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Privacy Policy

Last updated: October 11, 2023

Klip’em Inc. (“Klip’em,” “we” or “us”) is committed to protecting your privacy and to complying with data protection legislation, including the data protection regime introduced by the General Data Protection Regulation (EU Regulation 2016/679, the “GDPR”) and other applicable international consumer privacy laws. This Privacy Policy (“Policy”) explains how personal information is collected, used and disclosed by Klip’em in connection with your use of our website (“Site”), the associated services (“Service”), and when you otherwise interact with us.

1. Information We Collect

When we use the term “personal information” in this Policy, we mean information that identifies you, relates to you, describes you, or otherwise could be linked to you. In some jurisdictions, Klip’em is the so-called “Data Controller” in respect of all personal data collected and processed in relation to your engagement with Klip’em.

  1. Information you provide. We collect personal information from you when you:
    • Create an account with us
    • Contact us
    • Visit our website
    • Select or “Klip” offers that we present to you on the Site
    • Redeem a coupon or claim your chosen reward
    • Take part in any interactive features of the Service, including games, contests, and customer satisfaction and other surveys.


    We collect the following types of personal information directly from you:

    • Contact information. When you use or interact with the Services, we collect or obtain relevant contact details from you, including your first name, last name, phone number and email address.
    • Account information. When you set up an account, we collect your username and password, and other relevant information you may provide, such as your store preferences and zip or postal code.
    • Age information. You may provide us your date of birth in connection with offers for alcohol or other age-restricted offers.
    • Offer information. We collect information about the offers that you select or “Klip” on the Site. If you have not yet signed up for an account, offer information will be associated with your IP address or by using a cookie placed on your device. If you have logged in via Facebook, we will associate such offers with your Facebook ID.
    • Information regarding your purchases, including photographs of receipts, and any information contained in such receipts.
    • Other information. We collect information that you provide, such as when you contact us or complete a survey.
  2. Information we receive from third parties. When you use our Service, we also receive information about you from other third parties. For example:
    • Third Party Services. If you log in to the Services through a third-party service such as Facebook, we may receive some information about you and your use of that third-party service. For example, if you choose to log in to the Services with your Facebook account, we may receive information from these companies, such as your name and email address, age range, language, current city, friends list, and any other information you permit the social network to share with third parties. The information we receive is dependent upon your privacy settings with the social network and your permission. You should always review, and if necessary, adjust your privacy settings on your social networks and services before linking or connecting them to our Site or Service.
    • Other third parties.We also may collect or receive personal Information relating to you from:
      • Our affiliated companies;
      • Partners who assist us in fraud prevention or in connection with claims or disputes;
      • Partners with whom we work for advertising measurement, attribution, and analytics;
      • Payment processors such as PayPal.
  3. Information we collect by automated means. We and the third-party partners we use to provide the Service and maintain the Site automatically collect certain information about your device, browser, and activity when you visit our Site or use our Service.
    • Trackers such as cookies and pixels.
      • Cookies and other trackers which are essential to the functioning of our Site or the delivery of the Service, known as “essential” cookies, are automatically enabled (and do not require your consent) and cannot be turned off because they are essential to enable you to browse our Site and/or receive the Service.
      • For all other trackers, where you have provided your consent to us to use such trackers - if required by applicable laws, we (and our third-party partners, advertisers and/or advertising networks) may send one or more cookies, device identifiers, pixels or similar technologies that uniquely identifies your browser and convey information to us about how you use the Site and Service (e.g., the pages you view, the links you click, how frequently you use the Service, and other actions), and allow us to track your usage of the Service over time.
      • For more information about which trackers we use and how you can manage your cookie settings and disable certain types of tracking, please see our Cookie Statement
    • Log file and device information. We collect log file information from your browser or mobile device each time you access the Service. Log file information may include information such as your web request, Internet Protocol (“IP”) address, browser type, information about your device, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information. If you have given your consent - where required by applicable laws, we may employ clear gifs (also known as web beacons) which are used to track the online usage patterns of our users. The information allows for more accurate reporting and improvement of the Service.
    • Location information. When you access the Site, we infer your general location, for example by using your device’s IP address.
    • Analytics. We may also collect and analyze, including via our third-party analytics providers, traffic and usage trends for the Site and Service. The information may include the pages you visit, your use of third-party applications, and other information that assists us to improve the Service. If you visit our Site and Service via Facebook, we collect aggregated information about metrics.

2. Purposes For Which We Process Personal Information And The Legal Bases on Which We Rely

We collect and process your personal information (including, where legally permissible, special or sensitive categories of personal information) for the following purposes and relying on the following legal bases:

Purpose Description Legal basis
  • To provide and manage the Service.
    		•
  • We use your personal information to operate, maintain, and provide to you the features and functionality of our Site and Service, including to diagnose or fix technology problems.
    		•
  • Necessary for the performance of a contract or our legitimate interest to provide and administer our services.
    		•
  • To communicate with you.
    		•
  • We use your personal information to provide you with relevant information about us or our Service or to request information or feedback. These communications include sending you from time-to-time important updates about the Service, communications about changes to this Privacy Policy or other applicable terms and policies. Communications may include email messages.
    		•
  • Necessary for the performance of a contract or our legitimate interest in fulfilling your requests and communicating with you.
    		•
  • To process your transactions.
    		•
  • We use your information to process your coupon/rebate transactions.
    		•
  • Necessary for the performance of a contract or our legitimate interest in managing the provision of our services to customers.
    		•
  • To provide customer support.
    		•
  • We use your personal information to respond to your customer support communications and inquiries and assist you in your use of the Site and Service.
    		•
  • Necessary for the performance of a contract or our legitimate interest in fulfilling your requests and communicating with you.
    		•
  • To carry out our marketing and advertising activities.
    		•
  • If you have given your consent, we (and our partners) use your personal information to send you marketing and promotional materials and communications, including interest-based and other advertisements, and to analyze and measure their effectiveness.
    		•
  • Consent
    		•
  • To customize and personalize the Service.
    		•
  • We use your personal information to help us understand which parts of the Service are of most interest to you and customize or personalize your experience.
    		•
  • Our legitimate interest in providing a relevant and well-functioning website for the benefit of our website visitors; your consent.
    		•
  • To identify usage trends and improve the Service.
    		•
  • We use your personal information to help us (or our service providers and partners) conduct research and analytics about your use of the Service, including total number of users, number of clicks on coupons offered on our Site, traffic, usage, and demographic patterns on Site and Service, and identify usage trends. We also use your personal information to monitor the effectiveness of the Services, identify issues, test new features or changes in our features, and improve the Service.
    		•
  • Our legitimate interest in providing a relevant and well-functioning website for the benefit of our website visitors; your consent.
    		•
  • To maintain security and prevent fraud.
    		•
  • We use your personal information to (a) help maintain the security and integrity of the Services, (b) detect, prevent, investigate, and protect you, our business, our users, and others from fraud, unauthorized transactions, and other unsafe activity, and (c) protect the safety, rights, or property of any person, the public, or Instacart.
    		•
  • Our legitimate interest in promoting the safety and security generally and to protect our rights and the rights of others.
    		•
  • To satisfy our legal obligations.
    		•
  • We use your personal information to comply with applicable laws and regulations, respond to legal process, and/or respond to requests and communications from law enforcement authorities or other government officials.
    		•
  • Legal obligation or our legitimate interest in protecting against misuse or abuse of our websites or services, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes, responding to lawful requests, or for auditing purposes.
    		•

    3. How We Disclose Your Personal Information

    We may disclose your personal information to:

    • Our affiliates and subsidiaries. Other companies owned by or under common ownership as Klip’em, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this Policy.
    • Our service providers and third-party partners. Service providers and third parties that perform services on our behalf, in order to carry out their work for us. Such third parties will only act on our instructions and are contractually obliged to comply with applicable data protection provisions. They may include: cloud storage services, system hosting services, research partners, data security services, payment processing services, analytics services, legal services, and targeted advertising services.
    • Our marketing and advertising partners. Marketing and advertising partners, including social media platforms, third-party advertising networks, and other parties to assist in serving and measuring our or their advertisements.
    • Third parties, at your request. For example, you may have the option to share coupons with your friends through email, text messages, or various social media sites.
    • Third parties in connection with a sale or business transaction. Other parties in connection with any company transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third-party or in the event of bankruptcy or related or similar proceedings.
    • Third parties in connection with legal or security matters. Third parties as required to (i) satisfy any applicable law, regulation, subpoena/court order, legal process or other government request, (ii) enforce our Terms of Service, including the investigation of potential violations thereof, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect against harm to the rights, property or safety of Klip’em, its users or the public as required or permitted by law and (v) detect, prevent or otherwise address criminal, security or technical issues.

    We may also share information with others in an aggregated and anonymous form that does not reasonably identify you directly as an individual.

    4. Accessing, Deleting or Correcting Your Personal Information

    You, as a data subject, may have certain rights relating to your personal information, subject to local data protection laws. Depending on the applicable laws these rights may include:

    • right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;
    • right of rectification or erasure/deletion;
    • right to restrict processing;
    • right to object to processing;
    • right to data portability;
    • right to withdraw consent;
    • right to withdraw your consent at any time (to the extent we base processing on consent), without affecting the lawfulness of the processing based on such consent before its withdrawal.

    Account Access and Correction

    You may request access and correction to your personal information through your account settings or by contacting us at info@klipem.com.

    If your personal data is processed on the basis of legitimate interests, you may also have the right to object to the processing of your personal data.

    If the processing is based on your consent, you have the right to withdraw your consent at any time. Please note that this does not affect the lawfulness of the processing carried out on the basis of the consent until the withdrawal.

    You can make use of any of your rights by contacting us at info@klipem.com. We will require you to verify your identity and to specify what information you require.

    Account Deletion

    If you have an account, you can delete it along with associated information at any time as follows:

    Note that some information may be retained in connection with our legal and record-keeping obligations, as required by applicable laws.

    5. Your Other Choices Regarding Your Information

    Marketing Communications

    If you have given your consent, we may send you marketing and promotional messages. If you no longer wish to receive such messages, you may opt out of receiving them / revoke your consent by following the opt-out or unsubscribe instructions included in any marketing or promotional communication you receive from us or by adjusting the settings in your account.

    Please note that even if you unsubscribe or opt-out of marketing and promotional messages from us, we will still send you administrative and transactional messages, such as account verification, password or local area number requests, order confirmations, change or updates to features of the Service, or technical and security notices.

    Do Not Track

    “Do Not Track” (“DNT”) is a developing standard for web browsers that aims to inform the websites you visit that you do not want information about your online activity collected over time and across third-party websites or online services. Although we do our best to honor the privacy preferences of our users, we do not interpret or respond to DNT or other similar signals from your browser at this time. For more information, visit http://www.allaboutdnt.com.

    6. Links To Third Party Websites

    The Service contains links to and from third party websites of our business partners, advertisers, and social media sites. If you follow a link to any of these websites, please note that these websites have their own privacy policies. Please check the individual policies before you submit any information to those websites. We are not responsible for the privacy policies or data collection, use and disclosure practices of those sites.

    7. Security and Storage of Personal Information

    Klip’em uses commercially reasonable physical, administrative, and technological safeguards to protect the personal information we hold from misuse and loss and from unauthorised access, modification, or disclosure, for example by use of physical security and restricted access to electronic records.

    We will store your personal data as long as is necessary for the purposes named in this Privacy Policy, especially for the fulfilment of our contractual and legal obligations. We may also store your personal data for other purposes if or as long as the law allows us to store it for particular purposes, including for defence against legal claims. Where we no longer require your personal information, we will take reasonable steps to anonymize or ensure it is kept de-identified (in case we have a legitimate interest to keep it as such).

    8. Cross-Border Transfers

    Your information collected through the Service may be stored and processed in the United States or any other country in which Klip’em or its affiliates, partners or service providers maintain facilities, which may result in the transfer of your personal information outside of the country or region in which you reside.

    If personal information is transferred out of the European Economic Area (“EEA”), Canada or UK, we will do so in accordance with applicable law and take appropriate steps to ensure your information is protected, however, please note that non-EEA countries may not offer the same level of personal data protection as the EEA countries. In relation to data being transferred outside the EEA, and UK, for example, a transfer may be done in one of the following ways:

    • the country that we send the data to might be approved by the European Commission as offering an adequate level of protection for Personal Data;
    • the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your Personal Data; or
    • in other circumstances the law may permit us to otherwise transfer your personal information outside of the EEA and UK.

    9. Persons Under the Age Of 18

    Klip’em does not knowingly collect or solicit any information from anyone under the age of 18. The Service and its content are not directed at children under the age of 18. If you believe that we might have any information collected from a child under 18, please contact us by writing to the address in this Privacy Policy.

    10. Contact Us

    If you have any questions or comments about this Privacy Policy or our information handling practices, you can contact Klip’em privacy officer’s team at:

    Privacy Team
    Klip'em, Inc.
    50 Beale Street, Suite 600,
    San Francisco, CA 94105
    Tel: +1 (650) 999-0427
    Email: info@klipem.com

    11. How to Submit a Privacy-Related Complaint

    If you wish to complain about a breach of your privacy or the handling of your personal information by us, please contact our privacy officer’s team at info@klipem.com.

    In addition, if you are resident in the following countries, you also have the right to lodge a complaint with the relevant data protection authority for your country. Details are set out in the table below.

    Country of residence Data protection authority and contact details
    Australia

    Australia
    GPO Box 5218
    Sydney NSW 2001
    Email: enquiries@oaic.gov.au
    Tel: 1300 363 992
    www.oaic.com.au

    United Kingdom

    Information Commissioner’s Office
    https://ico.org.uk/make-a-complaint

    EU

    The data protection authority in your relevant member state
    https://ec.europa.eu/justice/article-29/structure/data-protection-authorities

    12. Updates To This Policy

    This Privacy Policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and the changing business environment. The most current version of this Privacy Policy is located at https://www.klipem.com/coupon/privacy_policy and can also be obtained by contacting us at info@klipem.com.