LAST REVISED: 4/19/2024
We know that your privacy is important to you, and we work hard to earn and keep your trust. Flaunt Software, Inc. (collectively with its subsidiaries, “Flaunt,” “Company,” “we,” “us,” and “our”) respects your privacy and is committed to protecting your privacy through our compliance with this Privacy Policy (the “Policy”).
This Policy describes:
This Policy applies to information we collect through Flaunt Services or in emails and other electronic messages between you and Flaunt, and information gathered when you interact with our advertising on third-party websites and/or services if such advertisements reference or link to this Policy.
This Policy does not apply to information collected by us offline or through any other means or information collected by any third party through any application or content (including advertising) that may link to or be accessible from Flaunt Services (for further information, see below, “Third-party Websites and Services”).
Please read this Policy carefully to understand our practices regarding your information and how we will treat it. If you do not agree with our policies and practices, then please do not use Flaunt Services. By using Flaunt Services, you agree to the terms of this Policy. This Policy may change from time to time (see below, “Changes to this Policy”). Your continued use of Flaunt Services after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.
This Policy should be read in conjunction with any applicable Terms of Use, into which this Policy is incorporated by reference.
Flaunt provides services to other companies (the “Flaunt Customers”) that allow you to interact with such Flaunt Customers, to receive incentives, engage on social platforms, and avail certain benefits from such Flaunt Customers (the “Incentives”). Only you can choose to participate in such programs, and only you can choose to sign up to engage with such Flaunt Customers, to receive Incentives. You do this by providing us with your Personal Information as described in this Policy. You do not have to sign up to receive or avail any of the Incentives, and any Incentives are solely at the Flaunt Customers’ discretion.
To ensure that we provide you with the best possible experience, we will store, use, and share personal information about you in accordance with this Policy. Personal information is information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user, household or device (“Personal Information”). In particular, we may collect the following categories of Personal Information from users of Flaunt Services:
We obtain the categories of Personal Information listed above from the following categories of sources:
Directly from you. For example, when you:
Indirectly from you. For example, through information we collect from you in the course of providing our services to you.
Directly and indirectly from interaction with Flaunt Services. For example, from Flaunt Services usage details that are collected automatically. For more information on automatic information collection, please review the “Automated Information Collection” section below.
Often, Flaunt collects information under the direction of its clients, and has no direct relationship with the individuals whose Personal Information it processes. Flaunt collects third party information when a customer connects an integration to our platform. This information is retained for the life of the contract, even if the integration is disconnected.
The information that you provide in each case will vary. In some cases, you may be able to provide Personal Information via email or free text boxes, such as contacting Flaunt to request further information. When providing your Personal Information, please provide only relevant information and do not provide unnecessary sensitive information, such as Social Security numbers, credit card information or other sensitive personal data, unless required for our services.
Additionally, we may ask you to create a username and password that should only be known to you. When you provide this information to us, you may no longer be anonymous. Moreover, we may receive information about you from other sources and add it to the information you have provided to us. Likewise, we may provide you with the opportunity to use integration services by logging into your existing tools. This service will authenticate your identity and provide you the option to share certain Personal Information to use with Flaunt.
In addition to the information that you provide to us, we may also collect information about you during your interaction with Flaunt Services. We collect this information using automated tools that are detailed below. These tools may collect information about your behavior and your computer system, such as your internet address (IP Address), the pages you have viewed, and the actions you have taken while interacting with Flaunt Services. This information may be stored in log files. The information we collect automatically is only statistical data and does not include personal information. It helps us to improve Flaunt Services and to deliver a better and more personalized service, including by enabling us to:
Some of the tools we use to automatically collect information about you may include:
(a) Cookies. A “cookie” is a small data file transmitted from a website to your device’s hard drive. Cookies are usually defined in one of two ways, and we may use either (or both) of them:
(1) session cookies, which do not stay on your device after you close your browser, and
(2) persistent cookies, which remain on your device until you delete them or they expire.
Of course, if you do not wish to have cookies on your devices, you may turn them off at any time by modifying your internet browser’s settings. However, by disabling cookies on your device, you may be prohibited from full use of Flaunt Services features or lose access to some functionality.
(b) Google Analytics. Flaunt Services sends aggregated non-Personal Information to Google Analytics for the purpose of providing us with the ability to conduct technical and statistical analysis on the performance of Flaunt Services. For more information on how Google Analytics supports Flaunt Services and uses information sent from Flaunt Services, please review Google’s privacy policy available at https://policies.google.com/technologies/partner-sites.
(c) Web Beacons. A Web Beacon is an electronic image. Web Beacons can track certain things from your computer and can report activity back to a web server allowing us to understand some of your behavior. If you choose to receive emails from us, we may use Web Beacons to track your reaction to our emails. We may also use them to track if you click on the links and at what time and date you do so. Some of the third-party marketers we engage with may use Web Beacons to track your interaction with online advertising banners through Flaunt Services. This information is only collected in aggregate form and will not be linked to your Personal Information. Please note that any image file can act as a Web Beacon.
(d) Embedded Web Links. Links provided in our emails and, in some cases, on third-party websites may include tracking technology embedded in the link. The tracking is accomplished through a redirection system. The redirection system allows us to understand how the link is being used by email recipients. Some of these links will enable us to identify that you have personally clicked on the link and this may be attached to the Personal Information that we hold about you. This data is used to improve our service to you and to help us understand the performance of our marketing campaigns.
(e) Third-party Websites and Services. We work with a number of service providers of marketing communications technology. These service providers may use various data collection methods to improve the performance of the marketing campaigns we are contracting them to provide. The information collected can be gathered from you interaction with Flaunt Services and also on the websites where Flaunt marketing communications appear. For example, we may collect data where our banner advertisements are displayed on third-party websites.
We also use Rb2b, a third-party service that helps identify the companies visiting our website using publicly available firmographic data, IP address mapping, and cookies. Rb2b does not identify individual users but may collect technical information (such as browser metadata, region, or referral source) to help us optimize business outreach and analytics efforts.
(f) Behavioral Targeting and Re-Targeting. We partner with third parties to manage our advertising on other websites and or services. Our third-party Flaunt Customers may use technologies such as cookies to gather information about your interactions with Flaunt Services and other websites or services in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt out by sending an email to privacy@flauntloyalty.com. Please note this does not opt you out of being served ads. You will continue to receive generic ads.
The information we gather and that you provide is collected to provide you information and the services you request, including any Incentives you want to receive from Flaunt Customers. These may include:
Duration. The length of time Flaunt intends to retain Personal Information, is for as long as reasonably necessary to carry out Flaunt’s intended business purpose for such information, and in accordance with applicable law.
We may disclose your Personal Information to a Flaunt Customer, or our service providers for a business purpose. When we disclose your Personal Information to a Flaunt Customer, we do so at your direction. When we disclose your Personal Information to a service provider, we enter into a contract with such service provider(s) that describes the purpose and requires the service provider to both keep that Personal Information confidential and not use it for any purpose except for the purposes set forth in the contract.
In the preceding twelve (12) months (or a time period prescribed by applicable law), we may have disclosed the following categories of Personal Information for one or more business purposes:
We may disclose your Personal Information for a business purpose to the following categories of service providers and:
Except as described in this Policy, we will not share your information with third parties without your notice and consent, unless it is under one of the following circumstances:
Legal Reasons.
Sale of Business or Merger. There are circumstances where Flaunt may decide to buy, sell, or reorganize its business in selected countries. Under these circumstances, it may be necessary to share or receive Personal Information with prospective or actual Flaunt Customers or affiliates. In such circumstances, Flaunt will ensure your information is used in accordance with this Policy.
We want to provide you with relevant information that you have requested. When possible, we will always provide options as to what information we collect and how you can manage any preferences that pertain to such information.
If we provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed. Transactional or service-oriented messages, such as delivery confirmation messages, are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services, and are not intended for the purposes of marketing.
We will not intentionally send you email newsletters and marketing emails unless you consent to receive such marketing information. After you request to receive these emails, you may opt out of them at any time by selecting the “unsubscribe” link at the bottom of each email. Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided.
We strive to maintain and process your information accurately. We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements. We employ technologies designed to help us maintain information accuracy on input and processing.
Where we can provide you access to your Personal Information in our possession, we will always ask you for a username and password to help protect your privacy and security. We recommend that you keep your password safe, that you change it periodically, and that you do not disclose it to any other person or allow any other person to use it.
To view and change the Personal Information that you have provided to us, you can log in to your account and follow the instructions on that webpage, or contact us directly for assistance.
We do not intentionally seek to gather information from individuals under the age of sixteen (16). We do not target Flaunt Services to such individuals, and would not expect them to be engaging with Flaunt Services. We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly on the internet. If we become aware of any Personal Information that we have collected about minors, we will take steps to securely remove it from our systems.
We welcome inquiries or feedback on the services or products you might use or like to use. Any inquiries, feedback, suggestions, ideas, materials, blog posts, comments or other information you provide to us (collectively, “Submissions”) will be treated as non-proprietary and non-confidential. Your Submissions on or through Flaunt Services may be made available to others who interact with Flaunt Services. In addition, we may use your Submissions in advertising campaigns and other promotions. We may or may not use your name in connection with such use, and we may or may not seek your consent before using the Submissions for such purposes. Therefore, you should have no expectation of privacy with respect to your Submissions on or through Flaunt Services. You should not submit any content you do not wish to make available to the general public, and you must take special care to make sure your Submissions comply with our Terms of Use or other applicable agreements. All terms and conditions of our Terms of Use apply to Submissions on or through Flaunt Services. In particular, your Submissions must not violate the privacy or other rights of others. You may not use false identifying information or contact information, impersonate any person or entity, or otherwise mislead us as to the origin of any Submission.
This Policy does not apply to websites, services, or other domains that are maintained or operated by third parties or our affiliates, and websites/services that are operated by Flaunt Customers. Flaunt Services may link to Third-party Websites and Services, such as Facebook, Twitter, and LinkedIn. For example, if you click on an advertisement displayed through Flaunt Services, you may be taken to another website that we do not control. These links are not endorsements of these websites, and this Policy does not extend to such Third-party Websites and Services and the information collected on or via such Third-party Websites and Services. Because this Policy is not enforced on such Third-party Websites and Services, we encourage you to read any posted privacy policy of the Third-party Websites and Services before using the website or service and providing any information.
Your Consumer Rights Under State Privacy Laws.
State consumer privacy laws may provide their residents with additional rights regarding our use of their Personal Information.
States like California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with certain additional privacy rights with respect to their Personal Information. Personal Information we collect, AND that is subject to these state privacy laws, is collected for the commercial purpose of effectively providing our services to you, as well as enabling you to learn more about, and benefit from, Flaunt Services. To the extent afforded by applicable state privacy laws, you may exercise each of your rights as identified below, subject to our verification of your identity.
Only you, or someone legally authorized to act on your behalf, may make a request related to your Personal Information. If an authorized agent makes a request on your behalf, we may require proof that you gave the agent permission to submit the request.
Responding to Your Request. Upon receiving your request, we will confirm receipt of your request by sending you an email confirming receipt. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the Personal Information. In some instances, such as a request to delete personal information, we may first separately confirm that you would like for us to in fact delete your personal information before acting on your request.
We will respond to your request within forty-five (45) days (or the time periods required by applicable law). If we require more time, we will inform you of the reason and extension period in writing.
In some cases our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
California Specific Provisions: The following apply to California residents specifically:
To provide you with our services, we may store, process, and transmit information in the United States and other locations around the world, including countries that may not have the same privacy and security laws as yours. Regardless of the country in which such information is stored, we will process your Personal Information in accordance with this Policy.
Under the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, or “GDPR”), individuals in the EU are afforded specific rights with respect to their Personal Information, or “personal data” as defined under the GDPR. For the purposes of this Policy, Flaunt operates in some circumstances as a data controller and in others as a data processor. Any personal data we collect from you is processed in the United States and under the terms of this Policy.
Any personal data we collect from you is processed in the legitimate interest of our business and providing our services to you as the lawful means of such processing. You may always withdraw your consent to our use of your personal data as described below. We will only retain your personal data for the time necessary to provide you the information and services to which you have consented, to comply with the law and in accordance with your rights below.
When Flaunt collects your personal data directly, the Data Controller is:
NAME: Flaunt Software, Inc.
ADDRESS: 830 Massachusetts Ave, Suite 1500 Fl 3, Indianapolis, IN 46204
EMAIL ADDRESS: privacy@flauntloyalty.com
You can exercise any of the following rights, subject to verification of your identity, by notifying us as described below:
We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact for the following regions:
Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website:https://prighter.com/q/17918072814
We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact for the following regions:
Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website:https://prighter.com/q/17918072814
We use reasonable technical, administrative, and physical safeguards designed to protect your Personal Information against accidental loss and from unauthorized access, use, alteration, and disclosure. However, we can never promise 100% security. You have a responsibility, as well, to safeguard your information through the proper use and security of any online credentials used to access your Personal Information, such as a username and password. If you believe your credentials have been compromised, please change your password. Please also notify us of any actual or suspected unauthorized use.
This Policy describes our current policies and practices with regard to the information we collect through Flaunt Services. We are continually improving and adding to the features and functionality of Flaunt Services along with the products and services we offer through Flaunt Services. If we make any changes to this Policy, a revised Policy will be posted on this webpage and the date of the change will be reported in the “Last Revised” block above. You can get to this page from any of our webpages by clicking on the “Privacy Policy” link (usually at the bottom of the screen).
We value your opinions and welcome your feedback. To contact us about this Policy or your Personal Information, please contact us by email at privacy@flauntloyalty.com.
You can also send us an opt-out request at:
Flaunt Software, Inc.
830 Massachusetts Ave
Suite 1500 Fl 3
Indianapolis, IN 46204