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Tango Card, Inc. Privacy Notice

This Privacy Notice describes how Tango Card, Inc. and affiliates (collectively, “Tango Card,” “we,” “us,” or “our”) collects, uses, shares, and safeguards personal information. This Privacy Notice also tells you about your rights and choices with respect to your personal information, and how you can reach us to get answers to your questions. Tango Card provides services that support our enterprise clients’ rewards and incentives programs. When we receive information for our own purposes, such as the contact or billing information of our clients, the processing of that information is described by this privacy Notice. However, when we receive or process information on behalf of one of our clients, the privacy practices that apply to the processing of that information is governed by our client’s privacy notice.This Privacy Notice describes how Tango Card, Inc. and affiliates (collectively, “Tango,”“we,” “us,” or “our”) collect, use, share, and safeguard personal information. This Privacy Notice applies to Tango and Tango’s online properties (including our websites and websites or mobile applications that link to it “Sites”), our social media pages or handles, our products and services, (the “Services”). This Privacy Notice also tells you about your rights and choices with respect to your personal information, and how you can reach us to get answers to your questions. Tango provides Services to support our enterprise Clients’ (“Clients”) rewards and incentives programs.When we receive information for our own purposes, such as the contact or billing information of our Clients, the processing of that information is described by this Privacy Notice. When we receive or process information on behalf of one of our Clients, the privacy practices that apply to the processing of that information are also governed by our Client’s privacy notice.

You can jump to particular topics by going to the headings below:

Types Of Information We Collect
Use And Processing Of Information
Sharing Of Information
Your Choices
Information for Authorized Agents
How We Protect Personal Information
Cookie Policy

Special Information for Job Applicants

Other Important Information

Privacy Disclosures for Specific Jurisdictions

Contact Information

Types of information we collect

We provide Services and products to support enterprise Clients’ rewards, loyalty and incentive programs. In that capacity we receive personal information from our Clients or collect it directly from you, and we process that information on behalf of our Clients. In other situations, we receive personal information for our own use. The following provides examples of the type of information that we collect from you.

Information you give us

You may provide the following information to us directly:

  • Contact information, including name and email address.
  • Content you may include in survey responses.
  • Information contained in your communications to us, including call recordings of customer service calls.
  • Information you make available to us via a social media platform.
  • Information you submit to inquire about or apply for a job with us.
  • Any other information you submit to us.
Information we collect automatically

We and partners working on our behalf may use log files, cookies, or other digital tracking technologies to collect the following information from the device you use to interact with our Services:

  • Device information, including IP address, device identifiers, and details about your web browser.
  • Analytical information, including details about your interaction with our website, app, and electronic newsletters.
  • Diagnostic information, including web traffic logs.
  • Advertising information, including special advertising and other unique identifiers that enable us or third parties working on our behalf to target advertisements to you. Please be aware that our advertising partners may collect information about you when you visit third-party websites or use third-party apps. They may use that information to better target advertisements to you on our behalf.
  • Business record information, including records of your purchases of products and Services.

We may also create records using the above information when you interact with the Services.

Information we collect from other sources

In addition to the information that we collect from you or from our Clients, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources.

We may collect the following information about you from third-party sources:

  • Contact or identity verification information, including names and email addresses, for the purposes of fraud prevention or compliance with regulatory obligations.
  • Information about your interaction with advertisements on our Services, or ads that we place on third party websites, from online advertising companies.
  • If you decide to invite others to the Services, we will collect your and the other person’s names, email addresses, and/or phone numbers to send an email or text message and follow up with the other person. You agree that you have obtained the other person’s consent before giving us his or her contact information. You also agree that you will not send us the contact information of a minor. We may inform any other person you invite that you gave us his or her information.

Use and processing of information

We may use the information we collect in the following ways:

  • To identify you when you visit our websites.
  • To provide products and Services or to redeem rewards.
  • To improve our Services and product offerings, including analytics.
  • To offer you recommendations and tailor the Services to your preferences.
  • To respond to inquiries related to support, employment opportunities, or other requests.
  • To send marketing and promotional materials, including information relating to our products, Services, sales, or promotions, to personalize the advertisements you see on our Services and third-party online properties, and to measure the effectiveness of our advertising. We may share your information with business partners, online advertising partners, and social media platforms for this purpose.
  • For internal administrative purposes, as well as to manage our relationships.
  • To protect and secure our Services, assets, network, and business operations, and to detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal.
  • To comply with legal process, such as warrants, subpoenas, court orders, and lawful regulatory or law enforcement requests and to comply with applicable legal requirements, including “know-your-customer” due diligence and other anti-money laundering or OFAC compliance obligations.

Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose.  Our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.

Sharing of information

In addition to the specific situations discussed elsewhere in this notice, we disclose information in the following situations:

Affiliates and acquisitions. We may share information with our corporate affiliates (e.g., subsidiaries or other companies under common control). If another company acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information as described in this Privacy Notice.

• Other disclosures with your consent. We may ask if you would like us to share your information with unaffiliated third parties who are not described elsewhere in this notice.

• Other disclosures without your consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third-party intermediary.

• Public .Some of our websites and social media pages may provide the opportunity to post comments or reviews, on a message board or in a public forum. If you decide to submit information on these pages, that information may be publicly available.

• Service providers. We engage vendors to perform specific business functions on our behalf and they may receive information about you from us or collect information from you directly. These vendors are obligated by contract to use information that we share only for the purpose of providing these business functions, which include:

  • Supporting service functionality, such as vendors that support event registration, customer service and Client relationship management, subscription fulfillment, freight services, application development, list cleansing, postal mailings, and communications (email, fax).
  • Auditing and accounting firms, such as firms that assist us in the creation of our financial records.
  • Professional services consultants, such as firms that perform analytics, assist with improving our business, provide legal services, or supply project-based resources and assistance.
  • Analytics and marketing services, including entities that analyze traffic on our online properties and assist with identifying and communicating with potential Clients.
  • Security vendors, such as entities that assist with security incident verification and response, service notifications, and fraud prevention.
  • Information technology vendors, such as entities that assist with website design, hosting and maintenance, data and software storage, and network operation.
  • Marketing vendors, such as entities that support distribution of marketing emails.

• Online advertising partners: We partner with companies that assist us in advertising our Services, including partners that use cookies and online tracking technologies to collect information to personalize, retarget, and measure the effectiveness of advertising.

• Social media platforms: If you interact with us on social media platforms, the platform may be able to collect information about you and your interaction with us. If you interact with social media objects on our Services (for example, by clicking on a Facebook “like” button), both the platform and your connections on the platform may be able to view that activity. To control this sharing of information, please review the privacy policy of the relevant social media platform.

• Our enterprise clients: If you receive a reward such as a Reward Link or Tango Choice product that enables you to select a gift card from our website, we may share information about the gift card that you select with the Client who purchased the reward and instructed us to send it to you.

Your choices

You can make the following choices regarding your personal information:

  • Promotional emails.You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive.  If you decide not to receive promotional emails, we may still send you service-related communications, including rewards sent by other Clients.
  • Access to your personal information. For information that we collect on our own behalf, we will grant you, where required by law, reasonable access to the personal information that we have about you. You may request access to your personal information by contacting us at the address described below. For information that we process on behalf of our Clients, please reach out to the Client directly to request access, and we will await their instructions to provide information.
  • Changes to your personal information. For information that we collect on our own behalf we will grant you, where required by law, the ability to contact us at the address noted below in order to request that your information be modified. For information that we collect on our own behalf, we rely on you to update and correct your personal information. If our website does not permit you to update or correct certain information, you may contact us at the address described below in order to request that your information be modified. If we are processing your information on behalf of one of our Clients please reach out to that Client for the request, and we will await instructions from them on whether your information should be deleted. Note that we may keep historical information in our backup files as permitted by law.
  • Deletion of your personal information. We typically retain personal information that we collect on our own behalf for the period necessary to fulfill the purposes outlined in this notice, unless a longer retention period is required or permitted by law. For information that we collect on our own behalf, we will grant, where required by law, your request that we delete your personal information, by contacting us at the address described below. If we are processing your information on behalf of one of our Clients, we encourage you to reach out to that Client directly to make the request. We are required to await instructions from the Client on whether your information should be deleted. You should note that in many situations we may keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.
  • Revocation of consent or objections. For information that we collect on our own behalf we will grant, where required by law, your request to revoke consent to processing (where our processing is based upon consent), or object to our processing (where our processing is not based upon your consent) by contacting us at the address described below. If you revoke your consent or object we may no longer be able to provide you Services. In some cases we may limit or deny your request to revoke consent or object if the law permits or requires us to do so, or if we are unable to adequately verify your identity. If we are processing your information on behalf of one of our Clients, we encourage you to reach out to that Client directly to make the request. We are required to await instructions from theClient on whether we should stop processing.
  • Online tracking.We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
  • Jurisdiction-specific rights: You may have certain rights with respect to your personal information depending on your location or residency. Please see privacy disclosures for specific jurisdictions below. Please contact us to exercise your rights.

Please address written requests and questions about your rights to privacy@tangocard.com or call us at 1-877-743-7545.

Note that we may require you to prove your identity, including by phone call or email. Depending on your request, we will ask for information such as your name, the last item you received or ordered from us, or the date of your last redemption or order from us. We may also ask you to provide a signed declaration confirming your identity. Following a request and where required by law, we will use reasonable efforts to supply, correct or delete personal information about you in our files.

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf.  We will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us.

Information for Authorized Agents

If you are an authorized agent submitting a request on behalf of an individual you must attach a copy of the following information to the request:

  1. A completed Authorized Agent Designation Form indicating that you have authorization to act on the consumer’s behalf.
  2. If you are a business, proof that you are registered with the Secretary of State to conduct business in California.

If we do not receive both pieces of information, the request will be denied.

How we protect personal information

No method of transmission or electronic storage is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorized access to your personal information, we may notify you electronically, in writing via email, if permitted to do so by law.

Some of our sites may permit you to create an account and prompt you to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.

Special information for job applicants

When you apply for a job with us, we may collect information from you, including:

  • Information you provide in connection with your application.
  • Information that you make available in your social media accounts.
  • Information about you that is available publicly.
  • Information that you authorize us to collect via third parties, including former employers or references.

In certain circumstances, you may submit your application for employment through a third-party service that displays our job posting. We do not control the privacy practices of these third-party services. Please review their privacy policies carefully prior to submitting your application materials.

Other important information

The following additional information relates to our privacy practices:

  • Transmission of information to other countries.We process data both inside and outside the United States. Any transfers will comply with safeguards as required by relevant law.
  • Changes to this privacy notice. We may change our privacy notice and practices over time. We will provide notice of material changes by posting the updated policy on this page with the date the changes come into effect.  
  • Information about children. The Services are intended for users age 16 and older. We do not knowingly collect information from children. If we discover that we have inadvertently collected information from anyone younger than the age of 16, we will delete that information.
  • Sharing of medical or health information. To the extent that we receive protected health information about you, that information is subject to electronic disclosure to the extent permitted by applicable law.
  • Data retention. We may store information about you for as long as we have a legitimate business need for it.

Privacy disclosures for specific jurisdictions

European Economic Area, United Kingdom, and Switzerland

We process “personal data,” as that term is defined in the European Union’s GeneralData Protection Regulation (“GDPR”).

Your rights under the GDPR: Users who are located in the European Economic Area (“EEA”), U.K., or Switzerland have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here.

If you are located in the EEA, U.K., or Switzerland, you have the following rights:

  • Access and portability: Request access to personal data we hold about you or request transmission of your data to a third party.
  • Correction: Request that we rectify inaccurate or incomplete personal data we store about you.
  • Erasure: Request that we erase personal data when such data is no longer necessary for the purpose for which it was collected, when you withdraw consent and no other legal basis for processing exists, or when you believe that your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing.
  • Restriction of processing: Request that we restrict our processing of personal data if there is a dispute about the accuracy of the data; if the processing is unlawful; if the processing is no longer necessary for the purposes for which it was collected but is needed by you for the establishment, exercise or defense of legal claims; or if your request to object to processing is pending evaluation.
  • Objection to processing: Object to processing of your personal data based on our legitimate interests or for direct marketing (including profiling). We will no longer process the data unless there are compelling legitimate grounds for our processing that override your interests, rights, and freedoms, or for the purpose of asserting, exercising, or defending legal claims.
  • Transfers: Obtain information about and a copy of the safeguards we use to transfer personal data across borders.

Please contact us at privacy@tangocard.com to exercise these rights.

California

Your California privacy rights; “Shine the Light” law

California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their own direct marketing purposes in the preceding calendar year. We do not share your personal information with third parties for third parties’ direct marketing purposes.

California Consumer Privacy Act (CCPA)

The California Consumer Privacy Act (“CCPA”) gives California residents the rights to receive certain information regarding the collection, use, and disclosure of information about them, as well as rights to know/access, correct, delete, and limit the use and disclosure of sensitive personal information and opt out of the sale or sharing of personal information. You have the right to be free from discrimination based on your exercise of your CCPA rights. To the extent that we collect personal information that is subject to the CCPA, that information, our practices, and your rights are described below.

Notice at collection regarding the categories of personal information collected

You have the right to receive notice of certain information about our data collection, use, and disclosure. The following table summarizes the categories of personal information we collect; the categories of sources of that information; whether we disclose, sell, or share that information to service providers or third parties, respectively; and the criteria we use to determine the retention period for such information. The categories we use to describe personal information are those enumerated in the CCPA. We collect this personal information for the purposes described above in “Use and Processing ofInformation.”

Please note that because this list is comprehensive, it may refer to types of information that we collect and share about people other than yourself.  For example, while we transfer credit card or debit card numbers for our business purpose in order to process payments for orders placed with us, we do not collect or transfer credit card or debit card numbers of individuals that submit questions through our website’s “contact us” page.

Categories  of personal information that we collect

Source

We disclose for business purposes to:

We  “share” or “sell”  as defined in the  CCPA to:

Identifiers  – such as name, postal address, phone number, email address, account name,  signature, or other similar identifiers
You;  our enterprise clients
Service providers

Product and service fulfillment companies

Internet service providers

Payment Processors and financial institutions

Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law

Data analytics providers
Business  partners
Financial information – such as bank account number, credit or debit card number, or other financial information
You
Service providers

Payment Processors and financial institutions

Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law
Not sold/shared
Commercial information – such as information about products or services purchased,  obtained, or considered, or other purchasing or consuming histories or  tendencies
You;  our analytics and advertising partners
Service providers

Product and service fulfillment companies

Payment processors and financial institutions

Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law

Data analytics providers
Not sold/shared
Network activity data – internet or  other electronic network activity information, such as IP address, Device identifier (e.g., MAC), Cookie or tracking pixel information, Information about your interaction with our website, app, email correspondence, or  products, browsing history, search history, and information regarding an  individual’s interaction with an internet website, application, or advertisement
You; our analytics and advertising partners
Service providers

Product and service fulfillment companies

Internet service providers

Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law

Data analytics providers
Advertising  partners
Professional/ employment information – such as occupation
You;  our analytics and advertising partners
Service providers

Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law
Not sold/shared
Inferences  – drawn from any of the information listed above to create a profile
You; our analytics and advertising partners
Service providers

Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law

Data analytics providers
Not sold/shared

We determine the retention period for each of the categories of personal information listed above based on (1) the length of time we need to retain the information to achieve the business or commercial purpose for which it was obtained, (2) any legal or regulatory requirements applicable to such information, (3) internal operational needs, and (4) any need for the information based on any actual or anticipated investigation or litigation.

Entities to whom we disclose information for business purposes are Service Providers, which are companies that we engage to conduct activities on our behalf. We prohibit Service Providers from using personal information for any purpose that is not related to our engagement.

Entities to whom we “sell” or with whom we “share” information are third parties. Under the CCPA, a business “sells”personal information when it discloses personal information to a company for monetary or other benefit. A company may be considered a third party either because we disclose personal information to the company for something other than an enumerated business purpose under California law, or because its contract does not prohibit it from using personal information for purposes unrelated to the service it provides to us. A business “shares” personal information when it discloses personal information to a company for purposes of cross-context behavioral advertising.

Your rights under the CCPA

  • Opt out of sale or sharing of personal information:You have the right to opt out of our sale or sharing of your personal information to third parties. To exercise this right, please visit our Do Not Sell or Share My Personal Information  webpage or contact us. Your right to opt out does not apply to our disclosure of personal information to Service Providers.
  • Limit the use of your sensitive personal information:You have the right to limit our use and disclosure of your sensitive personal information if we use such information to infer characteristics about you. We do not use your sensitive personal information for this purpose. Your right to limit our use and disclosure of such information is subject to exception.
  • Know and request access to and correction or deletion of personal information: You have the right to request access to personal information collected about you and information regarding the source of that personal information, the purposes for which we collect it, and the third parties and service providers to whom we sell, share, or disclose it. You also have the right to request in certain circumstances that we correct personal information that we have collected about you and to delete personal information that we have collected directly from you. Please contact us to exercise these rights.
Colorado, Connecticut, Utah, and Virginia

Residents of the states of Colorado, Connecticut, Utah, and Virginia have the following rights:

  • Opt out of “sales” of personal information and use of their personal information for “targeted advertising,” as those terms are defined under applicable law.
  • Opt out of “profiling” under certain circumstances, as defined under applicable law. (Residents of Colorado, Connecticut, and Virginia only.)
  • Confirm processing of and access to personal information under certain circumstances.
  • Correct personal information under certain circumstances. (Residents of Colorado, Connecticut, and Virginia only.
  • Delete personal information under certain circumstances.

Residents of these states can exercise their rights by contacting us.

Nevada

Residents of the State of Nevada have the right to opt out of the sale of certain pieces of their information to third parties. Currently, we do not engage in such sales. If you are a Nevada resident and would like more information about our data sharing practices, please contact us.

Contact information

privacy@tangocard.com

1-877-743-7545

Last revised date: March 8, 2023