Punchh (“Punchh,” “us,” “we,” or “our”) offers a variety of services on behalf of our business Partners (our “Partners”). We provide many of our services to you and other patrons of our Partners (“Users,” “you,” or “your”) through the Punchh website and through mobile, point of sale, and online applications provided by and on behalf of Punchh and our Partners (collectively, our “Platform”). By patronizing the businesses of our Partners, you access and use these services through our Platform.
Personal information refers to information connected to Users that may be used to identify them.
Punchh collects personal information when Users voluntarily submit it to us or when Partners submit User information on their behalf. For example, we may collect or receive information from a Partner about a User when the User creates an account on our Platform, edits their profile on our Platform, uses or accesses services or content through our Platform, or otherwise interacts with us, our Partners, or other Users of the Platform. Many methods Punchh uses to collect personal information require User opt-in.
In addition to personal information that we may receive from Users or Partners, Punchh may collect other personal information about Users in the following ways:
Punchh retains your personal information for as long as necessary for the purpose that it was collected, unless a different amount of time is required or allowed by law.
Punchh’s primary purpose in collecting personal information is to provide Users with content and services that Users request through the Platform or that match User interests.
Punchh may also use personal information for various other purposes, including without limitation to:
Our collection and use of your information is based, in different contexts, upon your consent, our need to perform a contract, our obligations under law, and our legitimate interest in conducting our business.
Except as explained herein, we do not sell, rent, share, trade or give away personal information. In accordance with Privacy Shield, we take responsibility for the processing of personal information that we transfer to third parties acting as an agent on our behalf.
Marketing. We do not share User information with third parties to directly market to Users, but Partners may market to Users using our Platform. We may market to Users on behalf of our Partners or other third parties that would like to send Users information about their products and services. For example, Punchh may offer a promotion in conjunction with a cosponsor that may have special offers or services that might be of interest to Users.
Within the Platform. Except where a User might choose to include a full name in his or her profile, a User’s email address and full name will only be used in the following circumstances:
Service Providers. Punchh may share User personal information with service providers that perform services for Punchh, such as providing hosting services, marketing assistance, analyzing User data, and processing payment card information.
Sharing Without Your Consent. There may also be instances when Punchh may disclose User personal information without providing Users with a choice in order to protect the legal rights of Punchh, other affiliated companies or their employees, agents, and contractors; to honor a request that Users have made through the Platform; to protect the safety and security of other Users; to protect against fraud or for risk management purposes; in response to a request by public authorities including in national security or law enforcement scenarios, or to comply with the law.
Sharing With Your Consent. We may also ask for your consent to share your personal information in other ways.
Affiliates and Acquisitions. If Punchh sells all or part of its business or makes a sale or transfer of assets or is otherwise involved in a merger or business transfer, Punchh may transfer User personal information to a third party as part of that transaction.
Social Networking. The Platform may offer Users the ability to share personal information through a social networking site (e.g., Facebook, Twitter, LinkedIn), using such site’s integrated tools (e.g., Facebook “Like” button, or Twitter “Tweet” button). The use of such integrated tools enables Users to share personal information about themselves with other individuals or the public. For more information about the purpose and scope of data collection and use in connection with such social networking site or a site’s integrated tools, please visit the privacy policies of these social networking sites.
Users can access, modify, and delete some types of personal information through their Platform account by contacting Punchh using the contact information in the “Data Protection Officer, Communications, and Requests” section below. You may also contact Punchh to make a request regarding your personal information, such as asking Punchh to:
Please note that although Punchh takes all requests seriously, depending on applicable law and Punchh’s legal rights, we may not be able to grant your request. Additionally, some of your personal information may be controlled by our Partners. If your request relates to personal information controlled by our Partners, we will direct you to communicate with that Partner directly. Finally, in limited cases, under applicable law Punchh is allowed to charge for certain requests.
Promotional Emails. Users who no longer wish to receive our weekly email updates or other email notifications may opt-out of receiving these communications by following the instructions contained in the applicable email or by logging-in and changing their settings in the account settings.
Do-Not-Track. Some web browsers and devices permit Users to broadcast a preference that they not be “tracked” online. At this time Punchh does not modify User experience based upon whether such a signal is broadcast.
The Platform is not meant for or targeted to children and should not be used by children under 13.
Punchh employs reasonable and appropriate security measures to protect personal information. While there is no such thing as “perfect security” on the Internet, we will take reasonable steps to ensure the safety of personal information. Please keep your password and account information secure, and notify us of unauthorized use of your account.
User privacy is important to us and we encourage you to submit all questions and complaints to Punchh using the information in the “Data Protection Officer, Communications, and Requests” section below. However, you may also have the right to complain to a government or regulatory body about our privacy practices.
Our contact information for privacy-related communications is our data protection officer, who can be reached at:
1. PUNCHH, INC.
1875 S Grant St #810
San Mateo, CA 94402
2. PUNCHH, INC.
815 Brazos St.,
Suite 410, Austin,
TX 78701, United States
If Punchh needs to communicate with you regarding your personal information, we may do so using any method practicable, including electronically, through the platform, through postal mail, or by telephone.
In compliance with the Privacy Shield Principles, Punchh commits to resolve complaints about its collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Punchh at:
1875 S Grant St #810
San Mateo, CA 94402
650 781 7100
Punchh has further committed to refer unresolved Privacy Shield complaints to PrivacyTrust, an alternative dispute resolution provider located in the United Kingdom. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.privacytrust.com/drs/punchh for more information or to file a complaint. In certain scenarios, you may be able to invoke binding arbitration against Punchh for privacy shield complaints. The services of PrivacyTrust are provided at no cost to you.