Supplemental California Privacy Notice

By continuing to use our services, you are agreeing to the updated Privacy Policy below.

Effective from January 1, 2023

This Privacy Notice for California Residents supplements our main privacy policy and applies to visitors, users, and others who live in California and whose personal information Quotient processes as a “business.” It does not apply to personal information we collect in the following circumstances:

• From employees or job applicants in their capacity as employees or job applicants; and
• Information that we process as a service provider on behalf of other businesses. Please see our main privacy policy for more information on how we process information as a service provider.

A. Categories of Personal Information that We Collect and Share

The California Consumer Privacy Act (“CCPA”) requires us to give California residents certain information about the categories of personal information we collect and how we use it, the categories of sources of the information, categories of third parties to whom we disclosed the information during the past twelve months for business purposes, and the categories of third parties to which we sold or shared personal information in the past twelve months. While we have set out the categories below as required by the CCPA, you can review our main privacy policy for more detailed information that describes our collection, disclosure, and use. Depending on how you interact with us, we may collect and disclose the categories of information summarized below.

Please note that we may also disclose all personal information to (a) comply with federal, state, or local laws; (b) comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (c) cooperate with law enforcement agencies concerning conduct or activity that we believe may violate federal, state, or local law, (d) when we sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction), or (e) to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

B. Categories of Purposes for Our Use of Your Information

With the exception of financial information, retailer online account credentials, professional information, and certain mobile phone numbers (as described further below), all of the categories of personal information we collect about you (as detailed above) are used for the following purposes:

• Providing our Services (for example, processing rebate and coupon redemptions or delivering targeted offers or promotions to you)
• For our operational purposes
• Improving our existing Services and developing new products and services
• Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity
• Bug detection, error reporting, and activities to maintain the quality or safety of our Services
• Auditing consumer interactions (for example, measuring ad impressions, coupon activity)
• Short-term, transient use, such as customizing content that we or our service providers display on the Services
• Providing services for, and products to, our business customers and partners (such as brands and retailers), including advertising, marketing, measurement and analytics services on our Services and elsewhere
• Advertising, marketing, measurement and analytics, on our Services and elsewhere
• Other uses that advance our commercial or economic interests, such as third-party advertising and communications about relevant promotions or offers from third parties
• Uses disclosed in our main privacy policy
• Other uses that we notify you about

Mobile phone numbers given to us in order to print or install our coupon printing software are used only for verification, security, fraud, identity and audit purposes. Financial information given to us to allow us to transfer funds (e.g. earned rebate rewards) is used only for payment of rewards or rebates and to detect, protect against, and prosecute fraudulent or illegal activity. Retail online account credentials are used only to access your retailer online account to collect purchase information from that retailer, as further described in section 3(a) of our Privacy Policy. Professional information from representatives of our vendors and business partners is used only in furtherance of our business relationship with the vendor or business partner, such as to fulfill services and communicate with you about business matters.

C. Opt Out of Sale or Sharing of Personal Information
The CCPA allows consumers to opt out of the “sale” of personal information and “sharing” of personal information for cross-context behavioral advertising purposes. The law defines these terms very broadly. Certain uses of your data described above may constitute a sale or sharing for cross-context behavioral advertising purposes under the CCPA, as we currently understand it. If you would like to opt out of our use of your information for purposes that are considered a “sale” or “sharing” under California law, you may do so here. If you want to learn more about tracking cookies, which enable targeted advertising that allows us to provide promotions and offers relevant to you, please visit our Cookies Policy here. As further explained in the Cookie Policy, you can visit the “Help” or “Settings” section of your browser and follow instructions for deleting cookies to delete tracking cookies placed by us. If you clear your cookies after you asked us to delete tracking cookies, we will not be able to know that you made this request so you will need to opt-out again. You can also submit an opt-out request by emailing us at privacy@quotient.com and include “CCPA OPT-OUT REQUEST” in the email subject line. Please note, however, that you must use the link provided to opt out of cookie based “sales” and “sharing.”  We do not knowingly collect or sell the personal information of minors under 16 years of age.

D. Limit Use of Sensitive Personal Information
Quotient uses certain categories of information deemed to be “sensitive personal information” under the CCPA. Specifically, we collect the following sensitive personal information:

Account Login Information
Financial Account Login Information, e.g. PayPal®
Precise geolocation data
Race
Ethnicity
Religion

We collect this information to better tailor the services and advertisements/offers to you. The CCPA allows you to request that we limit our use of your sensitive personal information to only those uses needed to provide the Services or to comply with applicable law. If you would like to request that we limit use of your sensitive personal information, please fill out the form available here.

E. California Residents’ Information Rights
In addition to the opt-out right and limit use of sensitive personal information rights described above, California residents have the right under the CCPA to request (subject to certain limitations) that we:

• Provide you the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information.
• Provide access to and/or a copy of certain information we hold about you.
• Delete certain information we have about you.
• Correct inaccurate personal information we have about you.

Note that some information we hold about you may be associated with a device identifier only. In response to requests to access certain information that we hold about you that are only associated with a device identifier, we cannot provide such information because we are unable to adequately verify that the person who has submitted the request is the actual owner of the device associated with a given data set. Because this data is not associated with other personal information such as name, address, email address with this data that is associated with a specific device identifier only, we do not have methods to adequately verify the identity of an actual device owner.

You may have the right to receive information about the financial incentives that we offer to you (if any). You also have the right to not be discriminated against (as provided for in applicable law) for exercising your access, deletion, correction, or sale/sharing opt-out rights. We will not discriminate against you for exercising your rights. Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the Services to you, for financial auditing purposes, and for compliance with applicable law. Asking us to delete your information may impact your ability to use our services, including closure of your user account and you may no longer be able to access or use all or parts of the Services.

If you would like to exercise any of these CCPA rights, please visit our privacy portal or you may send an email to privacy@quotient.com. If you submit your request by email, please include “CCPA REQUEST” in the email subject line and include, in the body of the email, your name (First and Last), email address, state and zip code of residence, and a description of the CCPA rights you wish to exercise.

Additionally, you may submit a request to delete or a request for information by calling 1-888-914-9661.  When prompted for your PIN, enter 741594, which will take you to the Quotient Technology privacy line. Please listen carefully and follow the instructions.  When prompted to provide your name and email address, please speak clearly and spell out your name and email address.  When you have finished providing the information requested, you must press “#” to submit your request.  If you do not press “#” to end your recording, your request will not be submitted.  Note, when submitting your requests by phone, a separate call is required for each request you are exercising (e.g. one request to submit a request to know and another request to submit a request to delete).  If we are not able to understand the information you have provided, we may call you on the number you used to call the toll-free number, if it is available, in order to confirm your information.

After submitting your request(s), we are required to verify your request(s) to ensure it is not fraudulent. To verify your request, we will contact you via the email address you provided with, or to submit, your request.  Further, we may require you to confirm ownership of the email address associated with your request or provide additional information necessary to verify the validity of your request.  For example, we may ask for you to provide additional information to determine if it matches information we have.  Please be sure to check your SPAM/junk folder in case the email is filtered out by your mail system.  If you do not receive an email from us regarding your request(s) within 48 hours, your request or contact information may not have been submitted properly, and you will need to submit a new request.

You may also designate an authorized agent to make a request on your behalf. To do so, you must provide us with a copy of written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.

F. Data Retention
We retain your information for as long as is necessary to provide the Services or for other necessary purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. In determining how long to retain information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the information, applicable legal requirements, and our legitimate interests. The purposes for which we process information (as well as the other factors listed above) may dictate different retention periods for the same types of information. If you opt out of email marketing, we maintain your email on our suppression list for an extended time to comply with your request. We may delete or de-identify your information sooner if we receive a verifiable deletion request, subject to exemptions under applicable law. We may retain cached or archived copies of your information.

G. CCPA Request Metrics
For metrics related to CCPA requests received during the previous year, please go here.