- Offer Wall. Our App may display a third-party hosted "offer
wall." Such an offer wall allows third-party advertisers to offer virtual
currency, gifts, or other items to users in return for the acceptance and
completion of an advertisement offer. Such an offer wall may appear in our
App and be displayed to you based on certain data, such as your geographic
area or demographic information. When you click on an offer wall, you will
be brought to an external website belonging to other persons and will leave
our App. A unique identifier, such as your user ID, will be shared with the
offer wall provider in order to prevent fraud and properly credit your
account with the relevant reward. Please note that we do not control
third-party websites and have no responsibility in relation to the content
of such websites. The inclusion of a link towards a third-party website does
not imply an endorsement by us of such website. Accordingly, we do not make
any warranty regarding such third-party websites and we will not be liable
for any loss or damage caused by the use of such websites. In addition, when
you access any third-party website, please understand that your rights while
accessing and using those websites will be governed by the privacy notice
and terms of service relating to the use of those websites.
4. WHO WILL YOUR INFORMATION BE SHARED WITH?
In Short:We only share information with the following third parties.
We only share and disclose your information with the following third parties.
We have categorized each party so that you may be easily understand the
purpose of our data collection and processing practices. If we have processed
your data based on your consent and you wish to revoke your consent, please
contact us using the contact details provided in the section below titled "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?".
- Advertising, Direct Marketing, and Lead Generation
Google AdSense
and
AdMob
- Allow Users to Connect to Their Third-Party Accounts
Google account
- Communicate and Chat with Users
Freshchat
Google Ads Remarketing
and
Facebook Custom Audience
- Social Media Sharing and Advertising
Facebook advertising
- User Account Registration and Authentication
Google Sign-In
Facebook Analytics
,
Google Analytics
and
Heap Analytics
- Website Performance Monitoring
Sentry
Firebase Remote Config
and
TestFlight
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short:We may use cookies and other tracking technologies to collect and store your
information.
We may use cookies and similar tracking technologies (like web beacons and
pixels) to access or store information. Specific information about how we use
such technologies and how you can refuse certain cookies is set out in our
Cookie Notice
.
6. DO WE USE GOOGLE MAPS PLATFORM APIS?
In Short:Yes, we use Google Maps Platform APIs for the purpose of providing better
service.
This
Website
or
App
uses Google Maps Platform APIs which are subject to Google’s Terms of Service.
You may find the Google Maps Platform Terms of Servicehere. To find out more about Google’s Privacy Policy, please refer to thislink.
We obtain and store on your device ('cache') your location
. You may revoke your consent anytime by contacting us at the contact details provided
at the end of this document.
7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short:If you choose to register or log in to our services using a social media
account, we may have access to certain information about you.
Our
Services
offers you the ability to register and login using your third-party social media
account details (like your Facebook or Twitter logins). Where you choose to do
this, we will receive certain profile information about you from your social media
provider. The profile Information we receive may vary depending on the social media
provider concerned, but will often include your name, email address, friends list,
profile picture as well as other information you choose to make public on such
social media platform.
We will use the information we receive only for the purposes that are
described in this privacy notice or that are otherwise made clear to you on
the relevant
Services
. Please note that we do not control, and are not responsible for, other uses of
your personal information by your third-party social media provider. We recommend
that you review their privacy notice to understand how they collect, use and share
your personal information, and how you can set your privacy preferences on their
sites and apps.
8. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short:We keep your information for as long as necessary to fulfill the purposes
outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary
for the purposes set out in this privacy notice, unless a longer retention
period is required or permitted by law (such as tax, accounting or other legal
requirements). No purpose in this notice will require us keeping your personal
information for longer than __________ months
past the termination of the user's account.
When we have no ongoing legitimate business need to process your personal
information, we will either delete or anonymize such information, or, if this
is not possible (for example, because your personal information has been
stored in backup archives), then we will securely store your personal
information and isolate it from any further processing until deletion is
possible.
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short:We aim to protect your personal information through a system of
organizational and technical security measures.
We have implemented appropriate technical and organizational security
measures designed to protect the security of any personal information we
process. However, despite our safeguards and efforts to secure your
information, no electronic transmission over the Internet or information
storage technology can be guaranteed to be 100% secure, so we cannot promise
or guarantee that hackers, cybercriminals, or other unauthorized third parties
will not be able to defeat our security, and improperly collect, access,
steal, or modify your information. Although we will do our best to protect
your personal information, transmission of personal information to and from
our Services
is at your own risk. You should only access the
Services
within a secure environment.
10. DO WE COLLECT INFORMATION FROM MINORS?
In Short:We do not knowingly collect data from or market to children under 18 years
of age.
We do not knowingly solicit data from or market to children under 18 years of
age. By using the Services, you represent that you are at least 18 or that you are the parent or
guardian of such a minor and consent to such minor dependent’s use of the
Services. If we learn that personal information from users less than 18 years of age
has been collected, we will deactivate the account and take reasonable
measures to promptly delete such data from our records. If you become aware of
any data we may have collected from children under age 18, please contact us
at
info@sutlr.com.
11. WHAT ARE YOUR PRIVACY RIGHTS?
In Short:You may review, change, or terminate your account at any time.
If you have questions or comments about your privacy rights, you may email us
at info@sutlr.com.
Account Information
If you would at any time like to review or change the information in
your account or terminate your account, you can:
- Contact us using the contact information provided.
Upon your request to terminate your account, we will deactivate or delete
your account and information from our active databases. However, we may
retain some information in our files to prevent fraud, troubleshoot
problems, assist with any investigations, enforce our Terms of Use and/or
comply with applicable legal requirements.
Cookies and similar technologies:
Most Web browsers are set to accept cookies by default. If you prefer, you can
usually choose to set your browser to remove cookies and to reject cookies. If
you choose to remove cookies or reject cookies, this could affect certain features
or services of our
Services. To opt-out of interest-based advertising by advertisers on our
Services
visit
http://www.aboutads.info/choices/.
Opting out of email marketing:
You can unsubscribe from our marketing email list at any time by clicking on the
unsubscribe link in the emails that we send or by contacting us using the details
provided below. You will then be removed from the marketing email list — however,
we may still communicate with you, for example to send you service-related emails
that are necessary for the administration and use of your account, to respond to
service requests, or for other non-marketing purposes. To otherwise opt-out, you
may:
- Access your account settings and update your preferences.
12. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications
include a Do-Not-Track ("DNT") feature or setting you can activate to signal
your privacy preference not to have data about your online browsing activities
monitored and collected. At this stage no uniform technology standard for
recognizing and implementing DNT signals has been finalized. As such, we do
not currently respond to DNT browser signals or any other mechanism that
automatically communicates your choice not to be tracked online. If a standard
for online tracking is adopted that we must follow in the future, we will
inform you about that practice in a revised version of this privacy notice.
13. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short:Yes, if you are a resident of California, you are granted specific rights
regarding access to your personal information.
California Civil Code Section 1798.83, also known as the "Shine The Light"
law, permits our users who are California residents to request and obtain from
us, once a year and free of charge, information about categories of personal
information (if any) we disclosed to third parties for direct marketing
purposes and the names and addresses of all third parties with which we shared
personal information in the immediately preceding calendar year. If you are a
California resident and would like to make such a request, please submit your
request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered
account with a
Service, you have the right to request removal of unwanted data that you publicly
post on the
Services. To request removal of such data, please contact us using the contact
information provided below, and include the email address associated with your
account and a statement that you reside in California. We will make sure the
data is not publicly displayed on the
Services, but please be aware that the data may not be completely or comprehensively
removed from all our systems (e.g. backups, etc.).
CCPA Privacy Notice
The California Code of Regulations defines a "resident" as:
(1) every individual who is in the State of California for other than a
temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is
outside the State of California for a temporary or transitory purpose
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to certain
rights and obligations regarding your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the
past twelve (12) months:
Category
| Examples
| Collected
|
A. Identifiers | Contact details, such as real name, alias, postal address, telephone
or mobile contact number, unique personal identifier, online
identifier, Internet Protocol address, email address and account name |
YES
|
B. Personal information categories listed in the California Customer
Records statute | Name, contact information, education, employment, employment history
and financial information |
YES
|
C. Protected classification characteristics under California or
federal law | Gender and date of birth |
YES
|
D. Commercial information | Transaction information, purchase history, financial details and
payment information |
NO
|
E. Biometric information | Fingerprints and voiceprints |
NO
|
F. Internet or other similar network activity | Browsing history, search history, online behavior, interest data, and
interactions with our and other websites, applications, systems and
advertisements |
YES
|
G. Geolocation data | Device location |
YES
|
H. Audio, electronic, visual, thermal, olfactory, or similar
information | Images and audio, video or call recordings created in connection with
our business activities |
NO
|
I. Professional or employment-related information | Business contact details in order to provide you our services at a
business level, job title as well as work history and professional
qualifications if you apply for a job with us |
NO
|
J. Education Information | Student records and directory information |
NO
|
K. Inferences drawn from other personal information | Inferences drawn from any of the collected personal information
listed above to create a profile or summary about, for example, an
individual’s preferences and characteristics |
YES
|
We may also collect other personal information outside of these categories
instances where you interact with us in-person, online, or by phone or mail in
the context of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our Services and to respond to your
inquiries.
How do we use and share your personal information?
Manager Special, LLC
collects and shares your personal information through:
- Targeting cookies/Marketing cookies
More information about our data collection and sharing practices can
be found in this privacy notice.
You may contact us by email at
info@sutlr.com,
by visiting
here, or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your right to
opt-out we may deny a request if the authorized agent does not submit
proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers
pursuant to a written contract between us and each service provider.
Each service provider is a for-profit entity that processes the
information on our behalf.
The current list of our service providers can be found in below.
We may use your personal information for our own business purposes,
such as for undertaking internal research for technological
development and demonstration. This is not considered to be "selling"
of your personal data.
Manager Special, LLC has disclosed the following categories of personal information to
third parties for a business or commercial purpose in the preceding
twelve (12) months:
- Category B. Personal information, as defined in the California
Customer Records law, such as your name, contact information,
education, employment, employment history and financial
information.
- Category K. Inferences drawn from any of the personal
information listed above to create a profile or summary about,
for example, an individual's preferences and characteristics.
Your rights with respect to your personal data
Right to request deletion of the data - Request to delete
You can ask for the deletion of your personal information. If
you ask us to delete your personal information, we will respect
your request and delete your personal information, subject to
certain exceptions provided by law, such as (but not limited to)
the exercise by another consumer of his or her right to free
speech, our compliance requirements resulting from a legal
obligation or any processing that may be required to protect
against illegal activities.
Right to be informed - Request to know
Depending on the circumstances, you have a right to know:
- whether we collect and use your personal information;
- the categories of personal information that we collect;
- the purposes for which the collected personal information is
used;
- whether we sell your personal information to third parties;
- the categories of personal information that we sold or
disclosed for a business purpose;
- the categories of third parties to whom the personal
information was sold or disclosed for a business purpose; and
- the business or commercial purpose for collecting or selling
personal information.
In accordance with applicable law, we are not obligated to
provide or delete consumer information that is de-identified in
response to a consumer request or to re-identify individual data
to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s
Privacy Rights
We will not discriminate against you if you exercise your
privacy rights.
Verification process
Upon receiving your request, we will need to verify your
identity to determine you are the same person about whom we have
the information in our system. These verification efforts
require us to ask you to provide information so that we can
match it with information you have previously provided us. For
instance, depending on the type of request you submit, we may
ask you to provide certain information so that we can match the
information you provide with the information we already have on
file, or we may contact you through a communication method (e.g.
phone or email) that you have previously provided to us. We may
also use other verification methods as the circumstances
dictate.
We will only use personal information provided in your request
to verify your identity or authority to make the request. To the
extent possible, we will avoid requesting additional information
from you for the purposes of verification. If, however, if we
cannot verify your identity from the information already
maintained by us, we may request that you provide additional
information for the purposes of verifying your identity, and for
security or fraud-prevention purposes. We will delete such
additionally provided information as soon as we finish verifying
you.
Other privacy rights
- you may object to the processing of your personal data
- you may request correction of your personal data if it is
incorrect or no longer relevant, or ask to restrict the
processing of the data
- you can designate an authorized agent to make a request under
the CCPA on your behalf. We may deny a request from an
authorized agent that does not submit proof that they have
been validly authorized to act on your behalf in accordance
with the CCPA.
- you may request to opt-out from future selling of your
personal information to third parties. Upon receiving a
request to opt-out, we will act upon the request as soon as
feasibly possible, but no later than 15 days from the date of
the request submission.
To exercise these rights, you can contact us
by email at
info@sutlr.com,
by visiting
here, or by referring to the contact details at the bottom of this
document. If you have a complaint about how we handle your data, we
would like to hear from you.
14. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as
necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The
updated version will be indicated by an updated "Revised" date
and the updated version will be effective as soon as it is
accessible. If we make material changes to this privacy notice,
we may notify you either by prominently posting a notice of such
changes or by directly sending you a notification. We encourage
you to review this privacy notice frequently to be informed of
how we are protecting your information.
15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at
info@sutlr.com or by post to:
Manager Special, LLC
11619 Vantage Hill Road
Unit 12B
RESTON
,
VA 20190
United States
16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE
COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the
right to request access to the personal information we collect
from you, change that information, or delete it in some
circumstances. To request to review, update, or delete your
personal information, please submit a request form by clicking
here. We will respond to your request within 30 days.