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Privacy Policy

Effective Date: May 18, 2020
We value the privacy of our customers’ information and we are always striving to make our customer experience better. This Privacy Policy describes our information practices and, in particular, how we collect, use and share the Personal Information that we gather through our Services, as defined below. If you have any questions about this Privacy Policy or our information practices, please contact us through the options provided below.

BY USING OUR SERVICES, YOU CONSENT TO THE INFORMATION PRACTICES AND OTHER TERMS AS DESCRIBED IN THIS PRIVACY STATEMENT.

Who We Are
Arrowhead Promotion & Fulfillment Co. Inc. (Arrowhead) is a provider of Sweepstakes, Rebates, Premiums, Sampling, Loyalty Programs and other Promotion-related Fulfillment Management Services as well as Customer Support Services. We manage and execute these promotions and programs on behalf of our clients' businesses. Many of these programs include the gathering of personally identifiable information as a requirement of consumer or business participation.

This privacy policy tells you how we use the personal information collected. This includes the gathering of data at this site as well as the sites we build on our client's behalf, data gathered through mobile technology and through offline resources. Please read this privacy policy before using the site or submitting any personal information. By providing your information through this site or other program sites, mobile entry or offline, you are accepting the practices described in this privacy policy. These practices may be changed, but any changes will be posted and changes will only apply to activities and information on a going forward, not retroactive basis. You are encouraged to review the privacy policy whenever you visit the site to make sure that you understand how any personal information you provide will be used.

Collection and Use of Information
We collect personally identifiable information, such as names, postal addresses, email addresses, etc., when voluntarily submitted by program participants or site visitors. Use of this data may include but is not limited to: consumer or business response, notification of potential winner, fulfillment of premiums or prizes, opt-in for future marketing efforts, and program reporting. This information is used to fulfill these requirements above, unless you give us permission to use it in another manner, for example to add your information to a mailing list. Personal identifiable information is collected by Arrowhead on behalf of our clients and is the property of our clients. Arrowhead does not share this information with any party other than our clients unless as directed by our clients or as required by law. Arrowhead is not responsible for data collected on behalf of clients when such data is in a client's possession.

Do Not Sell
Arrowhead does not sell, utilize, implement, publish, distribute or otherwise use the protected data for any other purpose whatsoever.

Cookie/Tracking Technology
Our websites may use cookie and tracking technology depending on the features offered. Cookie and tracking technology are useful for gathering information such as browser type and operating system, tracking the number of visitors to the Site, and understanding how visitors use the Site. Cookies can also help customize the Site for visitors. Personal information cannot be collected via cookies and other tracking technology; however, if you previously provided personally identifiable information, cookies may be tied to such information. Aggregate cookie and tracking information may be shared with third parties.

Although most web browsers are initially setup to accept cookies, if you prefer, you may decline the placement of a cookie on your hard drive by using the appropriate features of your web browser software or delete any existing cookies. Users should understand, however, that certain function of this Site may not function properly if your web browser does not accept cookies.

You can find out more about Cookies and how to manage them by visiting www.AboutCookies.org.

You can understand which third parties have currently enabled Cookies for your browser or mobile device and how to opt-out of some of those Cookies by accessing the Network Advertising Initiative’s website or the Digital Advertising Alliance’s website or, if you are located in the European Union, at the Your Online Choices website. For more information on mobile specific opt-out choices, visit the Network Advertising Initiative’s Mobile Choices website.

We use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with the Site, compile reports on the Site’s activity, and provide other services related to Site activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website. The technologies used by Google Analytics do not gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt out of tracking of analytics by Google, click here: https://policies.google.com/technologies/ads

We have implemented certain third-party technologies, including Google Remarketing and Display Advertising features to collect data about visitors to our Site in order to, among other things, deliver advertising content on sites across the Internet in a manner that is specifically directed toward the interests expressed by the visitors while on our Site. Third-party vendors, including Google, use cookies to serve ads based on someone’s past visits to the Site. You can opt-out of Google’s use of cookies to serve ads based on your past visits to the Site via the following link: Google Ad Settings. We do not have access to, nor control over, third parties’ use of cookies or other tracking technologies.

Do Not Track (DNT)
DNT is a privacy preference that you can set in certain web browsers. When you turn on the DNT, the browser may send a signal or other message to web services requesting that they not track you. Currently, our web servers do not recognize or respond to DNT signals. Our websites and mobile applications may continue to collect information in the manner described in this Privacy Policy.

Distribution of Information
We may share information with governmental agencies or other companies assisting us in fraud prevention or investigation. We may do so when: (1) permitted or required by law; or, (2) trying to protect against or prevent actual or potential fraud or unauthorized transactions; or, (3) investigating fraud which has already taken place. The information is not provided to these companies for marketing purposes.

Dispute Resolution
Within the scope of this privacy notice, if a privacy complaint or dispute cannot be resolved through Arrowhead Promotion and Fulfillment Co., Inc.'s internal processes, Arrowhead Promotion and Fulfillment Co., Inc. has agreed to participate in the VeraSafe Privacy Shield Dispute Resolution Procedure. Subject to the terms of the VeraSafe Privacy Shield Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe under the Privacy Shield Dispute Resolution Procedure, please submit the required information to VeraSafe here: https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/

Arrowhead complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Arrowhead has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

In compliance with the Privacy Shield Principles, Arrowhead commits to resolve complaints about our collection or use of your personal information. Any individual with inquiries or complaints regarding our Privacy Shield policy should first contact Arrowhead at: PrivacyDept@apfco.com.

Note: the privacy practices set forth in this privacy policy are for Arrowhead managed programs and websites. If you link to other web sites, please review the privacy policies posted at those sites.

In compliance with the Privacy Shield Principles, Arrowhead commits to the right of individuals to access their personal data. Our organization is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). In cases of onward transfer to third parties of data of EU individuals received pursuant to Privacy Shield, Arrowhead is potentially liable.

Arrowhead recognizes the possibility, under certain conditions, for the individual to invoke binding arbitration and under certain conditions, more fully described on the Privacy Shield website at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

California Privacy Rights
If you are a California user, you have certain rights with respect to the collection, use, transfer, and processing of you “Personal Information,” as defined by the California Consumer Privacy Act (“CCPA”). We reserve the right to limit these rights where permitted under applicable law, including where your identity cannot be reasonably verified or to the extent your rights adversely affect the rights and freedoms of others. To exercise any of the rights below, please contact us via the contact information below. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your personal information.

Collection of Personal Information
Over the previous 12 months, we may have collected the following Personal Information:

Category

Examples

Collected in the Past 12 Months

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some Personal Information included in this category may overlap with other categories.

YES

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

YES

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

YES

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

YES

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements.

YES

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

YES

I. Professional or employment-related information.

Current or past job history or performance evaluations.

YES

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

NO

K. Inferences drawn of the consumer.

Inferences drawn from Personal Information identified above to create a profile about a consumer reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

YES


The examples listed above are illustrative only and do not reflect the specific pieces of information that Arrowhead has collected in the previous 12 months.

Sources From Which Personal Information Is Collected
As a service provider, Arrowhead receives or has access to Personal Information collected by the business, including Personal Information in categories A (identifiers), B (personal), and C (protected classifications). Arrowhead collects information in category D (commercial) by keeping a log of certain transactions in connection with the services provided. Arrowhead uses that Personal Information solely to provide the services to the business. Arrowhead does not maintain any information received in its capacity as a service provider unless such information has been de-identified and aggregated.

In connection with employees and job applicants, Arrowhead collects directly from the individuals information in categories A (identifiers), B (personal), C (protected classifications), E (biometric), H (sensory), and I (employment).

We collect the personal information in categories F (internet and other electronic network activity), G (Geolocation), and K (inferences) based on your interactions with our website and mobile apps.

Business or Commercial Purposes for Which Personal Information Is Collected
Your Personal Information is used for the following purposes:
  • Respond to your requests for services or products
  • Provide you with customer support and respond to your communications
  • Send you transactional or administrative communications, as well as certain service-related announcements
  • Personalize your experience on our Platforms
  • Send you information relating to other programs, services, or products that we believe may be of interest to you
  • Run website analytics to evaluate performance
  • Fulfill our responsibilities as an employer

Third Parties With Whom Personal Information Is Shared
Arrowhead shares your Personal Information with analytics and service providers, benefits providers, transaction processors, and law enforcement (if necessary).

In the preceding 12 months, we have not sold Personal Information about consumers.

In the preceding 12 months, we have not sold Personal Information about minors.

In the preceding 12 months, we have disclosed the following Personal Information about consumers for business purposes:
  • We allow certain companies to use cookies, web beacons, or other online tracking devices to enhance online experiences and customize advertising.  For more information, please see the “Cookies and Other Technical Information” section.

Individual Rights

Right to Know About Personal Information Collected, Disclosed, or Sold
You have the right to request that Arrowhead disclose the Personal Information it collects, uses, and discloses about you to third parties. There are two types of Rights to Know requests that you can make:
  • Right to Know (Abbreviated Request):  If you make a Right to Know (Abbreviated Request), you will receive the following information about you:
    • Categories of Personal Information collected;
    • Categories of sources from which Personal Information is collected;
    • Business purpose for collecting or selling; and
    • Categories of third parties with who sold.
  • Right to Know (Specific Pieces of Information Request):  If you make a Right to Know (Specific Pieces of Information Request), you will receive the following information about you:
    • Specific pieces of Personal Information collected about you.

This information will be provided to you free of charge, unless Arrowhead determines that your request is manifestly unfounded or excessive. You may request this information twice in a 12-month period.

There are certain exceptions to a consumer’s Right to Know, including exceptions relating to employment information and information processed as a service provider. Arrowhead will state in its response if an exception applies.

Right of Deletion
You have the right to request that Arrowhead and our service providers delete any Personal Information about yourself which Arrowhead has collected from you upon receipt of a verifiable request. This right is subject to certain exceptions, including exceptions relating to employment information and information processed as a service provider. Arrowhead will state in its response if an exception applies.

Right to Opt-Out of the Sale of Personal Information
You have the right to opt-out of the sale of your personal information by a business subject to certain laws and regulations.

Arrowhead does not, and will not, sell any Personal Information of California consumers. Arrowhead will update this Privacy Policy and comply with applicable laws and regulations in the event that it sells Personal Information of California consumers in the future.

Right to Non-Discrimination
You have the right not to receive discriminatory treatment for exercising the privacy rights conferred by California law. Arrowhead will not discriminate against you because you exercised any of your privacy rights, including, but not limited to, by: denying goods or services to you; charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing a different level of quality of goods or services to you; or suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Submitting Requests
If you have a request related to information submitted in connection with a promotion, Arrowhead suggests that you submit that request directly to the business holding the promotion. As Arrowhead is only a service provider for those promotions, we may only be able to direct you to that business if you submit the request directly to us. See “Privacy Contact Information” section below for ways to submit requests.

Verifying Requests
Arrowhead provides California consumers with an online web form to submit requests. The web form is accessible at https://apfco.com/secured/wprivacy/. As stated in the web form, Arrowhead must verify that the person requesting information or deletion is the California consumer about whom the request relates in order to process the request. To verify a California consumer’s identity, we may request up to three pieces of Personal Information about you when you make a request to compare against our records. We may also request that you sign a declaration under the penalty of perjury from the consumer whose personal information is the subject of the request.

Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in your request to verify your identity and will delete any information you provide after processing the request. Arrowhead reserves the right to take additional steps as necessary to verify the identity of California consumers where we have reason to believe a request is fraudulent.

Authorized Agents
You may choose a person registered with the California Secretary of State that you authorize to act on your behalf to submit your requests (“Authorized Agent”). If you choose to use an Authorized Agent, Arrowhead requires that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with Arrowhead. Failure to do so may result in Arrowhead denying your request.

Privacy Contact Information
If you have any questions, concerns, or comments about our privacy policy or your California privacy rights, you may contact us at (800) 950-9914, or via email at PrivacyDept@apfco.com or via website at https://apfco.com/secured/wprivacy/, or via mail at Attn: Privacy Dept., 1105 SE 8th St. Grand Rapids MN 55744.

We reserve the right to make changes to this policy at any time.

Last Updated: May 18, 2020