Prodege Privacy Policy

This Privacy Policy was last updated on: July 1, 2016

NOTICE OF ARBITRATION PROVISIONS:
Your use of the Prodege Sites and Features and our Services (as defined below) is subject to binding individual arbitration of any disputes which may arise, as provided in Paragraph 11 of our Terms of Use (https://www.prodege.com/terms). Please read the arbitration provisions carefully and do not use any of the Prodege Sites and Features or our Services if you are unwilling to arbitrate any disputes you may have with us (including without limitation any disputes relating to this Privacy Policy or our privacy practices) as provided in the Terms of Use.

Prodege, LLC (together with its affiliates, the "Company") owns and operates a number of different websites, mobile apps, and interactive services, including without limitation Swagbucks.com, MyPoints.com, MyGiftCardsPlus.com, SodaHead.com, and others (collectively, the "Prodege Sites"). This privacy policy ("Privacy Policy") applies to the Prodege Sites and to all of the features, mobile applications, emails, online services and other functionalities (collectively, the "Features") available via or related to the Prodege Sites, whether accessed via a computer, mobile device, or otherwise (collectively, the "Prodege Sites and Features") and the services available on or through the Prodege Sites and Features (the "Services"). This Privacy Policy only covers information collected by the Company through the Prodege Sites and Features and our Services, and does not cover any information received or collected offline by the Company (unless specifically stated) or collected by any unrelated websites or companies to which we may provide links.

We are concerned about your privacy and want you to be familiar with how we collect, use and share your information. This Privacy Policy outlines the type of information that we collect and receive from you while you are using our Services. Additionally, this Privacy Policy identifies the ways in which we process, and sometimes share, such information and what control and choices you have with regard to the collection and use of your personal information. Please review this Privacy Policy carefully, especially before providing any personal information through the Prodege Sites and Features. Our Prodege Sites and Features are operated in and controlled from the United States of America unless otherwise stated. If you do not wish to have us collect, use and share information as described in this Privacy Policy, please do not use the Prodege Sites and Features or our Services.

By using any of the Prodege Sites and Features or our Services, and/or clicking to "Accept" or otherwise acknowledging or consenting to this Privacy Policy where that option is made available to you, you agree to be bound by this Privacy Policy, as well as our Terms of Use (https://www.prodege.com/terms). If you do not agree to this Privacy Policy or our Terms, please do not use any Prodege Sites or Features or our Services.

Please don't hesitate to contact us with any questions regarding our Privacy Policy. If you are a Swagbucks member, you can reach us at our Help Center by visiting https://help.swagbucks.com/, selecting "Submit a Request" and following the prompts. If you are a MyPoints.com member, you can reach us by contacting MyPoints Member Services by visiting: https://help.mypoints.com/, selecting "General Questions" and following the prompts.

TABLE OF CONTENTS

Personal Information We Collect

When you visit or use any of the Prodege Sites and Features or our Services, you may be required to share information that identifies you personally. "Personal Information" refers to any information that can reasonably be used to identify, contact or locate you. Examples of Personal Information may include, without limitation, your name, your location, your credit card number, your email address, your mailing address, and your phone number.

Generally, we collect Personal Information when you provide it to us by visiting the Prodege Sites and Features or using our Services. This may include registering for any account with us, filling out surveys, joining a mailing list, corresponding with us, entering one of our sweepstakes or contests, choosing to submit testimonials, stories, photos or the like, or otherwise volunteering or providing information about yourself.

We may use your Personal Information and other information we collect about you in order to provide you with our Services, to improve the Prodege Sites and Features, to provide advertising, content, surveys, offers, promotions, and rewards, and for other marketing, administrative and general business purposes as described in this Privacy Policy.

If you don't provide us with your Personal Information, we will generally be unable to provide you with our Services and you will be unable to use the Prodege Sites and Features.

Other User Information We Collect

We may collect certain other information each time you visit Prodege Sites and Features or use our Services so we can improve the overall quality of your online experience. This kind of information is not ordinarily considered personally identifying information. For example, we collect or may collect your IP address, device ID, referrer data, and browser and platform type. You do not have to register on any of the Prodege Sites and Features or provide any Personal Information to us before we can collect this information. We may assign an ID number to your registration and link additional data to that ID number, such as the date and time you visited, the information you provide, and the links you choose to click. Like most standard website servers, we use log files to collect and store this user information. We may analyze and use this information for a variety of purposes, including operating and improving the Prodege Sites and Features or our Services, collecting further information about and learning from user behavior and trends, and gathering demographic information. Furthermore, we may combine or link information we collect from or about you offline with information we collect from or about you online through the Prodege Sites and Features or your use of our Services.

You may choose to install and use optional browser extensions, add-ons or similar plug-in technologies (the "Extensions") which may also collect and use your information in a variety of ways. For example, the Swagbucks Swagbutton and MyPoints Score! Feature are Extensions that allows you to shop directly with our merchant partners and earn rewards. If you install Extensions, we may be able to determine automatically when you are visiting one of our merchant partners' websites where our rewards may apply. In addition, to assist in rewarding you for purchases made through our shopping-rewards features, third-party affiliate or ad network cookies or other similar technologies (discussed below) may be placed on your computer when you install and use an Extension or when you click on an affiliate or ad network link within a shopping-rewards feature, your browsing activity on our merchant partners' websites (and, with your consent, other websites) may be tracked, and that information may be shared with our advertisers, merchant and survey partners, or others in order to provide you with advertising, content, surveys, offers, promotions, and rewards, or for other marketing, administrative and general business purposes.

We may also use GPS or similar geo-location technology to determine the city and/or geo-coordinates of where you are located, including when you are using a mobile device. As noted in the section on "Sharing" below, we may use and share your location information with our advertisers, merchant and survey partners, or others in order to provide you with advertising, content, surveys, offers, promotions, and rewards, or for other marketing, administrative and general business purposes, based on your location.

In addition, our mobile applications may collect, among other things, certain information automatically, including, but not limited to the type of mobile device you use, your mobile device's unique device identifier (UDID), the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, and information about the way you use the mobile application.

Information We Receive from Third Parties

We may also receive and supplement the information we directly collect from or about you with information from third parties. If you are on a third party website or service and you opt-in to receive information from us, the third party may forward to us your e-mail address and other information about you so that we may contact you as requested. In addition, we may receive information from advertisers, merchant or survey partners, and others to ensure that you properly receive any earned rewards or for other marketing, administrative or general business purposes. We may also supplement and combine the information we collect about you with outside records from third parties in order to enhance our ability to provide you with advertising, content, surveys, offers, promotions and rewards, and for other business purposes.

Friend Referrals

We may provide you with an opportunity to invite your friends, family and acquaintances ("Friends") to use various Prodege Sites and Features. If you elect to use our referral service for informing a Friend about any of the Prodege Sites and Features, you will provide us with your Friend's name and email address. Using our referral service permits us to automatically send the Friend one or more emails or other communications, on your behalf, inviting them to visit or register for the Prodege Sites and Features (which invite may include additional subsequent reminders and communications). You warrant and represent that you have your Friend's consent to provide us with his or her information for this purpose, and that you will not give us referral information for any person not permitted to use the Prodege Sites and Features, including, without limitation a child under the age of 13, a person whose account has previously been suspended or deactivated, or a person residing or located in a territory where use of the Prodege Sites and Features is not authorized.

Community Features and User Content

The Prodege Sites and Features may provide you the opportunity to participate in and post text (including questions, comments, and suggestions), images, audio, videos, or other content (collectively, "User Content") publicly through our blogs, chat rooms, forums, interactive features, third-party social networking services or other communication functionality ("Community Features"). Please note that certain information, such as your username and profile picture, may be publicly displayed on the Prodege Sites and Features along with your User Content. Your User Content may also contain metadata, which may contain information about or relating to you, that we may also collect, share and use.

Note that anything you post through Community Features is public -- others will have access to that User Content and may use it or share it with third parties. If you choose to voluntarily disclose Personal Information in the User Content, that information will be considered public information and the protections of this Privacy Policy will no longer apply to that information. In addition, by posting through our Community Features, you are agreeing that we may use your User Content and excerpts from your User Content in connection with our advertising, marketing, and promotional activities.

Third-Party Links

The Prodege Sites and Features contain links to other websites that we do not own. In addition, because aspects of the Prodege Sites and Features include third-party offers for goods, services and the like, third parties may collect your information based on your interaction with those offers. Third-party privacy practices are not covered by this Privacy Policy, and we are not responsible for the privacy practices of such third parties. We encourage our users to be aware of and to read the privacy statements and similar disclosures of any third-party website that collects personally identifiable information before using or disclosing any personally identifiable information to such website.

Advertising Networks and Analytics Companies

We may allow other companies, commonly called third-party ad servers or advertising networks (collectively, "ad networks"), to display advertisements on the Prodege Sites and Features. These advertisements may be based on your interests as reflected in your use of the Prodege Sites and Features or our Services, as well as your use of other websites and services. Some of these ad networks may place a persistent cookie or other similar technology on your computer, allowing them to recognize your computer each time they send you an online advertisement. In this way, ad networks may compile information about where you see their advertisements online and determine which ads you click on, so that they may provide you with advertising, content, surveys, offers, promotions, and rewards that they believe will be of most interest to you. We do not have access to or control over the cookies or other similar technologies that may be placed by these parties on your computer, nor do we have responsibility for these parties' privacy policies or information collection practices. Likewise, we may also work with consumer data resellers that buy and/or sell information to other companies for multiple purposes including offering products and services that may interest you, and we use certain third-party analytics providers to help us understand how you use the Prodege Sites and Features or our Services, and these companies may set their own cookies and similar technologies on your computer or mobile device. These and other third parties may collect information about you, including but not limited to your online activities over time and across different websites and services, when you use the Prodege Sites and Features or our Services, or other online websites and services. Each of these third parties has its own privacy policy that may differ from this Privacy Policy.

We may share your Personal Information and other information with our advertisers, merchant and survey partners, and others for the purpose of making it easier for you to sign up for their surveys, promotions and offers, validating your communications or transactions with them, authenticating and/or validating your identification, crediting you with any earned rewards, and other business purposes. Additionally, we may share information with our service providers and other third parties to assist us in delivering content, advertising, surveys, offers, promotions and rewards to you, both on the Prodege Sites and Features and elsewhere online, and for other marketing, administrative and general business purposes.

Cookies and Similar Technologies

In addition to the ad networks, we may set (or allow third parties to set) and access cookies and other similar technologies, such as web beacons and embedded scripts, on your computer. A cookie is a small data file that a website may send to your browser and which may then be stored on your system. We use both session cookies and persistent cookies. For the session cookie, once you close the browser, the cookie terminates. A persistent cookie is a small text file stored on your hard drive for an extended period of time. Persistent cookies can be removed or disabled by following the web browser help-file directions for your particular browser. We also use Flash cookies, which are data files placed on a computer or mobile device via the Adobe Flash plug-in (or other compatible Flash plugin) that may be built-in to or downloaded by you. Flash cookies may be used for various purposes, including, without limitation, enabling a Flash feature and remembering your preferences. For more information about Flash and the privacy choices Adobe offers, visit http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. Web beacons and embedded script are invisible images or other programming code, which may be used on the Prodege Sites and Features for a variety of analytical purposes and to help us provide a better and more customized user experience, including, without limitation, providing personalized features and preferences to you within the Prodege Sites and Features; in doing so, we may link the information we collect from cookies and other similar technologies with your Personal Information and may track your browsing activity on our merchant partners' websites in order to provide you with advertising, content, surveys, offers, promotions and rewards, and for other marketing, administrative and general business purposes.

Most web browsers automatically accept cookies, but you can usually configure your browser to prevent this. To opt-out of certain cookies and for more information, please visit aboutads.info/choices and/or networkadvertising.org/managing/opt_out.asp. Not accepting or opting out of our cookies may make certain features of the Prodege Sites and Features and our Services unavailable to you.

Note that your browser settings may allow you to automatically transmit a "Do Not Track" signal to websites and online services you visit. At present, we do not believe that there is a consensus among industry participants as to what "Do Not Track" means in this context. Like many websites and online services, we currently do not alter our practices when we receive a "Do Not Track" signal from a user's browser. To find out more about "Do Not Track," you may wish to visit http://www.allaboutdnt.com.

Social Features

Certain functionality on the Prodege Sites and Features may permit interactions that you initiate between the Prodege Sites and Features and a third-party website or service, such as Facebook and Twitter ("Social Features"). Examples of Social Features include enabling you to "like" or "share" content from the Prodege Sites and Features with other websites or services; to log-in to the Prodege Sites and Features using your username and password for a third-party website or service; to transmit content to the Prodege Sites and Features from your account on a third-party website or service; and to otherwise connect the Prodege Sites and Features to a third-party website or service.

If you choose to use Social Features, information you post or provide access to will be shared with that third-party website or service and others, and may be publicly displayed on the Prodege Sites and Features or by the provider of the Social Feature that you use. Similarly, if you post information on a third-party platform that references any of the Prodege Sites and Features (e.g., by using a hashtag associated with any of the Prodege Sites and Features in a tweet or status update), your post may be published on the Prodege Sites and Features in accordance with the terms of the third-party website or service. Also, both we and the third party may have access to certain information about you and your use of the Prodege Sites and Features and the third-party website or service. In addition, we may receive information about you if other users of a third-party website give us access to their profiles and you are one of their "connections," or information about you is otherwise accessible through your connections' web pages, profile pages, or similar pages on a social networking or other third-party website or service.

The information we collect in connection with Social Features is subject to this Privacy Policy. The information collected and stored by the third-party website or service via Social Features remains subject to the third party's privacy practices, including whether the third party continues to share information with us, the types of information shared, and your choices with regard to what is visible to others on that third-party website or service.

Sharing

In addition to the types of sharing described throughout this Privacy Policy, we may disclose your Personal Information and other information as described in this section.

We may disclose your Personal Information when required by law, or where we have a good-faith belief that such action is necessary to comply with a judicial or administrative proceeding, a criminal investigation, a court order, or legal process served on us. We may also share your Personal Information at the request of governmental authorities conducting an investigation, or if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of the Terms of Use or Privacy Policy for any of the Prodege Sites and Features or our Services. We may also use IP addresses or other device identifiers to identify users, and we may do so in cooperation with copyright owners, Internet service providers, wireless service providers, or law enforcement agencies in our discretion. These transfers and disclosures may occur without notice to you.

We may also share your Personal Information with our affiliates for administrative, marketing and other business purposes, and with third-party service providers in connection with the service providers' performance of services to, or on behalf of, the Prodege Sites and Features or our Services. Such services include, for example, customer support, collecting and analyzing information about usage of the Prodege Sites and Features or our Services, delivering advertising, content, surveys, offers, promotions and rewards to you on the Prodege Sites and Features or elsewhere online, processing payments, and performing other administrative, marketing and other business services.

In addition, if you use our mobile applications, we may share your current location with our partners so that we or our partners may provide you with advertising, content, surveys, offers, promotions, and rewards, and for other business purposes, based on your location. Please see the section on "Updating Your Information; Choice/Opt-Out" below for information about how you can opt out of such sharing.

We may share aggregate or individualized information that may include your use of the Prodege Sites and Features or our Services and our merchant partners' websites, with our advertisers, merchant and survey partners, and others for the purpose of providing you with advertising, content, surveys, offers, promotions, and rewards, and for other marketing, administrative and general business purposes, and we may also receive from ad networks information about third-party websites that you have visited.

The information about you that we share with or receive from third parties may generally be used for marketing, administrative and other business purposes.

Business Transitions

In the event the Company (or any of its affiliates) goes through a business transition, such as a merger, consolidation, restructuring, acquisition by another company, sale or assignment of rights or assets or a portion thereof, or other company change, we may transfer users' information, including Personal Information, and other business data in connection with that business transition (e.g., to a subsequent owner, co-owner, or operator of any of the Prodege Sites and Features, or any affiliates and trusted agents, service providers, or partners of the foregoing), including during the course of any due diligence process.

Updating Your Information; Choice/Opt-out

You are responsible for maintaining the accuracy of any information you submit to us, such as your contact information.

You may opt out of receiving marketing e-mails by following the opt-out instructions provided to you in those e-mails, by submitting a request using the Help Center for Swagbucks.com members or the Contact Member Services page for MyPoints.com members, or by visiting My Settings or Settings on Swagbucks.com or MyPoints.com, respectively. Please note that as long as you remain registered with or a user of any of the Prodege Sites and Features or our Services, even if you opt-out of marketing emails, you may still receive administrative emails, such as notices about service and status changes and changes to our Terms of Use or Privacy Policy.

If you sign up to receive SMS or MMS messages from the Prodege Sites and Features, you may unsubscribe from any SMS or MMS messages received by replying "STOP".

If you do not wish to receive advertisements, content, surveys, promotions, offers, or rewards from us which would be sent to you by virtue of your having installed the Extensions, you should not install or should un-install such Extensions. In addition, you may remove or disable cookies as described above in the section on "Cookies and Similar Technologies" and you may clear your browser history in accordance with the system settings of your web browser.

Certain advertising networks and exchanges may participate in the Digital Advertising Alliance ("DAA") AdChoices Program and may display an Advertising Option Icon for interest-based ads. You can learn more about the DAA AdChoices Program here: http://www.youradchoices.com. In addition, certain advertising networks and exchanges may participate in the Network Advertising Initiative (NAI). The NAI has developed a tool that allows consumers to opt out of targeted advertising delivered by NAI members' ad networks. To learn more about opting out of targeted advertising or to use the tool, click here: http://www.networkadvertising.org/choices.

You may opt-out of providing your location information to us when you are using mobile devices. If you do not want us to use your location information as described in this Privacy Policy, you should turn off the location services for the mobile application located in your account settings (if available) or in your mobile device settings.

If you do not want our mobile applications to collect any information from you, you should uninstall the application using the standard uninstall procedures that may be available as part of your mobile device or via the mobile application marketplace or network where you obtained the mobile application.

Notification of Changes

We reserve the right to make changes to this Privacy Policy from time to time. If we decide to change this Privacy Policy, we will provide notice of such changes by sending you an administrative email and/or posting those changes in places on the Prodege Sites and Features deemed appropriate by us so our users are always aware of what information we collect, how we use it, and under what circumstances it may be shared with others. Your continued use of any of the Prodege Sites and Features or our Services after delivery of the administrative email to you or after the changes are posted constitutes your agreement to the changes. If you do not agree to the changes, please discontinue your use of such Prodege Sites and Features and our Services. To the extent that an arbitrator or court of applicable jurisdiction determines that applying any changes to this Privacy Policy to any prior events or circumstances would render this an illusory or unenforceable contract, such changes shall be applicable on a prospective basis only, with respect to events or circumstances occurring after the date of such changes, to the extent necessary to avoid this Privacy Policy being deemed illusory or unenforceable. In any event, if any Personal Information was previously submitted to or collected by us pursuant to an earlier version of this Privacy Policy that required a certain notice period prior to any changes being effective, any changes under this Privacy Policy will not be effective as to you or such previously-collected Personal Information until the previously-specified notice period has passed after the date of this Privacy Policy.

Children's Privacy

The Prodege Sites and Features and our Services are general audience websites and services and we do not knowingly collect any Personal Information from children younger than the age of 13. If you are under 18, you should use the Prodege Sites and Features and our Services only with involvement of a parent or guardian. If you are under 13, you should not submit any Personal Information to us. If we learn that we have inadvertently collected Personal Information from a child younger than 13, we will take commercially reasonable efforts to delete such Personal Information from our databases.

Security

We maintain security measures in place in order to attempt to protect against the loss, misuse and alteration of the Personal Information under our control. Please be advised, however, that the Internet and other various networking communication media are not entirely secure, and your information may therefore be subject to interception or loss which is beyond our reasonable control. While we strive to protect your Personal Information, we cannot ensure or warrant the security of any Personal Information you transmit to us, and any transmission is done at your own risk. Accordingly, we assume no responsibility or liability for disclosure of your Personal Information or other information due to errors in transmission, unauthorized third-party access or other causes beyond our reasonable control.

Location of Processing and Applicable Law

Although we generally maintain our user data in the United States, it is possible that some of the data processing may occur outside of the United States, carried out by companies or individuals under contract with us. While the data protection laws of these countries may vary, we will make every reasonable effort to protect your Personal Information under this Privacy Policy. By using the Prodege Sites and Features and our Services, you consent to this transfer of your personal data to any server used by the Company or its service providers from time to time.

If you are not a resident of the United States, please be aware that data protection laws in the United States and other countries (as well as the legal procedures for courts, governmental authorities, and parties in civil litigation to obtain access to our user data) may differ substantially from the laws and procedures in your country of residence. If you are located in a country outside the United States and submit Personal Information to us, you are consenting to the transfer, processing, storage and use of that information in the United States as provided in this Privacy Policy.

The interpretation and application of this Privacy Policy shall be governed by the laws of the United States and the State of California without regard to its conflict of law provisions. Your use of the Prodege Sites and Features or our Services are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States.

Your California Privacy Rights (California Residents)

When California residents provide certain personal information to a business, they have the right under California Civil Code Section 1798.83 to request certain disclosures if that business shares that personal information with third parties, and in some cases affiliates, for the third parties' or affiliates' direct marketing purposes. Once per calendar year California residents may request that the business provide a list of companies with which it shares such personal information for the third parties' or affiliates' direct marketing purposes, and a list of the categories of such personal information that the business shares.

California residents may request further information about our compliance with this law by e-mailing CaliforniaPrivacy@Prodege.com. Please include "California Privacy Rights Request" in the first line of the description and your California mailing or street address. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this e-mail address, or made by non-California residents.