Effective Date: July 31, 2019.
We at News America Marketing Interactive L.L.C. and News Marketing Canada Corp. (collectively, “SmartSource”), and News America Marketing Digital LLC (“Checkout 51”) (SmartSource and Checkout 51 together, “NAM” or “we”), respect your concerns about privacy. This Privacy Notice (“Notice”) applies to personal consumer information obtained by Checkout 51 and SmartSource, including through (1) www.checkout51.com and www.checkout51.ca, (2) www.smartsource.com, www.smartsource.ca and www.utilisource.ca, (3) the Checkout 51 and SmartSource mobile apps, (4) marketing experiences accessed via scannable quick response (QR) codes, near field communications or other methods, which may or may not relate to the brands, websites and/or apps listed above, (5) surveys, product sampling and other offer distribution opportunities and (6) emails related to the above ((1) through (6), collectively, the “Services”).
The Notice describes the types of personal information we obtain about consumers, how we use the information and with whom we share it. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices. The Services are for a general audience, are not targeted to children, and we do not knowingly collect personal information from children under 13 years of age.
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Information We Obtain
We obtain personal information about consumers through the Services, publicly and commercially available sources and from our NAM affiliates and/or business partners (such as consumer product companies, retailers, social media networks, etc.). The types of personal information we may obtain include:
Contact information (such as name, postal address, email address and telephone and/or mobile numbers);
Username and password when you register through our Services;
Other registration information such as store loyalty card numbers you elect to register;
Information on receipts made available to us through the Services, such as the items and date(s) of your purchases, prices of the items, methods of payment, the last four digits of your credit card number, signature, and names and locations of the merchants (“Receipt Data”);
Purchase transaction data and other data provided by our business partners that we match to you through information you have provided to us, such as store loyalty card numbers, contact information or other identifying information;
Contact information for friends or other people you would like us to contact
Other information you may provide to us, such as through our “Submit a Request” feature.
Information Obtained by Automated Means Through Our Services
A “cookie” is a file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. Through these automated collection methods, we obtain “clickstream data,” which is a log of the links and other content on which a visitor clicks while browsing a website. As the visitor clicks through the website, a record of the action may be collected and stored. We also may use similar automated means to obtain and store information regarding your actions while using our mobile apps.
We may link certain data elements obtained through automated means, such as your browser or device information, with other information we have obtained about you to let us know, for example, whether you have opened an email we sent to you, what search queries you may have run and what advertisements you may have seen on our Services or on third-party websites and apps. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. You also may be able to delete your Flash cookies or adjust your Flash cookie settings by visiting the Adobe Flash Website Storage Settings Panel and Global Storage Settings Panel. Please note, however, that without cookies you may not be able to use all of the features of our Services, and location services must be enabled through your mobile operating system for certain location-based elements of the Services to operate. Your device settings also may allow you to prohibit mobile app platforms (such as Apple and Google) from sharing certain information obtained by automated means with app developers such as Checkout 51 and SmartSource.
In addition, if you register for Checkout 51 or SmartSource through or connect your Checkout 51 or SmartSource account to a third-party social media network or service (such as Google, Facebook or Twitter), we may obtain certain information about you from the relevant social media network or service, such as your user ID and/or user name associated with that social media network or service, the information contained in your public profile on the social media network and friends lists. The specific information we obtain depends on your privacy settings on the applicable social media network or service.
The providers of third-party apps, tools, widgets, plug-ins and application programming interfaces (APIs) on our Services, such as social media sharing tools and location-based services, also may use automated means to collect information regarding your interactions with or use of these features. This information may be collected directly by the providers of those features or shared by us with such providers and is subject to the privacy policies or notices of those providers. NAM is not responsible for those providers’ information practices.
How We Use the Information We Obtain
We may use the information collected from and about you to:
Provide our products and services, such as coupon delivery services and offers based on your location;
Create and manage online accounts;
Send promotional materials, alerts regarding available offers and other communications, including communications through the Services and outside of the Services, such as via mail, email and through third-party websites and apps;
Communicate about, and administer participation in, special events, promotions, programs, offers, surveys, contests and market research;
Respond to inquiries from you and other third-parties, including inquiries from law enforcement agencies;
Anonymize personal information to provide third parties with aggregated data reports showing anonymized information and other non-personal information;
Supplement your personal information collected from you with additional information from publicly and commercially available sources, and/or information from NAM affiliates and our business partners;
Associate your browser and/or device with other browsers or devices you use for the purpose of providing relevant and easier access to content, advertising across browsers and devices, and other operational/business purposes;
Operate, evaluate and improve our business (including developing, enhancing, analyzing and improving our Services; managing our communications; performing data analytics; and performing accounting, auditing and other internal functions);
Protect against, identify and prevent fraud and other unlawful activity, claims and other liabilities, including to protect against offer stacking and enforce other offer restrictions; and
Comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies.
We may use third-party analytics services on our Services, such as those of Google Analytics. The analytics providers that administer these services use technologies such as cookies, web beacons, web server logs and similar technologies to help us analyze your use of the Services. The information collected through these means may be disclosed to these analytics providers and other relevant third parties who use the information, for example, to evaluate use of the Services. To learn more about how to opt out of Google Analytics services, please visit the link below:
Google Analytics: https://tools.google.com/dlpage/gaoptout
We also may use your personal information in other ways for which we provide specific notice at the time of collection.
Through our Services, we and our third-party service providers may obtain information about your activities to provide you with advertising about products and services tailored to your individual interests. We and our third-party service providers also may obtain information for this purpose from third-party websites and apps. This section of our Privacy Notice provides details and explains how to exercise your choices.
We engage third-party advertising networks to help us target our messaging to visitors through interest-based and contextual means. Through these ad networks , we can track your online activities over time and across third-party websites and apps by obtaining information through automated means, as described above. The networks use this information to show you advertisements on our Services or other third-party websites and apps that may be tailored to your individual interests. The information our ad networks may obtain on our behalf includes data about your visits to websites and use of apps that serve NAM advertisements, such as the pages or ads you view and the actions you take on the websites or apps. This data collection takes place both on our sites, apps and emails and on third-party websites and apps that participate in these ad networks. This process also helps us track the effectiveness of our marketing efforts. To learn how to opt out of this ad network interest-based advertising,
To the extent required by applicable law, we will obtain your consent before using your information for interest-based advertising.
Our sites are not designed to respond to “do not track” signals from browsers.
If you so elect, you may provide your mobile phone number to NAM. By submitting your mobile phone number, you consent to receive text message alerts from NAM containing promotions, offers, contest and event information, or product information that may be sent using automated dialing systems (“Text Messages”). Your consent to receive Text Messages is not otherwise required to purchase or receive any goods or services from us. You may not consent to receive Text Messages on behalf of someone else or provide someone else’s phone number. You agree to enter into, sign and receive your consent to receive Text Messages electronically. You can contact us as set forth under “How to Contact Us” below to request a free copy of your consent.
You may receive recurring Text Messages. We do not charge a fee for you to receive Text Messages from us; however, your mobile service provider may charge you for sending and/or receiving Text Messages and air-time, as well as any other standard applicable rates charged by your mobile service provider.
Text Messages are distributed via third party mobile network providers and, therefore, we cannot control certain factors relating to message delivery or guarantee availability or performance of this service, including liability for transmission delays or message failures. To receive help with Text Messages, you can contact us as set forth under the How to Contact Us Section below.
You may unsubscribe from receiving NAM Text Messages any time by texting the word “STOP” to the short code listed here from your device. You may also choose not to receive Text Messages by contacting us as set forth under the How to Contact Us Section below and specifying that this is your preference.
We may also obtain the date, time and content of your messages in the course of your use of Text Messages. We will use the information we obtain in connection with our Text Messages in accordance with this Privacy Notice.
From time to time you may be asked to provide your mobile phone number to NAM in connection with specific text messaging programs. Some text messaging programs may have additional or different terms and conditions from those set forth above, which will be presented to you at the time that you opt-in to receive those Text Messages.
In general, in order to stop receiving Text Messages from a specific NAM text messaging program, you can text STOP to the short code for the text messaging program from which you no longer wish to receive message (i.e., the number from which its Text Messages are being sent). You will then receive confirmation of your opt-out of that text messaging program. This will only opt you out of the specific text messaging program associated with that short code. You will remain opted in to any other NAM text messaging programs that you have signed up for.
Push Notifications and In-App Alerts and Updates
When you download one of our mobile applications, we may provide you with the option to opt in to receive push notifications from NAM on your mobile device in connection with that mobile application. These push notifications may include promotional communications regarding NAM products and services. You may, after downloading the applicable mobile application, opt out of receiving push notifications by adjusting the settings on your mobile device. Opting out of push notifications will not affect other communications you receive from NAM, such as email communications. You also may receive alerts and updates within our mobile applications regarding NAM products and services or your NAM accounts. To opt out of receiving these alerts and updates, you may uninstall the applicable mobile application from your mobile device.
We may share consumer personal information with
Our subsidiaries and affiliates, any of whom may use your personal information consistent with this Privacy Notice or for the subsidiary’s or affiliate’s own purposes, including marketing purposes. A current list of our affiliated companies is available at https://checkout51.com/affiliatedcompanies.
Service providers in the US and other jurisdictions who perform services on our behalf.
Our third party clients or business partners, such as consumer product companies and other third parties for those third parties’ own marketing purposes, such as to serve targeted advertisements.
From time to time, using encryption technology, we may compare our consumer member databases with our affiliates’, clients’ and/or partners’ databases to identify overlap between the databases. When there is an overlap between databases, we may share with those affiliates, clients and/or partners information such as Receipt Data and other data in our possession, including data collected via automated means, as described above, of the matched consumers. Those parties may use this information as permitted under their own privacy notices, including to contact consumers and/or to send targeted advertising or other promotional materials.
In addition, when the information collected from or about you does not identify you as a specific person, we may share it with third parties.
The Services may include iFrames that allow a third party to provide you with additional services, features or functions. For example, on www.smartsource.com, www.smartsource.ca and the SmartSource mobile app, we may include iFrames that allow a third party to provide you with the ability to load coupons directly onto store loyalty cards or payment cards. We do not collect the personal information you provide in these iFrames. Rather, the personal information you provide for that feature is obtained by the third party providing the ability to load promotions directly onto your card. We will notify you when you go to one of these iFrames and provide a link to the relevant third party’s privacy notice. We recommend you review the third party’s privacy notice before submitting any personal information.
In addition, we may disclose information about you (1) if we are required to do so by law or legal process, (2) to law enforcement authorities or other government officials, and (3) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We also reserve the right to transfer personal information we have about you in the event of a proposed or completed sale or transfer of all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).
We offer you certain choices in connection with the personal information we obtain about you, such as how we communicate with you.
To update your preferences, ask us to remove your information from our marketing emailing lists (such as Checkout51’s weekly reminder email) or submit a request, please contact us as outlined in the How to Contact Us Section below. Additionally, all users can change their notification preferences and Canadian users can change their email and data sharing preferences in the Settings section of the Checkout 51 mobile app.
You also can unsubscribe from our marketing emailing lists by following the “Unsubscribe” link in our emails.
In general, in order to stop receiving text messages, you can text STOP to the short code for the text messaging program from which you no longer wish to receive message (i.e., the number from which the text messages are being sent). You will then receive confirmation of your opt-out of that text messaging program. Please note that this will only opt you out of the specific text messaging program associated with that short code. You will remain opted in to any other NAM text messaging programs that you may have signed up for. To unsubscribe from the NAM general marketing text messaging program you can text “STOP” to the short code listed here from your device.
You may also choose not to receive text messages by contacting us as outlined in the How to Contact Us Section below and specifying that you no longer want to receive Text Messages.
To turn on or off location-based services, you can adjust the settings within your mobile operating system (e.g., currently for iOS, you can go to Settings → Privacy → Location Services → Checkout 51).
Accessing, Reviewing, Updating and Modifying Personal Information
You have the right to access, review, update, and correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law. You may request access, updating and corrections of inaccuracies in your personal information by emailing or writing to us at the contact information set out below. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.
To learn more about how to opt out of ad network interest-based advertising, please visit the consumer opt-out pages at:
In Canada: http://youradchoices.ca/choices.
Notice To California Residents
Subject to certain limitations, California residents may ask us to provide them with (1) a list of certain categories of personal information that we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and (2) the identity of those third parties. To make this request, California residents may contact us as specified in the How to Contact Us section below.
How We Protect Personal Information
We maintain administrative, technical and physical safeguards designed to protect the personal information we have about you against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
Transfers of Information
For your convenience and information, our Services may provide links to third-party sites, apps and services that may be operated by companies not affiliated with NAM. These companies may have their own privacy notices or policies, which we strongly suggest you review. We are not responsible for the privacy practices of any non-NAM sites, apps or services.
Updates to Our Privacy Notice
This Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our personal information practices. For significant changes, we will notify you by posting a prominent notice on our Services indicating at the top of the Notice when it was most recently updated.
How To Contact Us
If you have any questions or comments about this Privacy Notice or the manner in which we or our service providers treat your personal information, would like to exercise your choices, or would like us to update information we have about you or your preferences, please contact us as follows:
Checkout 51: support request
You also may write to:
News America Marketing
20 Westport Road, First Floor S.
Wilton, CT 06897
Canadian residents may also contact our Privacy Officer by email at email@example.com.