Privacy Policy

Wildfire Systems, Inc.

Effective Date: July 24, 2023

This is the privacy policy for Wildfire Systems, Inc. (“Wildfire,” “we,” “us,” or “our”). We have prepared this Privacy Policy to let you know about our policies and procedures regarding the collection, use and disclosure of information which is collected through your use of the software, services, programs, websites and/or applications which we offer directly to you (the “Services”).

We receive information about you from various sources, including information you submit, information collected from your use of the Services and information from third parties. When you use the Services, you are consenting to the collection, storage, and other uses of your information as described in this Privacy Policy.

What Does This Privacy Policy Cover?

This Privacy Policy covers the treatment of personally identifiable information ("Personal Information") gathered when you use or access the Services. This Privacy Policy also covers our treatment of any Personal Information that our business partners share with us or that we share with our business partners.

This Privacy Policy does not apply to the practices, content, or privacy policies of third parties that we do not own or control, including but not limited to third-party websites, services, and applications ("Third Party Services") that you elect to access through the Service. We encourage you to carefully review the privacy policies of any Third-Party Services you access.

We offer white-label rewards programs, loyalty solutions and monetization platforms for our clients, which include companies that you work with directly such as merchants, financial service providers, software providers, telecommunications companies, and other companies (“Client”). If you are a user of our Client’s website, service, or application that is powered by us, the terms of our Client’s privacy policy apply.

What Information Do We Collect?

In connection with certain aspects of the Services, we may use (request, collect, store, transmit, analyze, monitor) the following types of information about you:

• We may automatically receive and record information when you interact with the Services, including your IP address, cookie information and device information (such as IMEI, MAC, device manufacturer/model, screen resolution, browser user agent, operating system name and version). This information is used to fight fraud, to understand your interaction with the Services and to help us enhance the Services. We also collect statistical information about how users, collectively, use the Services ("Aggregate Information").
• You may give us permission to access your information from other services. For example, you may link your Google or email account which allows us to obtain information from those accounts (such as your contacts) or may serve as an alternate method of registering for our Services. The information we get from those services often depends on your settings or their privacy policies, so be sure to check what those are.
• We may request and you may choose to submit Personal Information when you register and when you administer your account or profile. This information may include your name and contact information (such as email or phone number). You can use many of the features of the Services without registering, thereby limiting the type of information that we collect. You can choose not to disclose such information to us, however, without such information your access to certain features of the Services may be limited.
• We collect personal information such as name, company name, email, phone number and information about how we can help you that you voluntarily provide to us when you contact us directly, express an interest in obtaining information about us or our products and Services, or if you contact us for customer service.
• We store information regarding how you use the Services, and we may associate such usage information with your device ID or account information.
• When the Services are installed and enabled on your device (either by yourself or via a third-party integration) and you input content, share content or copy content to your clipboard (content includes, but is not limited to, text, images, voice and URLs), we may use the content in order to perform and improve the Services. If you send a referral link, we may collect, store and analyze the content adjacent to the link in order to optimize the link destination.
• We collect location data such as information about your device's location, which can be either precise or imprecise depending on how our Clients’ have set up our Services on their sites and mobile apps. How much information we collect depends on the type and settings of the device you use to access the Services. For example, if our Clients use our Services on their sites and apps, we may use GPS and other technologies to collect geolocation data. You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.
• Authentication data. Tracking code or reference number which is unique to each user.
• Transaction Data. We receive information from merchants pertaining to each transaction you complete, including purchases and returns, in conjunction with your use of our Clients’ sites and mobile apps. Please refer to those parties’ privacy policies for more specific information about the personal information collected, which may include a date and time stamp of a transaction, transaction amount, amount of reward earnings generated, discount or coupon codes used, a descriptor of item(s) in each transaction, and other characteristics of the transaction.
• Aggregate and De-Identified Information. We share aggregate, anonymized, or de-identified information about users with third parties for marketing, advertising, research, or other purposes as permitted by applicable law.
• Third Party Analytics. We may use automated devices and applications, such as Google Analytics to evaluate usage of our site and Services. We use these tools to help us improve our site’s performance and user experiences. Please review the Google Privacy Policy at https://www.google.com/policies/privacy/ to learn more. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.
• If you provide your personal information to a Client, merchant, payment processor or other third-party service provider for which we are providing Services, we do not use any of the personal information that you share with such third party for our own purposes, other than providing the Services. Any personal information that you provide to third parties are governed by those third parties’ privacy policies. Be sure to read and understand those policies.
• Payment Information: We may request payment information in order to pay rewards to you which you have earned using the Services. Payment information varies depending on which payment method you choose. For example, (a) PayPal information may consist of the email, username or phone number associated with your PayPal account (b) Bank ACH payment information may include the name on your account, the bank’s routing number, your account number, and your phone number. You can choose not to disclose payment information to us, however, without payment information we will not be able to remit to you rewards you earn using the Services.
• Tax Information: For US residents, if your reward earnings reach certain thresholds set by tax authorities, we may request that you fill out and submit to us a Form W-9 (or other form) in order for us to be able to file a Form 1099 report of your earnings. We may have a similar request for residents of countries other than the US. You can choose not to submit tax information (as described above) to us, however, without this information we may not be able to pay you rewards in excess of federal or state mandated thresholds for reporting requirements.

Disabling the Services. You have the option to enable or disable the Services. If you choose to permanently disable the Services, we will no longer collect, store, transmit, analyze, or use any of your content. If you disable the Services, we may still send you communications and updates regarding your use of the Services prior to disabling.

Information Collected Using Cookies. Cookies are pieces of text that may be provided to your computer through your web browser when you access a website. Your browser stores cookies in a manner associated with each website you visit. We may use cookies to enable our servers to recognize your web browser and tell us how and when you visit the Site and otherwise use the Services through the Internet. We may also use cookies to enable tracking and attribution of transactions which result from referrals which occur subsequent to the initial click of a referral link. Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as allowing you to decide on acceptance of each new cookie in a variety of ways. We recommend that you leave cookies active, because they enable you to take advantage of certain features of the Services. This Privacy Policy covers our use of cookies only and does not cover the use of cookies by third parties. We do not control when or how third parties place cookies on your computer. For example, third party websites to which a link points may set cookies on your computer.

Web Beacons. We or the third parties we engage to track and analyze usage data may employ clear gifs (a.k.a. Web Beacons) to help us better operate and improve the Services. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on your computer's hard drive, clear gifs are embedded invisibly on web pages. We do not tie the information gathered by clear gifs to our user' Personal Information. If you wish to disable web beacons you should do so by turning images "off" in your email client (e.g., Outlook). Please see your email provider for more information.

How We Use Your Information

Other than as described below, we do not sell, transfer, or share your information with any third party. We use your information for the following purposes:

• To operate and provide the Services, register you to use the Services and customize the Services.
• To provide customer support, respond to you when you contact us, and otherwise communicate with you via email, text message, app notifications or other methods regarding the Services, terms, policies, and other updates.
• To understand how people use the Services, evaluate, fix, and improve our Services, research, develop, and test new services and features, and conduct troubleshooting activities.
• Verify accounts and activity and promote safety and security on and off the Services, such as by investigating suspicious activity or violations of the Terms of Service, and to ensure our Services are being used legally.
• To send administrative information to Clients. We may use your personal information to send product, service, and new feature information and/or information about changes to our terms, conditions, and policies.
• To protect our Services. We may use personal information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention).
• To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract with our Client.
• To respond to legal requests and prevent harm.
• To respond to inquiries/offer support to our Client’s users. We may use personal information to respond to inquiries and solve any potential issues you might have with the use of our Services on behalf of our Clients.
• To send our Clients and prospects marketing and promotional communications. We and/or our third-party marketing partners may use the personal information for our marketing purposes if you contact us directly in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Services, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (see the "WHAT ARE YOUR PRIVACY RIGHTS?" below).
• Deliver targeted advertising on behalf of our Clients. We may use your personal information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and to measure its effectiveness at our Clients’ request.
• For other business purposes. We may use your personal information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our Services and to evaluate and improve our Services, products, marketing, and your experience. We may also use deidentified or aggregated information that does not identify you for any purpose in compliance with applicable law.

International Usage. Our Services are provided Worldwide. By using our products or services, you authorize us to transfer, process, and store your information outside of your home country, including in the United States, for the purposes described in this policy. Our computer systems are currently based in the United States where data protection requirements and privacy regulations may be different than other parts of the world. If you use the Services as a user from outside the United States, you will have agreed to the terms of this Privacy Policy and our Terms of Service, you will have consented to processing of all such information in the United States, and you will have agreed that your personal information will be subject to the requirements of the privacy regulations of the United States, which may not offer an equivalent level of protection as certain other countries.

How, and With Whom, Is My Information Shared?

Information You Choose to Submit to Third Party Services: If you use the Services to submit content or Personal Information to Third Party Services, such information is governed by the privacy settings of those particular Third-Party Services. We therefore urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through the Services. In addition, you may access Third Party Services through the Services, for example by clicking on links to Third Party Services, and subsequently submit information directly to such Third Parties Services. We are not responsible for the privacy policies and/or practices of these Third-Party Services, and you are responsible for reading and understanding those Third-Party Services' privacy policies.

Transaction Information: We may share Personal Information with merchants and their intermediaries solely for their use in validating the transactions resulting from your use of the Services.

IP Address Information: While we collect and store IP address information, that information is not made public. We do at times, however, share this information with our partners, service providers and other persons with whom we conduct business, and as otherwise specified in this Privacy Policy.

Aggregate Information: We share Aggregate Information with our partners, service providers and other persons with whom we conduct business. We share this type of statistical data so that our partners can understand how people use our Services and their services or websites, which facilitates improving both their services and how our Services interface with them. In addition, these third parties may share with us non-private, aggregated or otherwise non-Personal Information about you that they have independently developed or acquired.

Information Shared with Service Providers: We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf in compliance with this Privacy Policy. For example, without limitation: we may share your payment information with payment companies to store your payment information and remit payments to you; we may use a third party to facilitate the collection of a Form W-9 and distribution of a Form 1099; we may share data with a security consultant to help us get better at identifying spam or fraud. In addition, some of the information you submit may be collected and stored by third party providers on our behalf.

Information Disclosed Pursuant to Business Transfers: All of our rights and obligations under this Privacy Policy are freely assignable by us in connection with a merger, acquisition, restructuring, or sale of assets, or by operation of law or otherwise, and we may transfer your information to any of our affiliates, successor entities, or new ownership.

Information Disclosed for Our Protection and the Protection of Others: We also reserve the right to access, read, preserve, and disclose any information as it reasonably believes is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) determine and enforce your adherence to our Terms of Service, including investigation of potential violations thereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

Service Providers : We may share your data with service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include cloud computing, IT services, and payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts.

Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Business Partners: We may share your information with our business partners to offer you certain products, services, or promotions.

Is Information About Me Secure? We employ procedural and technological security measures that are designed to safeguard your Personal Information from loss, unauthorized access, disclosure, alteration, or destruction. We may use encryption, password protection, two-factor authentication and/or other security measures to help prevent unauthorized access to your Personal Information. Please be aware that despite our best efforts, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your password, mobile device, and computer. We are not responsible for any lost, stolen, or compromised devices or passwords, or for any activity on your account via unauthorized access.

What Information of Mine Can I Access? You can access and delete cookies through your web browser settings. You can also access and manage the information that you have provided via your account settings and profile page.

WHAT ARE YOUR PRIVACY RIGHTS?

In some regions, such as certain U.S. states, the European Economic Area (EEA) and United Kingdom (UK), you may have specific rights over your personal information.

Please note: If we are processing your personal information under the instructions of our Clients, we ask that you direct your privacy rights request to our Clients so that they may properly instruct us how to handle the request.

Marketing e-Mails. You can opt-out of our marketing emails at any time by clicking on the link in any marketing email you receive from us, or you may log into your account and update your preferences. Please note that you may still receive operational emails.

Consent. If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time.

Push Notifications. You may opt-out from allowing us to send you push notifications by adjusting the permissions in your mobile device. You may also choose which types of push notifications to receive by adjusting the permissions within the application. This opt-out choice does not apply to in app notifications.

Do Not Track. 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 preferences. At this time, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

EEA & UK

In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws and when applicable, the instructions of our Clients.

In our role as a controller under applicable data protection laws, we may process your personal information under the following legal bases:

• Consent: We may process your personal data if you have given us specific consent to use your personal data for a specific purpose. You have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• Legitimate Interests: We may process your personal data when it is reasonably necessary to achieve our legitimate business interests.
• Performance of a Contract: Where we have entered into a contract with you, we may process your personal data to fulfill the terms of our contract.
• Legal Obligations: We may disclose your personal data where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

If you are a resident in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to lodge a complaint with your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Your California privacy rights

California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about businesses’ practices related to disclosing Personal Information to third parties for the third parties’ direct marketing purposes. Alternatively, such businesses may have in place a policy not to disclose Personal Information of customers to third parties for the third parties’ direct marketing purposes if the customer or user has exercised an option to opt-out of such information-sharing. We do not share your Personal information with third parties for direct marketing purposes, so these provisions are not relevant.

California has also adopted the California Consumer Privacy Act (“CCPA”), effective beginning in 2020. We comply with the requirements of the CCPA to the extent they apply to us. For purposes of the CCPA and this section, the term Data applies to all the Personal Information we collect about you. However, to the extent that Personal Information is de-identified and aggregated, it is not considered Data under the CCPA or this section.

If you are a California resident, you have the following rights:

• You have the right to request that we disclose the categories and the specific items of Data about you that we collect, use, disclose, and/or sell and that Data about you that we have collected, used, disclosed, and/or sold during the 12 months prior to your request.
• You also have the right to have the Data we collect about you deleted. We use a two-step process to verify your identity and to have the information deleted. Your rights to have Data deleted are subject to several exceptions, specifically the Data that is necessary for us to:
  • complete your transaction;
  • provide you a good or service;
  • perform a contract between us and you;
  • protect your security and prosecute those responsible for breaching it;
  • fix our system in the case of a bug;
  • protect the free speech rights of you or other users;
  • comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);
  • engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws;
  • comply with a legal obligation; or
  • make other internal and lawful uses of the information that are compatible with the context in which you provided it.
• To make any request under the CCPA, please email us with your full name and email address at privacy@wildfire-corp.com. Our Data Request Policy states that you will be asked to give us your name, e-mail address, telephone number, and any other information we request to reasonably verify your identity. We will respond to your request within 10 days after receipt of your request, and we will then take action to verify your identity and fulfill your request, as required by the CCPA.
• We will provide you with a CSV copy of your stored data within 45 days of your request, assuming we are able to verify your identity in that period and so long as you provide a correct email address for successful correspondence.
• You have the right not to receive discriminatory treatment by us for the exercise of any privacy rights conferred by the CCPA, which means that we will not take any action to hurt or punish you for exercising your rights under the CCPA.
• You may designate an authorized agent to make a request under the CCPA on your behalf by writing us at privacy@wildfire-corp.com. Upon receipt of your request, we will provide you with the information you will need to designate that agent.
• For more information, please direct your questions to us at privacy@wildfire-corp.com.

When we provide Services to our Clients, we are a “service provider” under the CCPA. When a California resident makes a privacy rights request under the CCPA (for example, to access or delete their personal information), our Clients are responsible for verifying the identity of the resident and directing us how to respond. Please refer to our Clients’ privacy policies for further information about their privacy practices and how to exercise your privacy rights.

We have listed the specific and general categories of information we have collected or disclosed in the last 12 months in this Privacy Policy. This Privacy Policy also lists the specific and general categories of Data we have disclosed to third parties for our business purposes.

We do not sell your personal Data. However, we do disclose certain categories of Data to the merchants whose businesses you visit using the Services, all as described in this Privacy Policy.

We do not sell the Personal Information of minors under 16 years of age.

Children. We do not knowingly collect personal information from or market to children. We do not knowingly solicit data from or market to children. If we learn that personal information from children has been collected, we will deactivate the account and take reasonable measures to promptly delete such personal information from our records. If you become aware of any personal information, we may have collected from children, please contact us at privacy@wildfire-corp.com.

What Happens When There Are Changes to this Privacy Policy? We will update this privacy policy through our site as necessary to stay compliant with relevant laws. We may update this privacy policy from time to time. The updated version will be indicated by an updated date. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

What If I Have Questions or Concerns? If you have any questions or concerns regarding privacy using the Services, please send us a detailed message via email at privacy@wildfire-corp.com or via postal mail at Wildfire Systems, Inc., 153 S. Sierra Ave., #1282, Solana Beach, CA 92075.