FRICTIONLESS LLC
PRIVACY POLICY
Frictionless LLC (“we”) has created this statement (this “Privacy Policy”) to explain and summarize how we use and protect, or in some cases do not protect, your personally-identifiable information (“PII”) that we collect through our websites, services, and related software (collectively, the “Services”). We reserve the right to change this Privacy Policy at any time by posting a new Privacy Policy at https://app.frictionlessguest.com/common/legal/privacy.aspx. You are responsible for periodically checking https://app.frictionlessguest.com/common/legal/privacy.aspx for changes. By accessing the Services, you indicate your understanding and acceptance of the terms of this Privacy Policy, and consent to the collection, retention and use of your PII consistent with this Privacy Policy, as amended from time to time. Your use of the Services is governed at all times by the Terms of Use for the Services, which may be found at https://app.frictionlessguest.com/common/legal/privacy.aspx. If you are accessing the Services from outside the United States, there may be other laws applicable to your PII.
1. INFORMATION WE COLLECT
We collect PII that you provide to us or that we learn from your use of the Services.
We also collect and maintain your PII on behalf of our clients. Your PII may be contained in more than one of our clients’ databases. Our collection and use of PII on behalf of our clients is performed as a service provider for our clients and in accordance with our contracts with our clients. Note that our clients have their own privacy policies (which may differ from ours), and our clients may use your PII in whatever manner is permitted under such policies. In other words, the PII that we collect and/or use on behalf of our clients is governed by both their respective privacy policies, and ours, depending on whether that PII is being used on behalf of a Client or us.
We may collect PII from you in several ways:
· In order to access certain aspects of the Services, you may be required to provide us certain PII such as your name, email address, telephone number and hotel loyalty/reward program number. REGARDLESS OF ANY OTHER PROVISION OF THIS PRIVACY POLICY, WE MAY PERMANENTLY STORE ANY PII PROVIDED BY YOU VIA SUCH DATA COLLECTION PROCESS.
· We may collect PII from you through your use of the Services.
· We may observe and track aspects of your activities, preferences, and transactions relating to your use of the Services, such as any ratings and/or reviews you provide relating to “eat, play and shop” attractions and coupons you access.
· You may provide us with PII in connection with a job application or inquiry.
· We may collect, on behalf of our clients, any and all information, including PII, that is stored, accessed, communicated via, or otherwise made available to them by you, via use of the Services or otherwise.
· We may collect information regarding the physical location of your computer, mobile device or other means by which you might access the Services.
· We will place a “cookie” information file on your browser when you use our Services to store and track information about you, including your PII. Cookies cannot damage user files, pass on computer viruses, capture e-mail addresses or read information from a user’s hard drive. We will use cookies to measure certain traffic patterns and to track your activities while using our Services. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to sign in or use some features of our Services that depend on cookies.
· We may observe technical aspects of your activities, preferences, and transactions (such as your IP address) relating to your use of the Services, via the use of “cookies” or otherwise.
· We may correlate the information we collect about you via cookies to your account and/or other PII we have collected about you, in order to be able to improve and provide the Services.
2. USES OF COLLECTED INFORMATION
We do not share your PII with third parties other than our clients for their direct marketing purposes, unless you permit us to do so, including via accessing and redeeming coupons that you obtain through use of the Services.
Performance of the Services. We may use your PII to diagnose technical problems, to facilitate your use of the Services, to track aggregate traffic patterns throughout the Service, or to otherwise improve the performance and utility of the Services.
Notifications. We may use your PII and other information you provide through your use of the Services (or otherwise) to notify you about changes to the Services and new products and services. We may also use such information to develop generic “personas” and/or to track your individual preferences, both of which we may use to provide you with information on, or special offers relating to, attractions that may be of interest to you. If you enable location tracking via your mobile device, we may deliver to you information on, or special offers relating to, attractions based upon your physical location as well. Any third party ads will be served anonymously, and, unless you click-through such ads, redeem the offers displayed, or otherwise affirmatively engage with the ad or the advertiser, the advertiser will not have access to your PII.
Service Providers. We may use third parties to provide services for us, such as data entry. Such third parties are prohibited from using the PII we provide to them for any other purpose than the provision of services to us.
Human Resources. If you provide your PII to us as part of an application for employment, we may use that PII for the purpose of employment consideration. We may keep your PII on file for future consideration.
Mergers, Acquisitions and Bankruptcy. We may transfer all PII in our possession to a successor organization in the event of a merger, acquisition, or bankruptcy or other sale of all or a portion of our assets. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred PII will be subject to this Privacy Policy, as it may be amended from time to time.
As Required by Law and Other Extraordinary Disclosures. We may disclose your PII to: (a) comply with legal process (such as a court order, subpoena, search warrant, etc.) or other legal requirements of any governmental authority; (b) potentially mitigate our liability in an actual or potential lawsuit; (c) protect our rights or property; or (d) protect the interest of other users of the Services.
Aggregation of Information. In support of our operations and business activities, we may aggregate data that individually might be considered PII, but as a result of the aggregation, becomes anonymized. For example, while your specific address would be PII, data on the overall number of subscribers with addresses in your zip code would not be able to be used to identify you, and is therefore not PII. We will ensure that sample sets and categories across which we aggregate are broad enough to preclude identification of individuals. Since this aggregated information is not PII, we may use it internally or disclose it to third parties for any purpose and without reference to this Policy.
3. CHILDREN
Children under the age of 18 are not permitted to register with us or to provide us with any PII. We do not intentionally or knowingly collect any PII from children under the age of 18, and if we become aware that any PII in our possession was collected from a child under the age of 18, we will remove such PII from our active user database and no longer use it. We may keep a copy of such PII in archive files for legal compliance purposes, but will do our best to ensure that such PII is used or accessed for only such legal compliance purposes.
By registering with us or use or otherwise providing PII to us, you are representing to us that you are either at least 18 years old.
4. SECURITY
We use reasonable security measures to protect data transmissions. However, no data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. We are not responsible for circumvention of any privacy settings or security measures in the Services.
You understand and acknowledge that, even after you stop using the Services and attempt to delete your PII from the Services, copies of your PII and other materials posted by you may remain viewable in, for example, cached or archived pages.
If we learn of a security breach that affects you, we will attempt to notify you electronically so that you can take appropriate protective steps. By using the Services or otherwise providing PII to us, you agree that we can communicate with you electronically, including regarding security, privacy and administrative issues. We may post a notice on the Services if a security breach occurs. We may also send an email to you at the email address you provide to us during registration, as updated by you.
5. CONTACT PREFERENCES
Generally, when we contact you, we will try to provide you with an easy and convenient way to notify us if you would not like further similar communications.
6. CONTACTING US
If you have any questions, comments, or concerns about this Privacy Policy, or would like to make changes to your PII, or delete PII you have provided to us, please email us at guest.support@frictionlessguest.com or contact us at the address below. You may make changes to your PII through the Services.
Postal Mail Address:
Frictionless LLC
Attn: Privacy Support
P.O. Box 610
Highland, MD 20777
-------
Updated: 2 April 2015