Sources of Information Collection

We acquire, process, and utilize information about you when you:

• Sign up for our Services

• Engage with our Services

• Download and/or access our Services via our application(s), including our mobile app and browser add-on

• Link to our Services through third-party platforms, including social networks, email services, and business associates

• Reach out to us for assistance

• Participate in a sweepstakes, contest, or promotion, or answer a survey or questionnaire

We gather specific information directly from you when you provide it to us. Additionally, when you have our mobile app or browser add-on installed, or when you interact with our Services online, we automatically collect information about your usage of the Services through log files, cookies, location-identifying technologies, and other tracking methods. We also receive information about you from third parties, such as when you connect via a third-party service or when information is shared by merchants and business partners you’ve interacted with.

Types of Information Collected

The information we collect may include, but is not limited to, the following personal data:

• Identifiers you give us, like your name, address, email, tax details (for winners of sweepstakes or contests), and phone number

• Identifiers obtained through your use of the Services, like unique online or device IDs, IP addresses, and details about your system setup, network, and connected devices and apps

• Customer Record Information, such as payment account details and billing address

• Protected Classification Characteristics, like gender, age, income, marital status, or other protected classifications under law, only if you provide this as identifiable demographic information in surveys

• Commercial Information, such as records of your interactions with products, merchants, and services, including search history, items viewed or clicked, and transaction data

• Internet and Network Activity, like your browsing history, interactions with our site and Services, and preferences for using the Services

• Sensory-related information, such as voice recordings if you contact our member services, as allowed by law

• Account credentials, including username and password

• Inferences about your preferences and behaviors from the collected information, excluding “sensitive” data

In some regions, certain collected information may be considered “sensitive” personal data, including demographic details and precise geo-location data, which we only use to provide the Services and not for inferring characteristics about you. We do not sell, share, or use sensitive data for targeted advertising as defined by U.S. state privacy laws.

We use the information collected for various business and commercial purposes:

To Provide and Manage Our Service

• Process your registration, including verifying your email and enrolling you in our programs

• Manage your account and preferences, including tracking your favored stores and transaction history

• Facilitate and oversee your transactions through our platform

• Deliver rewards or payments and identify reward opportunities and offers

• Send updates, security alerts, and administrative messages

• Offer member services and support, and respond to inquiries and requests

To Personalize and Enhance Our Services

We may use your information to personalize content and tailor Services to your interests. For instance, we might use your shopping history to suggest similar offers or present special in-store opportunities.
We also analyze trends and perform statistical analyses to improve our Services, websites, apps, marketing strategies, and the offerings of our business partners.

To Provide Marketing Information

Tufa may use your information to deliver personalized and relevant offers from our network of merchants via direct communications and digital advertising. You can manage these communications as outlined in the sections below. We may also use your information for online advertising, including on other websites, with options to opt-out as detailed in the subsequent sections.

To Safeguard You, Others, and Our Business

We may utilize the information we collect to evaluate risks and to investigate, prevent, and restrict fraudulent, spam, and other harmful activities within our Services, as well as to enhance our security protocols. Additionally, we may employ collected data to enforce our legal rights or defend against legal claims from third parties.

To Adhere to Legal Requirements

We may process information about you to fulfill legal obligations, adhere to regulations, and respond to legal and regulatory authorities in each region where Tufa operates.

To Manage Contests, Sweepstakes, Surveys, Polls, and Promotions

Occasionally, Tufa may invite you to participate in contests, sweepstakes, surveys, polls, and promotions. If you opt to join, we may use your personal data to manage these events, such as confirming eligibility or awarding prizes. For surveys or polls, your input will be collected and anonymized to gain insights into business and consumer trends. This data is kept in an anonymized state, and we do not attempt to re-identify it.

To Oversee Referral Programs

We offer features that enable you to inform others about our Services. If you use our referral options, we’ll request the email address of the person you’re referring to send them an invitation to join Tufa. This information is retained solely to dispatch the invitation and monitor the success of our referral initiative. By participating in our referral programs, you affirm that you have a personal connection with the individual you’re referring and are authorized to share their details with Tufa for the purpose of sending an invitation to join our Services. Should you wish to have someone’s personal information removed from our database, please reach out to our member services.

We may share the following categories of information for our business or commercial purposes:

Disclosure to Service Providers

We may share all categories of your personal information as necessary with our third-party service providers, including Tufa affiliates, who conduct various business operations for us or on our behalf, following our directives and in line with proper contractual and security measures to safeguard your data. For instance, we may collaborate with other companies for member support services, fraud prevention, payment processing, promotion management, analytics, database accuracy, direct marketing, and communications, among other operations.

Disclosure to Business Partners

Tufa collaborates with a variety of third-party business partners to offer our Services. We may share certain types of information with these partners:

Affiliate Partners

When you click a link to a merchant site via our Services, indicating your intent to engage with that business, we may share certain information about you (such as the clicked link and a unique ID to track your shopping) with an affiliate network to accurately account for your transactions. The Affiliate Partner may collect data about your activity to track the shopping trip and may also use this data for performance measurement or integrate it with other collected data, which may be used by their other business clients. In such cases, our disclosure to these Affiliate Partners could be considered a “sale” or “sharing” of your personal information under U.S. privacy laws, and you can opt-out as described in the relevant sections below.

Referral Marketing Partners

To broaden your options for signing up for our Services and initiating your shopping from third-party sites, we partner with referral marketing partners, which may necessitate sharing certain data about you with them. For instance, if you’re referred to our Services from a partner’s website, we may share information about your sign-up to validate the referral and enable your account access from the partner’s site. We may also share data regarding your recent purchases and app or extension installations to allow the partner to tailor their content to you.

Information Disclosure Practices

The disclosure of your activity within our Services may be considered “selling”, “sharing”, or “targeted advertising” as defined by U.S. privacy laws. Therefore, we offer an opt-out option detailed in Section 5.

Affiliated Companies

If you engage with our affiliated services, we may share transaction details to provide a seamless experience across platforms. For instance, if you participate in programs through our sister company, we may share certain information to display your activity summary on their site. We may also use cookies to facilitate your experience without repeated sign-ins. For detailed processing information, please refer to the affiliated company’s privacy policy.

Financial Partners

To offer you additional rewards redemption options and to market our co-branded financial products, we may share your information, including identifiers, with financial partners. If you choose alternative rewards redemption methods, you authorize us to share your personal information as needed with the relevant financial entity. If you express interest in receiving information about our co-branded products, you direct us to share your details with the respective financial partners.

We may also share your personal information with financial partners for their marketing purposes, which may be considered “selling”, “sharing”, or “targeted advertising”. You have the option to opt-out of this sharing for marketing purposes in Section 5.

Digital Advertising Providers

We collaborate with third parties for targeted advertising services. These partners may collect data about your Service usage, like browsing history and device interactions, to display relevant ads for our Services on other websites. Some partners may use this data for their own purposes or collect additional information across various websites to predict your preferences. You have the right to opt out of our sharing of your information for cross-context behavioral advertising as outlined in Section 5.

Legal Disclosures

We may disclose collected information, including personal information, as permitted by law, for legal processes, governmental inquiries, policy enforcement, and to protect the rights and safety of our company or others.

Business Transfers

In the event of mergers or business transfers, we may disclose collected information, including personal information, to involved parties. The acquiring entity would be bound to respect this Privacy Policy and applicable laws or provide notice of new practices.

We may also disclose aggregated or anonymized data that cannot reasonably identify you.

Account Information Updates

You are encouraged to keep your submitted information accurate. You can update your account details by logging into your account and adjusting settings.

Communication Preferences

Email Marketing

Upon account creation, you may receive periodic communications. You can opt out of promotional messages at any time by following unsubscribe instructions, modifying account settings, or contacting us. We may still send non-promotional communications as permitted by law.

Mobile Notifications

For mobile app users, notification preferences can be managed in your device settings.

SMS Messaging

If you consent to SMS messaging, we may contact you for account updates, support ticket information, and recovery purposes. You can opt out by changing your preferences or replying STOP to messages.

Data Sharing Preferences

You may decline to provide certain information, but this may affect your access to some services.

Mobile App/Browser Extension

You can halt all data collection by our mobile application and/or browser extension prospectively by uninstalling them. Since these tools collect data about your online behavior when installed, uninstallation is necessary to withdraw consent for data collection. In some cases, you can opt out of specific data collections by adjusting your settings within the browser extension or mobile device.

You possess certain rights regarding your personal information under applicable laws, with some exceptions.

Right to Know and Access

You have the right to inquire about the personal information we’ve collected, used, disclosed for business purposes, and sold or shared for cross-context or targeted advertising. This includes the purposes for which we use your information, the sources from which it was acquired, and the third parties to whom it was disclosed. You also have the right to access the specific pieces of personal information we hold about you.

Right to Request Deletion

You can request the deletion of your personal information that we’ve collected or maintain, subject to certain exceptions. We will comply with your request unless we need the information for a business purpose or are legally permitted to retain it.

Right to Correct

You can request corrections to any inaccurate or incomplete personal information we have about you. You can make corrections to information you’ve provided in your account settings.

Right to Opt-out of Sale or Sharing

If you wish to opt-out of having your personal information sold or shared, as described in Section 3, you can do so through our Privacy Preference Center. Please note that opting out may affect our ability to provide you with certain services.

Right to Non-Discrimination

We will not discriminate against you for exercising your privacy rights. We will not deny services, charge different prices, provide a different quality of services, or suggest that you may receive different prices or quality of services.

How To Exercise Your Rights

To exercise your privacy rights, please visit our Privacy Center. We will verify your identity through your account login and a verification code sent to your email. If we cannot verify your identity, we may request additional information for verification purposes.

Right to Appeal

You may have the right to appeal our decisions regarding your privacy rights requests, depending on your location. You can submit an appeal through our contact page under the “Data Privacy” section.

Agents

Only you or someone legally authorized to act on your behalf may make a request related to your personal information. We may require proof of authorization and independent identity verification for agents.

Shine the Light.

California residents can request details about how their information is shared with third parties for direct marketing purposes.

Notice Regarding Minors.

Our services are intended for adults 18 and over. We do not knowingly collect or share personal information from consumers under 16 without authorization or parental consent for those under 13.

Retention of Data.

We retain your information as long as necessary for the purposes outlined in Section 2. Some information may be retained even after you request deletion if required by law or for legitimate business purposes.

Information Security.

We implement measures to secure your personal information appropriate to the risk. These measures aim to maintain the integrity and confidentiality of your data. We regularly review these measures to ensure they provide adequate security.

This Privacy Policy is current as of the effective date noted below. Tufa reserves the right to modify this Privacy Policy periodically in line with applicable privacy laws, principles, and our handling of personal information. Should there be any changes to this Privacy Policy, we will inform you by updating the date of this document. For substantial changes, additional notice will be provided, such as a notification on our Service homepages or an email alert.

Should you have any inquiries about this Privacy Policy, please do not hesitate to reach out to us through our support channels or by mail at 48 Summit Ave #3 Brookline, MA 02446 Attention: Tufa Legal Department.