Last Updated: December 2015
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. We care about your privacy and treat the personal information of our members with respect and sensitivity. You can review certain limited information about our service (the “Service”) on our web site and any Freeosk kiosk without telling us who you are or revealing any personal information about yourself. 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 a designated club, credit or other card (the “Card”) to access the Service at designated Freeosk locations. If you become a Freeosk Member, or provide us with your email address through our kiosk you are not anonymous to us and you consent to the processing, storage and transfer of that information. If you use a Card, your information will be known to the Card issuer, and may be disclosed to us.
Information We Collect
Registration Information: When you become a Freeosk Member we collect registration information, including a unique device identifier, email address, and password. You may also provide a user name, mailing address and additional registration or profile information if you choose.
Profile Information: We collect information about you, the products/samples you are interested in and your use of the Service. This information includes information you voluntarily provide to us, such as your age, education, income and interests. We may also collect information related to the product samples you have viewed, selected and reviewed, coupons or other offers you have requested, received and used.
This information may be matched with purchase and other information maintained by the Card issuer or third parties and used by us and the Card issuer for analytical purposes and/or to provide coupons or other offers to you.
Cookies: When you access our Service we may also collect non-personally identifying information related to your use of the Service. We may send one or more “cookies” – a small data file – to your computer or mobile device to uniquely identify your browser and let us help you log in faster and enhance your navigation through the Service. A cookie may convey to us anonymous information about how you utilize the Service, and we may use such information to address targeted information, advertising or other communications to you. 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 Service accessed by that device. Persistent cookies can be removed by following your web browser’s directions. 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. However, some features of the Service may not function properly if the ability to accept cookies is disabled.
Log Files: When you use the Service via a computer or mobile device, our servers automatically record certain information sent by your web browser. These server logs may include information such as your web request, Internet Protocol (“IP”) address, browser type, referring/exit pages and URLs, number of clicks and how you interact with the Service, domain names, landing pages, pages viewed, mobile carrier, and other such information. Geo-Location Information : When you use our App, we may access, collect, monitor and/or remotely store “location data,” which may include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device. Location data may convey to us information about how and where you utilize the Service. Though location data does not collect or share any personally identifiable information about you, it may be used in conjunction with personally identifiable information from other sources and may be used to provide you with information or special offers based on your location. Some features of the Service, particularly location-based offers, may not function properly if use or availability of location data is impaired or disabled.
Device Identifiers: When you access the Service by or through a mobile device, we may access, collect, monitor and/or remotely store one or more “device identifiers.” Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device and are used to enhance the Service for you when accessed through that device. A device identifier 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 convey to us information about how you use the Service through that device. Though a device identifier does not collect or share any personally identifiable information about you, it may be used in conjunction with personally identifiable information obtained from other sources. A device identifier may remain persistently on your device, to help you log in faster and enhance your use of the Service. Some features of the Service may not function properly if use or availability of device identifiers are impaired or disabled. We may access, collect and/or store device identifiers and maintain them in your profile.
Card Issuer Profiles: If you use a Card to interact with a Freeosk kiosk, you will initially establish a separate anonymous profile with us that is separate from that of the Card issuer. The Card issuer will be able to identify you, and may choose to share certain information about you with us. By using the Service you permit the Card issuer to provide information related to your use of the Service in connection with the Card to us, however the Card issuer may elect not to provide us with that information in a personally identifiable form. If you elect to provide us with your email address or the Card issuer provides us with information that allows us to create a Freeosk Member profile or link any part of your Card information with your Freeosk Member profile that will be noted in your Freeosk Member profile. You can confirm with us or the Card issuer regarding whether or not the Card issuer shares information with us and what information it shares.
How We Use and Disclose Information
We use your email, device address, mailing address, Card identifier or Freeosk Membership identification to send you information about samples, coupons or other special offers, samples of products we think you may be interested in, member communications, surveys, newsletters. You may opt out of receiving communications that are strictly promotional by unchecking the registration box or following the opt out language contained in any promotional email. 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.
We use information we collect to operate, maintain and provide you the features and functionality of the Service, to analyze how the Service is used, diagnose service or technical problems, maintain security, personalize content, remember information to help you efficiently access your account, aggregate and monitor relevant metrics, including but not necessarily limited to the total number of visitors, traffic, and demographic patterns. We also use information we collect in order to send you samples, information, coupons or offers we believe you would be interested in receiving.
We may combine information that we may collect from you from different means online as well as offline (or through mobile applications) into one customer profile, and use that information as described in this policy.
We may provide your information, including your email address, to the Card issuer and other third parties for the purposes of sending you promotional materials regarding their goods and/or services. You may opt out of receiving such communications by unchecking the registration box or following the third party’s opt out procedures. Please note that once you consent to receive communications from a third party you will need to communicate with the third party in order to opt out of receiving their communications.
Refer a Friend: 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 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 Service may 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. While, due to technical restrictions, the recipient’s information may be retained in our systems as required for delivery and logging, we do not knowingly share it with third parties and 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 as part of a membership with us).
Behavioral Information: We may display or send targeted coupons, offers or advertisements to you while you are on and off the Service based on information we obtain from you, about you and/or from Card issuers and third parties. Card issuers may also send communications to you directly, or through the Service, based on behavioral information generated by your activities as a result of your use of a Card in connection with the Service.
Service Providers: We may provide your information to service providers who assist us in providing you with the Service and other information and services you are requesting from us. These service providers may include computer hosting services, email or mobile device communication companies. We have agreements with service providers which provide that your information can only be used in connection with providing services for us in connection with providing you the Service.
Business Transfers: As we develop our business, we may buy or sell assets or business offerings. Customer information is generally one of the transferred business assets in these types of transactions. We may also transfer or assign such information in the course of corporate divestitures, mergers, or dissolution or discussions regarding same.
Compliance with Laws and Law Enforcement: We may disclose your personal information 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 protect the safety of any business, person or member; to address fraud, security or technical issues; or to protect our rights or property or the rights of others. 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 Service. 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 but not limited to disclosing and/or sharing information, data and/or content connected with you and/or the Service.
Information received by us through the Service is stored and processed on secured servers and computers we control in the U.S. We use (and our service providers use) reasonable technical and administrative security measures designed to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. 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 is guaranteed to be completely secure. Unauthorized entry or use, hardware or software failure, and other factors may compromise data security. 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 Card, password, user id.
Access to Information
You may review and request amendments to the information that we maintain in your profile. You may access the information by contacting us at the address below. We may request documentation to identify you and/or support any amendments to your information that are requested.
The Service is intended for persons over the age of 13 years of age. We do not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to utilize the Service. Certain Card issuers 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 13 we will take steps to remove that information and terminate that membership/account.
Our customer mobile applications (each an “App”) are made available to you for use in connection with such activities as finding our locations and receiving coupons and other special offers from us or Card issuers. We may collect and use non-personally identifiable (e.g. geo-location) and personally identifiable (e.g. device id or e-mail address) information through each App solely for the purpose of providing you with the information you request in using the App as well as providing notifications and other information relevant to the App and/or special offers from us.
We may collect precise geo-location data, passwords, email addresses, and profile information requested through the App.
Information we collect is used for the purpose of the App and communicating with you. Information may be disclosed to third parties for marketing purposes, and will be disclosed to card issuers to the extent you use a card to identify yourself and service providers who assist us in completing transactions and helping us communicate with you.
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. card issuers) 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. The designated email address for these requests is email@example.com.
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