Privacy

Last Updated: June 29, 2017

Gray Matter LLC is committed to protecting and respecting your privacy.

This Privacy Policy (“Policy”) describes and governs the information collection, use, and sharing practices of Gray Matter and its corporate affiliates, subsidiaries, and divisions as may change from time to time (collectively, “Gray Matter,” “we,” “us,” and “our”) with respect to Gray Matter’s websites, mobile applications, and other digital and interactive services that link to this Privacy Policy (together, the “Services”).

Before you submit any information on or through the Services, please carefully review this Policy together with our terms of use and any other documents referred to therein to understand our views and practices regarding your information and how we will treat it. By using any part of the Services, you consent to the collection, use, and disclosure of your information as further outlined in this Policy. We will continue to evaluate this Policy as we update and expand the Services and our offerings, and we may make changes to the Policy accordingly. Any changes will be posted here and you should check this page periodically for updates. Your continued use of the Services will signify acceptance of the terms of the updated Policy.

Please note that this Privacy Policy applies only to information collected through the Services and not to information collected offline or to information you may provide to any third-party sites to which Gray Matter may link, except as expressly provided herein. This Policy applies regardless of the device used to access the Services (e.g., personal computer, mobile device, consumer electronics device, or any other technology or software known today or developed in the future). Some online services offered by or affiliated with Gray Matter may be governed by a separate privacy policy. In those instances, the product-specific privacy policy shall apply to that online service.

For the purpose of data protection laws applicable from time to time to you in the location that you provide your information (“Applicable Law”), Gray Matter will be the ‘data controller’ (or such equivalent or replacement terminology as appropriate).

INFORMATION WE COLLECT

We collect information in multiple ways, including when you provide information directly to us, and when we passively collect information from you, such as from your browser or device.

Information You Provide Directly to Us We may collect information from you during your use of or access to the Services.

2. Information that is Passively or Automatically Collected

a. Device/Usage Information

We may automatically collect certain information about the computer or devices (including mobile devices or tablets) you use to access the Services. As described further below, we may collect and analyze information such as (a) IP addresses, geolocation information, unique device identifiers, IMEI and TCP/IP address, and other information about your computer or device(s), browser types, browser language, operating system, mobile device carrier information, the state or country from which you accessed the Services; and (b) information related to the ways in which you interact with the Services, such as: referring and exit web pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content (such as advertisements) viewed and the order of those pages, statistical information about the use of the Services (such as barcodes scanned through certain of our mobile apps), the amount of time spent on particular pages, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.

We also collect and analyze information from your browser or device, such as, your operating system, plug-ins, system fonts, resolution and other data, for purposes of creating a unique profile or “fingerprint” of your browser or device. We may use this profile or fingerprint to understand and analyze how you interact with the Services, to customize content or advertising to you through the Services, to monitor against fraud or misuse of the Services, or in other ways consistent with this Privacy Policy.

b. Location Information

We and our service providers may automatically collect location information, including general information (e.g., IP address, zip code) from your computer or mobile device. If you access the Services through a mobile device, we may also ask you to share your specific geo-location information with us. The Services use this location information to provide customized location-based services, content, promotional offers and other information that may be of interest to you. For example, if you use our ShopSavvy mobile application, with your permission, we collect geolocation information from your device that will allow us to present location-based alerts such as nearby retailers or coupons, or organize products searched or scans based on the closest applicable retailer. We may also use location information to improve the functionality of the Services and our other products services. We and our service providers may also collect other information based on your location and your device’s proximity to “beacons” and other similar indoor proximity systems, including, for example, the strength of the signal between the “beacon” and your device and the duration that your device is near the “beacon.” If you do not wish to have this location information collected and used by us and our service providers, you may disable the location features on your device. Please note that if you disable such features, you will not be able to access or receive some or all of the services, content, features and/or products made available via the Services. Also see the “Tailored Advertising” section below for more choices regarding the delivery of interest-based content and advertising.

c. Cookies and Other Electronic Technologies

We may also collect data about your use of the Services through the use of Internet server logs, cookies and/or tracking pixels. A web server log is a file where website activity is stored to distinguish you from other users of our website. A cookie is a small text file that is placed on your computer when you visit a website, that enables us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv), enhance your user experience by delivering content specific to your interests; (v) perform searches and analytics; and (vi) assist with security administrative functions. Some cookies are placed in your browser cache while those associated with Flash technologies are stored with your Adobe Flash Player files. Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email, and that are designed to provide usage information like ad impressions or clicks, measure popularity of the Services and associated advertising, and to access user cookies. As we adopt additional technologies, we may also gather additional information through other methods. We also gather information and identify users through the fingerprinting methods described in Section 2(a) above.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Except for essential cookies, all cookies will expire after one year.

Your usage of the website without changing your browser cookies settings will indicate your consent to usage of cookies in accordance with this section of this Policy. You can change your cookie settings at any time. Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). You can also manage the use of Flash technologies, including cookies and local storage objects with the Flash management tools available at Adobe’s website. Please note that by blocking any or all cookies, you may not have access to certain features or offerings of the Services.

Please also see below the section entitled ‘Tailored Online and Mobile Advertising’ which contains further information on how cookies are used for advertising purposes by Gray Matter and by associated third parties.

3. Information Collected By and From Social Media and Other Content Platforms

If you access the Services through a third-party connection or log-in (e.g., through a social network), you may allow us to have access to and store certain information in your social network profile. This may include your first name, last name, gender, general location, a link to your profile, your time zone, birthday, profile picture, your “likes” and your list of friends. If you do not wish to have this information shared, do not use a social networking connection to access the Services. For a description on how social networking sites handle your information, please refer to their privacy policies and terms of use, which may permit you to modify your privacy settings. If you signed up using a social media log-in by mistake, you may be able to delete your account through your account settings at any time.

When you “like” or “follow” us on Facebook, Instagram, Pinterest, Twitter or other social media sites, we may collect some information from you including your name, e-mail address, and any comments or content you post relevant to us. We may also collect your information if you sign up for one of our promotions or submit information to us through social media sites.

4. Information from Affiliates and Non-Affiliated Third Parties

We may also obtain information about you if you use any other websites that we operate or may operate from time to time or other services we provide. We may share information amongst members of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries. We may also obtain information, such as demographic information, from our affiliates or from third parties, such as marketers, partners, researchers, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies and others.

HOW WE USE YOUR INFORMATION

Please note that we may combine information that we collect from you and about you (including automatically-collected information) with information we obtain about you from our affiliates and/or non-affiliated third parties, and use such combined information in accordance with this Policy.

We may aggregate and/or de-identify information collected through the Services. We may use de-identified and/or aggregated data for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, sponsors, event promoters, and/or others.

If you ever provide to us any information that classifies as ‘sensitive personal information’ (for example racial or ethnical origin, political opinions, religious beliefs, trade union membership, physical or mental health, sexual life, criminal proceedings and offences), we will only use this information to provide the Service you require in accordance with this Policy and we will ask for your explicit consent to such processing.

In connection with the foregoing, we work with DigiTrust to set a first-party cookie in your browser to enable us and DigiTrust Partners to collect web viewing data that includes visits to the Services and non-affiliated websites over time. This data may be used to infer whether you share interests with other users, and deliver advertising relevant to those inferences. Also, third parties whose products or services are accessible or advertised via the Services may place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about your use of the Services in order to (i) inform, optimize, and serve ads based on past visits to our websites and other sites and (ii) report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our websites and use of our Services. We also allow other third parties (e.g., ad networks and ad servers such as Google Analytics, DoubleClick and others) to serve tailored ads to you on the Services, other sites, and in other applications, and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services. We also may share with third-party advertisers a hashed version of your email address, solely in non-human readable form and content that you share publicly when using the services (e.g, user-generated content) for purposes of delivering tailored advertising. We neither have access to, nor does this Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device you use to access the Services by non-affiliated, third-party ad technology, ad servers, ad networks or any other non-affiliated third parties. Those parties that use these technologies, including DigiTrust, may offer you a way to opt out of ad targeting as described below. You may receive tailored advertising on your computer through a web browser. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link , the opt-out page of the European Interactive Digital Advertising Alliance, or TRUSTe’s Advertising Choices Page to opt-out of receiving tailored advertising from companies that participate in those programs. You may also use the links available in advertisements that appear in the Services and learn more about our advertising practices through the About Our Ads link available through the Services.

To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Services, you may still receive advertisements even if you opt-out of tailored advertising. In that case, the ads will just not be tailored.

When using a mobile application you may also receive tailored in-application advertisements. Each operating system, iOS for Apple phones, Android for Android devices and Windows for Microsoft devices provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems to opt-out of tailored in-app advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact the applicable platform operator. We do not control how the applicable platform operator allows you to control receiving personalized in-application advertisements; thus, you should contact the platform provider for further details on opting out of tailored in-application advertisements. We also may use third-party service providers to deliver advertisements on mobile applications or for mobile application analytics. You can opt-out from third-party interest-based advertising on some Android devices and Google apps by visiting Google Settings, Ads and then click on ‘Disable ads based on interests.’ You can also opt out of some interest-based advertising on your mobile device by downloading the Truste Privacy App available at: https://www.truste.com/consumer-resources/privacy-app/.

Please note that to the extent advertising technology is integrated into the Services, you may still receive advertisements even if you opt-out. In that case, the advertising will not be tailored to your interests. Also, we do not control any of the above opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

Notice Concerning Do Not Track Signals

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform online services that they do not want certain information about their webpage visits collected over time and across websites or services. We are committed to providing you with meaningful choices about the information collected on the Services for third party purposes, and that is why we provide links to the Network Advertising Initiative and the Digital Advertising Alliance opt-out pages, as well as choices provided by Google Ads, Google Analytics, and Truste. However, we do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. To learn more about Do Not Track, you can do so here.

UPDATING YOUR INFORMATION AND DATA RETENTION

You may access certain of your information and delete, change, or modify that information through your relevant account settings on the Services. For additional assistance with modifying or deleting information provided to us, contact us at [email protected] Matter.com.

We will keep your information only for as long as is reasonably necessary for the purpose that it has been processed, taking into account any legal requirements under Applicable Law. For the avoidance of doubt, we will retain your information to continue offering the Services to you. If you terminate your account, any association between your account and information we store will no longer be accessible through your account. However, if you have engaged in any public sharing prior to termination, that information will remain on our services and accessible to the public. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

If you wish to verify the details that we hold about you may do so by contacting us via e-mail to [email protected] Matter.com. Our security procedures mean that we may request proof of identity before we reveal information. This proof of identity will typically take the form of your e-mail address and any password submitted upon registration.

SECURITY

We have implemented administrative, technical, and physical security measures to protect against the loss, misuse and/or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect and store. All information you provide to us is stored on secure servers. Any payment transactions will be encrypted using Secure Sockets Layer (SSL) technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website or our service, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure, and although we will do our best to protect your information, we cannot and do not guarantee that the measures we take will prevent every unauthorized attempt to access, use, or disclose your information since despite our efforts, as no Internet and/or other electronic transmissions can be completely secure and any transmission is at your own risk.

It is important for you to protect against unauthorized access to your password and to your computer so we advise that you sign off when you have finished using a shared computer and strongly recommend that you do not use the browser’s password memory function as that would permit other people using your device to access your information. It is important for you to protect against unauthorised access to your password and to your computer so we advise that you sign off when you have finished using a shared computer strongly recommend and that you do not use the browser’s password memory function as that would permit other people using your device to access your information. We recommend that you change your password periodically. You are responsible for maintaining the security of your account username and password. You may not provide these account credentials to any third party. If you believe that your account username and/or password have been stolen or been made known to others, you must contact us immediately at [email protected] Matter.com and change your password immediately. We are not responsible if someone else accesses your account through information that they have obtained from you.To the fullest extent permitted by law, we disclaim all liability and responsibility for any damages you may suffer due to any loss, unauthorised access, misuse or alterations of any information you submit to the Service.

THIRD PARTY LINKS AND SERVICES

The Services may contain links to third-party websites, applications and other services. Please be aware that we are not responsible for the privacy practices of such other sites and services. We encourage our users to be aware when they leave our Services and to read the privacy statements of each and every site they visit that collects their information. Some of these links may be affiliate marketing links encoded by third parties. This means that we may earn a commission when you click on or make Gray Matterases via affiliate links, and affiliate partners may use cookies to understand your use of the Services. For more information about our affiliate marketing practices, please see the Gray Matter

Advertising Disclosure.

The Services may also include widgets and social media features such as the Facebook “Like” button, which are interactive mini-programs that provide specific services from another company (e.g. displaying the news, opinions, music, etc.). Information such as your email address may be collected through these features. These features may collect your IP address and set cookies to enable them to function properly. We are not responsible for nor do we endorse the privacy practices or the content of such third-party services. Any information you provide via those services is subject to their applicable privacy policies and is not covered by this Policy.

CHANGES TO THIS POLICY

We reserve the right to change this Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. Please check this page periodically for changes. Your continued use of the Services following the posting of changes to this Policy will mean you accept those changes.