Tremendous Privacy Policy

Welcome to our website. Your privacy is important to us and we value the trust you place in us.

Tremendous provides various reward, incentive and other products and services (“Client Services”) to corporate clients (our “Clients”), and our Clients provide these rewards, incentives and other products (“Rewards”) and services to individuals (“Recipients”) for redemption.

This Privacy Policy describes the types of information that Tremendous, LLC (“Tremendous”, “us” or “we”) collects, uses and discloses as a “controller” or “business” about (i) employees and representatives of current, past and prospective Clients (“Authorized Users”), including in relation to their use of the Client Services (ii) Recipients who choose to redeem Rewards received from one of our Clients, (iii) individuals who use our website at www.tremendous.com, or other websites we operate and link to this Privacy Policy, (collectively, the “Site”) or otherwise interact with us, including via email or through other applications, services, tools, and features that we offer, and (iv) individuals who apply for a job with Tremendous (collectively, our “Services”). For the purposes of this Privacy Policy, “you” and “your” means you as the user of the Services, whether you are a Client, Authorized User, Recipient, website visitor, job applicant, or another individual whose information we have collected pursuant to this Privacy Policy. This Privacy Policy sets forth our policy with respect to the collection, use and disclosure of information that is collected through the Services. By using or accessing the Services, you acknowledge that you have read, understood and agree to be bound by the terms of this Privacy Policy and Terms of Service, and agree to the data collection, use, disclosure and storage practices described in this Privacy Policy. For the purpose of applicable data protection laws, we are the “business” or “controller.”

This Privacy Policy does not apply to our collection, use and sharing of information about Recipients that we receive directly from one of our Clients when providing the Client Services. In those circumstances, Tremendous is generally a “data processor” or “service provider” under applicable data privacy laws, and not a “controller” or “business”, and we only process and use the data in accordance with the documented instructions of our Client, and strictly on their behalf, subject to our agreement and data processing addendum entered into with our Client. Our Clients are solely responsible for meeting any legal requirements applicable to “data controllers” or “businesses” (such as establishing a legal basis for processing and responding to data subject rights requests). If you have any questions about the Client Services and your use of data by our Clients, please reach out to the relevant Client directly.

Tremendous works with financial institutions, and may disclose certain information to them, in order to facilitate the redemption of some Rewards. Due to the requirements of such financial rules and regulations, including anti-money laundering laws, Tremendous may not be able to delete your information, even upon your request.

Information Collection

Depending on how you interact with the Services, we may collect different types of information about you, including as set out below.

1. Information You Provide to Us

2. Prospective or Current Clients and Authorized Users

Basic contact details: Name, address, email address, telephone number, mobile telephone number and information about the Client.

Tremendous account credentials: Username, password, security questions, to help us maintain and secure your account with us. If you choose to use register an account, you are responsible for keeping your account credentials safe. We highly recommend that you do not disclose your username, password, or other access details to anyone else. If you believe your account has been compromised, please contact us immediately.

Payment information: Bank account information, payment card information, or other financial account information**, billing address.** A third-party payment processor collects and processes payment card information on our behalf; we do not collect or retain your payment card information.

The information listed above is required to enable us to fulfil our contract with you. If you do not provide this information, we will not be able to provide you with our Services.

If you access the Client Services as an employee or representative on behalf of one of our Clients, you are considered an Authorized User under the Client's contract with us. Your use of the Client Services is subject to our contract with our Client, as well as this Privacy Policy and our terms of use. If you have questions about the collection and use of your information as part of us providing Client Services, please contact the Client, who may be your employer. The Services and Client Services are not intended to collect personal health information or other sensitive information about you as an Authorized User. Any such information should remain with the Client.

1. Recipients

Basic contact details: Depending on how you choose to redeem your Reward, we may collect from you your name, address, email address, mobile telephone number.

Demographic information: If you choose to redeem your Reward via a prepaid card, then we will collect your date of birth. At our Client’s election, depending on the value of the Reward, we may collect information about your citizenship. We collect this information to facilitate your redemption of the Reward and to comply with applicable laws and regulations.

Government Identifiers: Depending on the value of the Reward, you may be required to provide your Social Security number, Tax Payer Identification number, Employer Identification number, Internal Revenue Service account number. We collect this information to comply with applicable laws and regulations.

Transaction and redemption data: Depending on how you redeem your Reward, we may collect from you your bank account information, PayPal or other financial account information, and information about redemption of a Reward, including related transactions made on any prepaid cards.

1. Site Visitors

Basic contact details: Name, address, email address, telephone number, mobile telephone number and other information you provide in a webform or when communicating with us.

1. Job Applicants

Basic contact details: Name, phone number, email address and other contact information you may provide us.

Applicant details: Information included in your resume or CV, cover letter, LinkedIn profile, your website/portfolio, any other information you provide when applying for a role with Tremendous, including in your interview.

Professional and education-related information: Information about your professional qualifications, employment and education history, proof of eligibility to work, references, background check and other information you provide during the application or interview.

1. Information We Collect Automatically and Cookie Policy:

As is true of most Web sites, we automatically gather information about your computer such as your Internet Protocol (“IP”) address, browser type, referring/exit pages, and operating system.

Like many other Web sites, we also may use cookies (small text files that a website saves on your computer or device when you visit the Site), web beacons, pixel tags, log files or other technologies (“Cookies”), including Google Analytics, to automatically collect certain information about how you use our Services and interact with our emails and Site. This information may include:

• Device information: IP address, device identifiers, mobile device identifier, Media Access Control address, operating system, device model software version, mobile or ISP carrier information.

• Browser information: Browser type.

• Location information: Approximate location (based on IP address).

• Other information regarding your interaction with the Services and Site: Statistics on your Site views, traffic to and from our Site, referral URL, ad data, how you search for our Services, the websites you click on from our Site or emails, whether and when you open forward or click-through our emails and ads, domain name from which you accessed the Site, date and time you access the Site, areas or pages of the Site that you visit, amount of time you spend on the Site, and the number of times you return to the Site

How we use Cookies. We use Cookies (and the similar technologies noted above) to help us provide and improve the Services (such as remembering your choices and settings and facilitate automated activity), to verify your account, remember your actions, settings and preferences (such as login, language, font size and other display preferences), assist you with storing and tracking your passwords (so you don’t have to keep re-entering them), and to help us review and better understand how people use our Services. We use different types of Cookies on our Site:

• Session Cookies – These allow websites to link the actions of a user during a browser session, and may be used for a variety of purposes. These session Cookies expire after a browser session so would not be stored longer term. For this reason session Cookies may sometimes be considered less privacy intrusive than persistent Cookies.

• Persistent Cookies – These are stored on a users' device in between browser sessions which allows the preferences or actions of the user across a site (or in some cases across different websites) to be remembered. Persistent Cookies may be used for a variety of purposes including remembering users' preferences and choices when using a site or to target advertising.

• First and third party Cookies – Whether a Cookie is 'first' or 'third' party refers to the website or domain placing the Cookie. First party Cookies in basic terms are Cookies set by a website visited by the user - the website displayed in the URL window. Third party Cookies are Cookies that are set by a domain other than the one being visited by the user. If a user visits a website and a separate company sets a Cookie through that website this would be a third party Cookie. We allow third parties such as Google, Facebook, Segment, Bing and LinkedIn to use Cookies to collect information from the Site and elsewhere on the Internet (including your browsing activity across other websites) and use that information to provide analytics and measurement services and tailored advertising.

Tracking Options and Cookie Preferences. Cookies can expire at the end of a browser session (from when a user opens the browser window to when they exit the browser) or they can be stored for longer. You may adjust your browser or operating system settings to allow all Cookies or perform the following functions: delete all Cookies; block all Cookies; block third party Cookies; clear all Cookies when you close the browser; open a ‘private browsing’/‘incognito’ session (which allows you to browse the Internet without storing local data); and install add ons and plug ins to extend browser functionality. However, by doing so, you may not be able to use certain features or take full advantage of all of our offerings. You can find information about how to control Cookies as follows: Microsoft Edge Cookies information; Chrome Cookies information; Firefox Cookies information; Safari Cookies information; Opera Cookies information. Check the “Help” menu of your browser or operating system to learn how to adjust your tracking settings or Cookie preferences.

To learn more about the use of Cookies to deliver more relevant advertising and your choices about not having this information used by certain companies for tailored advertising, please click here or here. To opt out of Google Analytics, you may also download Google’s opt-out browser add-on here. The Internet Advertising Bureau website allows you to install opt-out Cookies across different advertising networks, see here. New technologies such as Mozilla allow you to tell websites not to track you, please click here. On your mobile device, you can adjust your privacy and advertising settings to limit your tracking for advertising or control whether you receive more relevant advertising. By choosing to continue to use this site without changing your Cookie setting, we will assume that you are consenting to receiving Cookies.

1. Information Obtained from Third Parties

Finally, we may obtain information about you from third parties or publicly available sources. Such information may include:

• Information collected about Recipients from Clients. If you are a Recipient, we may receive information about you from our Client when providing the Client Services, to enable us to notify you of the Reward and customize its presentation. This information may include your name, email address or phone number.

• Information we collect by going directly to third parties, such as:

• Your references, our vendors that help manage the job application process, and career websites, such as LinkedIn, Monster, or Indeed. We use this information to process your application for employment.

• Publicly available information such as information we obtain through search engines and other websites. We use this information to provide our Services.

Consumer marketing databases or other data enrichment companies. We use this information to better customize advertising and marketing to you.

If a Client or a specific third party provides us with personal information about others, such as Recipients, we will use that information for the reason for which it was provided to us or as otherwise permitted by law. Any information we obtain from third parties will be treated in accordance with this Privacy Policy. We are not responsible or liable for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices. For more information, see the section below, Links to Other Web Sites.

Information Use

We may use the information we collect from and about you to:

• Send you requested product or service information, including Rewards and incentives in order to fulfill our contract with you;

• Facilitate the redemption of a Reward;

• Provide you with information about products or services that may be of interest to you and tailored advertisements;

• Provide, improve and develop products and services, including the content and functionality of Services, Client Services and marketing efforts, and to conduct research and analysis;

• Comply with applicable laws or other legal obligations, including to respond to requests from public and government authorities;

• Respond to your questions and concerns, including service requests from Clients and Authorized Users;

• Protect the security or integrity of the Services, Client Services and our business; and

• Evaluate a job applicant’s candidacy and process an application for employment.

In addition, we will use some or all of the above information to comply with any applicable legal obligations, to enforce any applicable terms and conditions and/ or terms of service, and to protect or defend the Site or Services, our rights, the rights of our users, or others.

Information Disclosure

In certain circumstances, we may disclose your information to third parties consistent with this Privacy Policy. We may disclose the information we collect from and about you:

• For legal and security reasons and to protect our services and business, or as required by law, we will disclose your personal data to regulators, law enforcement agencies, public authorities, or any other relevant organizations: (i) in response to a legal obligation; (ii) if we have determined that it is necessary to disclose your personal data to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries; (iii) to protect the interests of, and ensure the safety and security, of us, our users, a third party or the public; (iv) to exercise or defend legal claims; and (v) to enforce our terms and conditions, other applicable terms of service, or other agreements.

• To our vendors and service providers who perform business, professional or technical support functions for us, including payment processing, cloud storage, customer support, marketing, tailored advertising, analytics and other services (these third parties are authorized to use your personal information only for limited purposes and may not disclose your information for other purposes).

Change in Tremendous’ ownership. We may sell all or a portion of our assets or business, or be involved in a merger, acquisition or other business transaction during the normal course of our business and information we have collected about you may be transferred as part of the transaction. We will make reasonable efforts to notify you via email and/or a prominent notice on the Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties. Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use personal information provided through the Services and Client Services in a manner that is consistent with this Privacy Policy and applicable law.

Combination of Information

We may combine the information we receive from and about you, including information you provide to us and information we automatically collect through our Site, as well as information collected offline or from third party sources, to help us tailor our communications to you and to improve our Services and Client Services.

Children

Protecting children's privacy is important to us. We do not direct the Services to, nor do we knowingly collect any personal information from, children under the age of thirteen.

Links to Other Web Sites

This Privacy Policy applies only to the Services. It does not apply to Giftrocket.com or other non-Tremendous websites and mobile applications, including those of our Clients, that may link to the Services or be linked to or from the Services; please review the privacy policies on those websites and applications directly to understand their privacy practices. The Services and the Site may contain links to third-party sites or applications, which may have privacy policies that differ from our own. We are not responsible for the practices of such sites or applications. The privacy and data security practices of such third-party sites or applications are governed by the privacy policies of those third parties, and not by Tremendous. The links to third-party sites from the Services do not imply that we endorse or have reviewed the third-party sites.

Data Security

The security of your personal information is important to us. We have taken certain physical, administrative, and technical steps to safeguard the information we collect from and about you. While we make reasonable efforts to help ensure the integrity and security of our network and systems and to protect your personal information, the transmission of information via the Internet is not completely secure and any electronic communication sent to or from the Services may not be secure. We also cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

Data Storage and Retention

Your personal information is stored on our service providers' servers in the United States. You understand and agree that we may collect, use, disclose, and otherwise process the information you provide as described in this Privacy Policy even if you are from an area outside the United States. Your personal information may be disclosed in response to inquiries or requests from government authorities or to respond to judicial process in the United States. We will retain your personal information for as long as it is reasonably needed for the purposes specified in this Privacy Policy, or to fulfill any legal or contractual obligations we may have. When determining the length of time to retain your information, we consider various criteria, including whether you are a prospective or current Client, Authorized User, Recipient, or Site Visitor and whether we need the information to continue to provide the Services and Client Services, resolve a dispute, abide by applicable laws and regulations, enforce our contractual agreements, prevent harm, promote safety, security and integrity, or protect ourselves, including our rights, property or products.

Changes to Our Privacy Policy

We reserve the right to revise this Privacy Policy at any time. When we do, we will post the changes on the Site. If we change the Privacy Policy in a material way, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us or by posting notice of such changes on the Services) and will take additional steps as required by applicable law. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

California Residents

This section applies to you only if you are a California resident (“resident” or “residents”). For purposes of this section, references to “personal information” shall include “sensitive personal information” unless otherwise indicated, as these terms are defined under the CCPA.

1. Processing of Personal Information

In the preceding 12 months, we collected and (where indicated below) disclosed for a business purpose the following categories of personal information and sensitive personal information (denoted by *) about residents:

1. The categories of sources from which we collect your personal information, and specific business or commercial purposes for which we collected and disclosed your personal information over the preceding 12 months, are described in the sections above, Information Collection, Information Use and Information Disclosure. We only use and disclose sensitive personal information for our internal business purposes as provided for in the CCPA and not for purposes subject to the CCPA “Right to Limit.”

2. Selling of Personal Information

   We do not “sell” (as that term is defined under the CCPA) personal information, nor have we done so in the preceding 12 months. Further, we do not have actual knowledge that we “sell” personal information of residents under 16 years of age.

3. Sharing of Personal Information for cross-context behavioral advertising.

You have a right to opt-out of the “sharing” of your information (including online identifiers and contact information) for the purposes of “cross-context behavioral advertising” (as both terms in quotes are defined under the CCPA).   Please see the “Right to Object to Targeted Advertising” choice below.

Your Privacy Rights

Depending on where you live, you may have some or all of the rights listed below in relation to information that we have collected about you. Note that a number of these rights only apply in certain circumstances, and all of these rights may be limited by law. For example, where fulfilling your request would adversely affect other individuals or our trade secrets or intellectual property, where there are overriding public interests or where we are required by law to retain your personal data.

Because we send Rewards on behalf of our Clients, if you are a Recipient who has received but not redeemed a Reward, please contact the sender, which is usually your employer, to exercise a right. To exercise any of these rights, you can contact help@tremendous.com. We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as your email address, before providing a substantive response to the request. Depending on your location, you may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.

In addition, where applicable, we will provide you with more information about our appeal process. When you submit a request or launch an appeal, we will limit our collection of your information to only what is necessary to securely fulfil your request or process your appeal. We will not require you or your authorized agent to pay a fee for the verification of your request or appeal.

1. Right to Access/Know

   You have a right to request that we confirm whether we process information about you and give you access to that information. You may also have a right to receive that information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another business without impediment. If you are a California resident, you have a right to request the following information about our collection, use and disclosure of your information.

   • categories of information about you we have collected, disclosed for a business purpose;

   • categories of sources from which we collected information about you;

   • the business or commercial purposes for collecting information about you;

   • categories of third parties to whom the information about you was disclosed for a business purpose; and

   • specific pieces of information about you we have collected.

2. Right to Delete

   You have a right to request that we delete information we maintain about you.

3. Right to Correct

   You have a right to request that we correct inaccurate information we maintain about you.

4. Right to Opt Out of Automated Decisionmaking
   You have a right to opt out of automated decisionmaking that results in a legal or otherwise similarly significant impact on you. We do not currently engage in such automated processing activities.

5. Right to Object to Targeted Advertising

You have a right to opt-out of the processing of your information for the purposes of targeted advertising (as defined under applicable law). You can opt out of online targeted advertising by companies participating in the Digital Advertising Alliance program through the Digital Advertising Alliance Consumer Choice page. If you are located in the United States, please visit: http://optout.aboutads.info/. For information on how we process opt-out preference signals, see the section above, Information We Collect Automatically and Cookie Policy.

How to Contact Us

Please also feel free to contact us at help@tremendous.com if you have any questions about our Privacy Statement or the information practices of the Services. If you are a Customer, you can also contact us by reaching out to your designated customer service manager.