Last updated June, 14 2019. The effective date of this policy for new users is June 14, 2019 while the effective date for existing users will be July 14, 2019.
Freeosk, Inc. ("Freeosk", "we" or "our") helps connect consumers with producers of products and vice versa, with no pressure, no obligation and no cost. In this way you can consider and try free samples of products that you might be interested in trying or buying.
You can review certain limited information about us and our Services on our web site and any Freeosk kiosk without telling us who you are. However to obtain a sample or receive information from us you will need to do one of two things: 1) You can sign up for an account and become a Freeosk Member through participating Freeosk locations, our mobile app or web site; or 2) you can use certain existing credentials you use with a participating store. For example, a designated club, loyalty, credit or other store card; email address; phone number; or other credentials associated with a retailer ("Retailer Credentials") to access the Service at designated Freeosk locations.
Once you use your Retailer Credentials to access the Services, your information will be shared with us and you will also become a Freeosk Member.
Note that anytime you choose to connect your use of the Freeosk Services to Retailer Credentials, information about you will be shared between us and the applicable retailer, including Personal Information, information relating to your purchases and samples tried, and information related to your interests and preferences. For further information, see "How We May Share Information with Third Parties".
Infomation We Collect
Information You Provide to Freeosk
You may provide us with "Personal Information," which is information that identifies or can be used to identify you as a specific individual) (such as your name, mailing address, and email address) and other information about you, such as demographic information (for example, ZIP code and day and month of birth) and information about your interests and preferences. When you create an account, it may include username and password. You may provide Personal Information and other information through various forms and features on the Services. Note that we may also de-identify Personal Information, turning it into non-Personal Information. This is sometimes accomplished using a mathematical function (commonly known as a "hash" function) to convert information into a code. The code does not identify you directly, but it may be used to connect your activity through the Services or elsewhere online.
Information Provided to Us by Retailers
Sometimes you will use Retailer Credentials issued by or associated with the store where you are shopping or the store’s app to access our Services. If you use Retailer Credentials or a store related app to interact with a Freeosk kiosk, you will establish a separate profile with us that is separate from that retailer ("Freeosk Member Profile"). We refer to the applicable store as the "Retailer". The Retailer will be able to identify that you used a Freeosk kiosk, and may share certain information with us about you and your purchase and transaction history, as well as your first and last name, contact information, your customer ID associated with the Retailer or other identifier (which may include a mobile advertising ID), and other information the Retailer has collected about you.
When you associate your use of our Services with Retailer Credentials or retail app, we and the Retailer may exchange and share information, including Personal Information, regarding your use of the Services including the samples you try, your purchase history with the retailer and other information in your profile. You can confirm what information is shared between the Retailer and Freeosk by contacting the Retailer or contacting us using our contact information below.
Information We Collect Automatically
Usage Information, Device Identifiers and Cookies:
We and our third-party advertising, analytics and other service providers automatically or passively collect certain information whenever you visit or interact with the Services ("Usage Information"), which we store in our server log files and which we may associate with your Freeosk profile. Usage Information may include information such as your web request, browser type, the operating system you are using, the URL or advertisement that referred you to our Services, the search terms you entered into a search engine that lead you to one of our Services, how you interact with the Services, your mobile carrier, and the time of day you visited the Services, among other information. It also includes how you use our Services, such as product samples you have viewed, selected and reviewed, and coupons or other offers you have requested, received and used.
Usage Information also includes your IP address and other unique identifiers associate with the device you use to access our Services ("Device Identifiers"). Device Identifiers uniquely identify your device and may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent by us to the device. A Device Identifier may be used to recognize you and track how you use the Services. Though a Device Identifier does not collect or share any Personal Information about you, we may combine it with Personal Information we have collected and may store Device Identifiers in your profile.
We use the following types of tracking technologies to collect Usage Information and similar information:
We use both session and persistent cookies. A session cookie is temporary and disappears when the Service session is completed. You can reset your web browser on your computer or mobile device to refuse all cookies or to indicate when a cookie is being sent. A persistent cookie remains on the hard drive of your device after you close your browser so that your browser can use it on subsequent uses of the Services accessed by that device. Persistent cookies can be removed by following your web browser’s directions.
If you choose to disable cookies on your device, some features of the Services or our content may not function properly.
Web Beacons: Web beacons (also known as "1x1 GIFs" or "clear GIFs") are small graphic images or other web programming code, which may be included in our web pages and email messages. Web beacons and similar technologies may be used for a number of purposes, including to count visitors to the Services, to monitor how users navigate the Services, to count how many emails that were sent were actually opened or to count how many particular videos or links were actually viewed.
In addition, we may use these and a variety of other technologies that collect Usage Information and similar information for security and fraud detection purposes.
We may infer your general location using other information we collect, such as IP address. In addition, when you use mobile application(s) (each an "App") to interact with us, we may access, collect, monitor and/or remotely store specific "location data" from your device, which may include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device. And, of course, whenever you interact with one of our Freeosks, we will know the store and location of that Freeosk. Geo-location and more general location data may be used to provide you with information, such as enabling you to find our Freeosk kiosk locations, or to send you special offers based on your location You may be able to turn off the collection of location information through your device settings. However, please note that we may still be able to infer your approximate location through other information we collect. In addition, some mobile service providers may also provide us or our third-party service providers with information regarding the physical location of the device used to access the Services.
Some features of the Services, particularly location-based offers, may not function properly if use or availability of location data is impaired or disabled.
If you choose to use our invitation service to invite a friend to use the Service, we will ask you for that person’s email address and we will automatically send an email invitation. We store this information to send this email, to register your friend if your invitation is accepted, and to track the success of our invitation service. If you utilize a social media application to perform the invitation, we will receive the information directly from the social media service and maintain that information.
The Services may also allow you to send information to your friends or others who you feel may be interested in receiving such information. To use this feature, you provide us with certain information about the receiving party. Any information you provide in connection with sending such other party the message, such as your name and your email address will, of course, be disclosed to such other party. We do not use this information except to send this one-time message (unless the recipient has independently consented to such use of his/her information including as part of a membership with us).
Information Third Parties Provide About You
We receive information about you from Retailers. In addition, we may receive information about you from other third parties. For example, we may supplement the information we collect with outside records from third parties, such as public databases, publicly available social media pages, or joint marketing partners, for various purposes, such as to provide you with information, services or products, to tailor our content and the offers we show you, or to enhance our products and services.
How We Use Information
How We Share Information with Third Parties
Information Shared through Our Partnerships with Retailers:
When you interact with us using Retailer Credentials or a retailer’s app, the Retailers may share certain information about you with us (as described above) and we may also share certain information with the Retailer. The information we share with the Retailer may include your Personal Information, which the Retailer may use for the purposes of directly sending you communications and promotional materials regarding their goods and/or services, directly, or through the Services. It also includes information regarding the samples you have tried, coupons you have used, and other information relating to your use of the Services.
California residents, please see "Your California Privacy Rights" for additional information.
When You Request that we Share Your Information:
We may share information when you request that we do so. For example, you may be presented with an opportunity to receive information and/or marketing offers from one or more third parties. If you agree at that time to have your Personal Information shared, your Personal Information will be disclosed to that third party (or parties) and will be subject to their privacy practices. Or, you may choose to interact with a third party application or feature, through which information about you is shared. Please note that we are not responsible for the privacy practices of third parties. If you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly.
We may provide information about you, including Personal Information, with third-party service providers to enable them to perform services on our (or your) behalf. These third parties may include computer hosting services, data matching services, and email or mobile communication companies.
Sweepstakes, Contests, and Promotions:
We may offer sweepstakes, contests, or other promotions (any, a "Promotion") that may require registration. By participating in a Promotion, you agree to the conditions or official rules that govern the Promotion, which may involve specific requirements (including allowing the sponsor(s) of the Promotion to use your name, voice, likeness, or other indicia of persona in advertising or marketing materials, except where prohibited by law). If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with administering the Promotion, such as in connection with winner selection, prize fulfillment, as required by law, or as permitted by the Promotion’s terms or official rules.
Administrative and Legal Reasons:
Freeosk may transfer and disclose information, including your Personal Information, Usage Information, and Device Identifier with third parties if required to do so by law or subpoena or if we believe that it is reasonably necessary to comply with a law, regulation or legal process; to address fraud, security or technical issues; to protect our rights, property, safety, security, or that of other users or the public. We may in our sole discretion elect in good faith to cooperate with any law enforcement agency requesting assistance with an official investigation by disclosing and/or sharing with such agency any and all information, data and/or content connected with you and/or your use of the Services. We may also, but need not, in our sole discretion, initiate a report to any law enforcement agency where it is reasonably suspected that unlawful activity may occur, or may have occurred, including sharing information connected with you and/or the Services.
You may submit your resume and Personal Information through the Site in response to (or to be considered for) a potential job opening at Freeosk. When you apply for a job with Freeosk, we may ask you to provide self-identifying information (such as veteran status, gender, and ethnicity) in conjunction with laws and regulations enforced by the Equal Employment Opportunity Commission and other federal, state, and local regulatory agencies. Providing such self-identifying information is voluntary, but if you do provide such information, we and/or our service provider may submit that information to the appropriate government or regulatory agencies to fulfill reporting requirements and use that information to defend against employment-related complaints.
In the event Freeosk goes through a transition such as being sold, has all or a portion of its assets acquired or transferred, whether voluntary or involuntary (such as through bankruptcy), or merges or becomes affiliated with any other division, individual, or entity (such as during the course of any due diligence process), any customer information owned or under the control of Freeosk (including your Personal Information) will likely be one of the transferred assets. We reserve the right, as part of this type of transaction, to assign or otherwise transfer your information (including your Personal Information) and other information we have collected from users of the Services. By providing your Personal Information, you agree that we may transfer such information to the acquiring entity without your further consent.
Third Party Advertising and Analytics Companies
Freeosk works with network advertisers, ad agencies, and other advertising partners to serve Freeosk ads online and to serve ads through our Services. We may use information we have learned about you to target ads to you and to allow third parties, such as the companies that provide the products you sample, to target ads to you. We may also use analytics providers to provide us with information regarding the use of the Freeosk Services and the effectiveness of our advertisements.
These third parties may set and access their own tracking technologies on your device (including cookies and web beacons), and they may otherwise collect or have access to information about you. And, we our third party advertising and analytics providers may collect Personal Information over time when you visit the Services or other online websites and services.
We may share non-personal information, including information that has been de-identified, aggregated user statistics, and Usage Information, directly or indirectly through third party service providers, with third party advertising companies, analytics providers, and other third parties, including for the purpose of serving you more relevant ads. In addition, we may share Personal Information with third parties who combine and link information from Freeosk with information from other sources. These third party service providers may then make non-personally identifiable information available to third-party advertisers, including information about your interests and preferences, to enable them to serve you more relevant ads. See the "Access to Information and Your Choices" section for information on how you may opt-out from our sharing your Personal Information with these advertising related third parties.
Some of these third party advertising and analytics providers are members of the Network Advertising Initiative ("NAI") or the Digital Advertising Alliance ("DAA") Self-Regulatory Program for Online Behavioral Advertising. You may want to visit http://www.networkadvertising.org/managing/opt_out.asp, which provides information regarding targeted advertising and "opt-out" procedures of NAI members. You may also want to visit http://www.aboutads.info/choices/, which provides information regarding targeted advertising and offers an "opt-out" by participating companies in the DAA Self-Regulatory Program.
For mobile applications, you may be able to limit certain advertising practices using the settings on your phone, tablet, or other mobile device. Also, on most mobile devices, you can install the DAA’s AppChoices app to make choices about cross-app interest-based advertisements from participating third parties. You may review additional information on opting out of mobile devices at https://www.networkadvertising.org/mobile-choice/.
Please note that opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive generic ads while online.
How We Respond to "Do Not Track" Signals
Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. There is no consensus among industry participants as to what "Do Not Track" means in this context. Like many websites and online services, our Site does not alter its practices when we receive a "Do Not Track" signal from a visitor’s browsers. To find out more about "Do Not Track," please visit www.allaboutdnt.com.
Third Party Links & Content
The Services may link to or incorporate websites or content hosted and served by third parties over which we have no control, and which are governed by the privacy policies and business practices of those third parties. Freeosk is not responsible for the privacy practices or business practices of any third party.
Information received by us through the Service is stored and processed on secured servers and computers we control in the U.S. We use commercially reasonable technical and administrative security measures designed to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration of your Personal Information. Some of the safeguards we use are firewalls, data encryption, physical access controls to data centers, and information access authorization controls. While we have implemented reasonable security measures please keep in mind that "perfect security" does not exist, and no transmission of information over the Internet or your mobile device is guaranteed to be completely secure. For example, unauthorized entry or use, hardware or software failure, and other factors may compromise data security. We cannot warrant or ensure the security of any information we collect. You acknowledge and agree to assume this risk when communicating with us and utilizing the Service.
Please remember that you are responsible for maintaining the confidentiality and security of any member name and password you use in connection with the Service. If you believe that your account information is being used in an unauthorized fashion, you must contact us immediately. You are also responsible for all use of the Service resulting from your Retailer Credentials, password, user id.
The Service is intended for persons over the age of 16 years of age. We do not knowingly collect or solicit personal information from anyone under the age of 16 or knowingly allow such persons to utilize the Service. Certain Retailers may impose additional age restrictions concerning the use of the Service. If we become aware that we have collected personal information from an individual under age 16 we will take steps to remove that information and terminate that membership/account.
Access to Information and Your Choices
You may review and request amendments to the information that we maintain in your profile. You may access and update certain information by logging into your account and you may request information or corrections by contacting us using the contact information below. We may request documentation to identify you and/or support any amendments to your information that are requested.
You may be able to change your preferences with regard to communications you receive from us by logging into your account. You may opt out of receiving email communications that are strictly promotional by unchecking the registration box or following the opt-out language contained in any promotional email. Please note that we reserve the right to send you certain communications relating to your account or use of the Services (for example, responses to communications we receive from you or updates to our policies) and these transactional account messages may be unaffected if you opt-out from marketing communications.
Remember, if you provide us with your mobile number or obtain a mobile application we may send communications to your phone or via the mobile application, including texts. If you elect to receive texts from us, your wireless carrier may impose a charge on incoming texts. Please check with your wireless carrier for details. You may opt-out of text messages sent by Freeosk by replying "STOP" to any text message we send to you. You can turn off our collection of GPS location data on your device through your device settings. If you have opted in to receive push notifications from our mobile application(s), you can turn off push notifications in your device settings.
If you do not want us to share your email address, or other Personal Information we have associated with your email address, with third party advertising-related companies in order to market and advertise to you online based on your interests and preferences, and to perform related services such as measurement and analytics, please email us at firstname.lastname@example.org.
Limitation of Liability
By providing us with any personal information you expressly and unconditionally release and hold us harmless from any and all liability for any injuries, loss or damage of any kind arising from or in connection with the use and/or misuse of the information. In addition, while we take efforts to ensure the proper and appropriate use of data by our service providers and third parties (e.g. Retailers) that may receive your information from us, we cannot be liable for any injuries, loss or damage of any kind arising from or in connection with the use and/or misuse of your information caused by those service providers and third parties.
Your Privacy Rights in California
If you are a California resident, you have the right to request information about how we share certain categories of personal information with third parties. California law gives you the right to send us a request at a designated address to receive the following information:
the categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year; the names and addresses of the third parties that received that information; and if the nature of the third party’s business cannot be determined from their name, examples of the products or services marketed.
We may provide this information in a standard format that is not specific to you. If you are a California resident, the designated email address for these requests is email@example.com and the designated mailing address for these requests is 325 North LaSalle Drive, Suite 525, Chicago, Illinois 60654. You must put the statement "Your California Privacy Rights" in the subject field of your email or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.