Last Updated June 4, 2020
Colu is providing municipalities in the United States with services that are intended to increase civic engagement, promote city goals, encourage local spending and support local businesses. This is done through Colu’s technological platform, which includes the Application. The Application is localized to each of the municipalities that are engaging Colu (each of them will be referred to as “City”); City is providing you with its own services through the Application, including, e.g., a municipal reward program (the “Reward Program”).
The Application contains links to and from websites and platforms of third parties, such as merchants, social platforms and others. Please note that these websites, platforms, and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites, platforms or services, such as contact and location data. Please check these policies before you submit any personal data to these websites and platforms or use these services.
2. Types of Private Information We Collect and How We Collect It
Information you provide to us. This is information, including Personal Information, that you agree to give us about you by filling in forms in the Application or the Website, or otherwise submitting such information, e.g., by corresponding with us (for example, by email or chat) or by phone. It includes information you provide when you register to use the Application (such as your name and email address), share data via the Application social media functions, if available, enter a competition, promotion or survey, and when you communicate with us for customer service or technical support for the Services. If you contact us, we may keep a record of that correspondence.
In signing up to the Application, you expressly consent to receive mobile phone text messages, push notifications and emails from us or from City to the mobile phone number and email address you provided us, including marketing and promotional communications. You can opt-out from receiving marketing and promotional emails and text messages by adjusting the relevant settings in the App or by contacting us at [XXXX@YY.com]. You may also follow the unsubscribe instructions in any promotional email you receive. Please note that certain Services-related messages that we send (including emails we may send on behalf of City) are necessary for the proper functioning and use of the Services and you may not have the ability to opt-out of those messages. You may opt-out from receiving phone notifications by adjusting the preferences in your mobile phone.
Information Collected from Devices. When you access or use the Services via a computer or mobile device, including, without limitation, a desktop computer, laptop, mobile phone, tablet, or other electronic device (each, a “Device”), we may collect information from your Device, such as your Device type and manufacturer, your Device operating system and version, your mobile carrier, your Device identifiers, your mobile phone number, your IP address, your browser type, your network connection type, information about the webpage that referred you to the Website or that you visited prior to the Website, and your behavior and activity on the Website and the Application. This includes, for example, details of your usage of the App, such as details of your participation in reward offers in the App, your reward balance and information on rewards awarded to you and redeemed by you through the Application at any of the Redeeming Merchants’ stores (each, a “Redemption Purchase”).
In addition, if you download the Application to your mobile Device, we may collect information from your mobile Device about your location. We may use this information to provide targeted offers to you and notify you of nearby third-party locations where you may use the Services. You may opt out of the collection of location data at any time by changing your settings on your mobile Device or your preferences in the App settings. However, if you do so, certain features of the Services may not be available to you or the performance of certain features of the Services may be limited or not work at all.
- Session Cookies: Session Cookies are temporary Cookies that expire and are automatically erased when you close your browser window. We may use session Cookies to grant you access to content and to enable actions that require you to be logged into your Account to perform.
- Persistent Cookies: Persistent Cookies are Cookies that usually have an expiration date in the distant future and remain in your browser until they expire or you manually delete them. We may use persistent Cookies to better understand usage patterns so we can improve the Services. For example, we may use a persistent Cookie to associate you with your Account or to remember your choices for the Services.
Information Collected from Third-Party Payment Card Information Vendor:
Once you have linked a payment card (or cards) to the App, Colu would receive from Plaid information from the financial account relating to that payment card, such as Information about transactions e.g., amount, date, payee, type, quantity, price, location, and a description of the transaction (“Transaction Information”) as well as general information on the financial account and any account associated with it, such as the financial account’s financial institution name, account name, account type, account ownership and the last 2-4 alphanumeric characters of an account’s official account number.
By linking your payment card, you:
Authorize Colu to receive, process and store the information provided by Plaid as described above and to monitor the Transactional Information on your linked payment card financial account in connection with identifying potentially qualifying purchases under the City’s Reward Program.
Please note that you are not obligated to link a payment card to the App, and you may opt-out of the information collection, processing and transaction monitoring on the payment card(s) you have linked by de-linking them through the Application. However, if you do not link a payment card, you will not be able to take advantage of reward offers that are based on completing qualifying purchases at local merchants, should City initiate such reward offers.
Information from Other Third Parties and Publicly Available Sources
We may receive personal data about you from third parties and public sources, such as data from analytics providers, and name, contact information, profile photo and other account/profile information from social networks such as Facebook and providers such as Apple if you choose to register to the App through these services (should such an option be available).
3. How We Use Private Information
offer and improve the Services and City’s services, including advising City on creating and personalizing content and reward offers;
analyze usage of the Services and City’s services;
alert you to software compatibility issues;
deliver any notices or alerts and communications relevant to your use of the Services or City’s services, including on behalf of City;
for marketing and advertising purposes including on behalf of City, including sending you promotional material or special offers on our behalf or on behalf of City or other third parties, provided that you have not already opted-out of receiving such communications;
to fulfill contracts we have with you, our contract with City, and to assist City in fulfilling its contracts with you;
offer you other products, programs, or services that we or City believe may be of interest;
perform market research, project planning, product development, troubleshooting problems, and analysis of user behavior;
detect, prevent and investigate actual or suspected fraud, hacking, infringement, or other misconduct involving the Services;
comply with any applicable laws and regulations and respond to lawful requests;
Investigate and resolve complaints, defend against legal claims and potential litigation, including on behalf of City
4. How We Share Information
With Merchants: On behalf of City, we may share your Personal Information with merchants with whom you made a potentially qualifying purchase under the terms of the Reward Program, to inform them where a transaction occurred as needed for the merchant to confirm a specific transaction occurred; for example, we may share the date and amount of your purchase so the merchant can verify your purchase with its records or confirm if there is a missing or disputed transaction. We may share with Redeeming Merchants similar information, on behalf of City, to verify a Redemption Purchase and its details. In addition, we share with Redeeming Merchants your full name (as you have registered it in the App).
We may also share some or all of your Personal Information –
with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us;
you request or authorize it, or to provide a service requested by you;
with Third-Party Service Providers that provide services to support the Services, such as data analysis, email delivery, hosting, infrastructure, network storage, customer service, technical support, and promotional services who are bound by contractual obligations to keep the information we provide them confidential.
to comply with applicable laws, rules, and regulations, and to comply with governmental and regulatory requests, court orders, and subpoenas;
to protect our rights, property, and safety and the rights, property, and safety of City and of others
In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Private Information may be shared and may be part of the transferred assets.
We take the security of your Personal Information seriously. We use technical, physical and administrative safeguards, such as, but not limited to, firewalls, encryption techniques and authentication procedures to maintain the security of your Information. Unfortunately, no collection or transmission of information over the Internet or other publicly accessible communications networks can be guaranteed to be 100% secure, and therefore, we cannot warrant the security of any such information. We are not responsible for the circumvention of any privacy settings or security features. You agree that we will not have any liability for misuse, access, acquisition, deletion, or disclosure of your Information.
We may provide you with the option to protect the access to the App with a code/password you select. We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages).
6. Children’s Information
The Services are not intended for children, and we do not knowingly attempt to solicit or receive information from children on the Services. If we learn we have collected or received personal information from a child under the age of 13 without verification of parental consent, we will take steps to comply with any applicable legal requirement to remove such Information. Please contact us if you believe that we have mistakenly or unintentionally collected Information from a child under the age of 13.
7. Contact Information