether we have an ongoing business need to retain it. We will retain your information for as long as we have a relationship with you and for a period of time afterwards where we have an ongoing business need to retain it, in accordance with our internal retention policies and practices. Following that period, we will make sure such information is deleted or anonymized where and to the extent required by law.

Using your information

We may use your information in any manner to which you explicitly consent. 

In addition, we may use your information to perform our Key Services (outlined above), or to perform any activities that are related (or in the case of sensitive information, directly related) to the performance of our Key Services or other services provided by iSponsor.  We may do these things without your prior consent where the law allows us to do so, including where it is impracticable for us to obtain your consent.

We may provide your information to regulatory authorities where required from time to time.  We may also provide your information to third parties such as our professional advisors where they are providing services to us and such information is necessary for them to provide those services. 

We may provide your information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of iSponsor’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by iSponsor about our App users is among the assets transferred.

We may use your information to enforce our rights arising from any contracts entered into between you and us, including the App and/or Website end user license agreement(s) or equivalent terms and conditions of services, and for billing and collection, or if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our Customers or others.

Do we use your information for direct marketing?

We may use your information to directly market our services, membership matters, events, publications, changes, notices or offers to you.  This marketing material may be sent by email, electronic direct marketing via our App, SMS, phone or post.  We may also use information collected about you from other individuals for these purposes where it is impracticable to obtain your consent in advance.

You may ‘opt-out’ or raise any concerns you may have regarding these messages by contacting us through our Website.

Disclosing your information

When may we disclose your information?

We may disclose your information to perform our Key Services or any activities that are related (or in the case of sensitive information, directly related) to the performance of those Key Services.  This may include disclosing information to third-party service providers that we engage such as those that provide our cloud-based computing systems.  We may also disclose information to external contractors (e.g. IT Contractors), but only where those contractors are accessing our records generally to help us with any issues we are having.

If you are a Customer, we will disclose limited information about you to Organizations that have received donations from your purchases with Sponsors, such as the amount of the donation, your nickname in the App and your profile photo.

We will not otherwise disclose information unless we believe we have reasonable grounds to do so or that we reasonably believe you have provided your authorization. You should be aware however, that we may be required to disclose information without your consent in order to comply with any court orders, subpoenas or other legal process or investigation including by tax authorities, if such disclosure is required by law. Where possible and appropriate, we will attempt to notify you if we are required by law to disclose your information.

Transaction Data

If you enroll in the App, iSponsor and its third party service providers (Fidel, the Rakuten Card Linked Offer Network, or other such service providers chosen by iSponsor at its discretion) (“Service Providers”) will collect and monitor information regarding the transactions that you make on linked credit cards or payment methods, as described in our applicable Terms and Conditions. This information is referred to as “transactional data” and is treated differently than your personal information in certain instances. For example, if you register a payment card (“Linked Card”) in connection with transaction monitoring, you authorize us to share your payment card information with the applicable payment network(s), including, as applicable, Visa, Mastercard and American Express or such other credit cards as iSponsor accepts (“Payment Networks”) so the applicable Payment Network(s) is or are informed of the registration of the Linked Card as a part of iSponsor’s services. You authorize the applicable Payment Network(s), including iSponsor, to monitor transactions on your Linked Card(s) to identify eligible transactions in order to determine whether you have qualified for or earned Contributions for an Organization (“Eligible Transactions”), and for the Payment Network(s) to share such transaction details with us to enable your Linked Card(s) transactions to be Eligible Transactions. You may opt-out of transaction monitoring on the Linked Card(s) at any time by either deleting the Linked Card(s) in your account settings.

Notwithstanding anything to the herein or in the iSponsor’s Terms and Conditions, iSponsor and its third party Service Providers will use transaction information solely as follows:

  • Use transaction data such as transaction amount, transaction time and merchant location to confirm an Eligible Purchase or return to match transactions to confirm whether your purchase qualifies for Contributions to an Organization or such entity’s own rewards.
  • Share transaction data with the participating merchant where a transaction occurred as needed for the merchant to confirm a specific transaction occurred. For example, the date and amount of your purchase and the last 4 digits of your card number so the merchant can verify your purchase with its records if there is a missing or disputed transaction;
  • Provide participating merchants or third party Service Providers aggregated and anonymized information relating specifically to registered card activity solely to allow participating Organizations, merchants and third-party Service Providers to assess the results of their involvement with iSponsor and/or any promotion or sponsorship; create a record of the transaction data and thereafter maintain and use data in connection with iSponsor’s App or Website;
  • Provide information in order to respond to a request from government authority or a payment organization involved in a transaction with you or a merchant.

You authorize the sharing, exchange and use of transactional information described above and herein by and among iSponsor and iSponsor’s third-party Service Providers, applicable Payment Networks and applicable merchants.

Transaction Monitoring

By registering a payment card in connection with transaction monitoring, you authorize iSponsor to share your payment card information with the applicable Payment Network so it knows you are enrolled. You authorize iSponsor and the applicable Payment Network to monitor transactions on your registered card(s) to identify qualifying purchases in order to determine whether you have qualified for or earned an offer linked to your payment card or Contributions related to an Eligible Purpose, and for the applicable Payment Network to share such transaction details with iSponsor and participating merchants, to enable your card-linked offer(s), Contributions and other target offers that may be of interest to you. You may opt-out of transaction monitoring on the Linked Card(s) you have registered by navigating to your settings menu to remove your Linked Card(s).

How can you access and correct your information?

It is your responsibility to ensure that the information you provide to us is accurate, complete and up-to-date. We may periodically, review your information to ensure that it is accurate, up-to-date, complete and relevant.  Where we have reason to believe that your information may not be accurate, up-to-date, complete or relevant then we may either attempt to contact you to correct the information or deidentify or destroy the information as required by law.

You may request access to the information we hold about you, or request that we update or correct any information we hold about you or ask us to restrict or cease processing your information or even delete your information, by setting out your request in writing and sending it by contacting us through our Website.

Where you make a request to access your information, we will do our best to respond within a reasonable period.  While we may allow access and provide the means by which you can access your information, we may refuse the request where we are entitled to do so under the Privacy Act or at law.  In this event, we will tell you the grounds for this refusal as well as suggested steps which may allow you to access your information in the circumstances of our refusal.  You may complain about this refusal by making a complaint as set out below.

Your privacy concerns and making a complaint.

Contacting Us

If you have any concerns or are unhappy about how your information is handled, please contact us at:

 

Email: support@isponsor.co

Telephone: +1.716.697.8177

Post: iSponsor USA, Inc.

360 North Pacific Coast Highway, Suite 2000, 

El Segundo, California 90245, USA

 

Upon receipt of your concerns we will designate an individual within our Organization who will liaise with you regarding the complaint and how it can be resolved.  We endeavor to provide a response to your complaint within 30 days of receipt.

Children Under the Age of 16

The App and Website are not intended for children under 16 years of age, and we do not knowingly collect personal information from children under 16. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at +1.716.697.8177.

California Residents

If you are a California resident and have an established business relationship with us, you can request a notice disclosing the categories of personal information we have shared with third parties, for the third parties’ direct marketing purposes , during the preceding calendar year pursuant to California’s “Shine the Light” Act. To request a notice, please submit your request to us at:

Email: support@isponsor.co

Telephone: +1.716.697.8177

Post: iSponsor USA, Inc.

360 North Pacific Coast Highway, Suite 2000, 

El Segundo, California 90245, USA

Do Not Track: We do not recognize or respond to browser-initiated Do Not Track signals, as the internet industry currently is still working on Do Not Track implementations and solutions.

Changes to this policy

This policy will be routinely reviewed to ensure it is accurate, up-to-date and complies with any and all updates under applicable US privacy law. The current policy is published on our website or can be obtained by contacting us using the information above.

This policy was last reviewed and updated 3 August 2022.

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