RAM
Deals - Privacy Policy
This Privacy Policy ("Privacy
Policy") explains how Rocky Mountain Student Media ("Rocky Mountain Student Media", "us",
"our", and "we"), collects and uses information when you
interact with us. This Privacy Policy applies to all users of Rocky Mountain
Student Media's mobile-device applications we offer, such as our iOS and
Android applications, that are developed by "Rocky Mountain Student
Media" and link or reference this Privacy Policy (collectively, the
"Services").
Please read this Privacy Policy carefully.
This Privacy Policy replaces and supersedes the last version of this Privacy
Policy for all users (including for those users that registered prior to the
Effective Date). If you do not agree to our practices, please do not register,
subscribe, create an account, or otherwise interact with the Services. Your use
of the Services is also subject to our Terms of Use.
Please contact us if you have any questions or comments about
our privacy practices or this Privacy Policy. You can reach us via postal at
the following address:
Rocky Mountain Student Media
CSU Lory Student Center, Room 118
1101 Central Ave. Mall
Fort Collins, CO 80523
a.
Contact
Information that allows us
to communicate with you, such as your name, postal addresses, email addresses,
social media website user account names, telephone numbers, or other addresses
at which you receive communications from or on behalf of Rocky Mountain Student
Media.
b.
Relationship
Information that helps us to
understand who you are and what types of stores, products, and advertisements
you might like. This includes lifestyle, preference, and interest information;
the types of coupons that interest you; information collected from social media
interactions (such as via Facebook Connect); and demographic information (e.g.,
birth date, age, gender, zip code).
c.
Transaction
Information about how you
interact with the Services, such as the coupons you view and redeem, the gift
cards you purchase or sell via our Services, the digital rebates that you
claim, including copies of receipts that you submit; other information about how
you use our Services, email, other communications, and applications; and how
you interact with Rocky Mountain Student Media's merchants, business partners,
and service providers after interacting with our Services, including, in some
cases, the items you purchase from those merchants.
d.
Location
Information allows us to
periodically determine your geolocation, such as your location relative to
nearby merchants or, your presence within a mall or store (e.g., near a
checkout, aisle, or entrance) or your state/province, city, or neighborhood
using technologies such as Bluetooth®, beacons or geofencing to tailor our
Services for providing you the best experience. Rocky Mountain Student Media
does not record and store your location information, nor do we use location
information for tracking any users using our Services.
Please see the Section 5 under the heading
"mobile" for information on how to limit the Location Information
that Rocky Mountain Student Media may collect from the Services operating on a
mobile device. Rocky Mountain Student Media does not store or share location
information.
e.
Analytics
Information about your use
of our Services, such as your IP address, access time, device ID or other
unique identifier (e.g., Android advertising ID or Apple IDFA), domain name,
screen views, language information, device name and model, operating system
type, and your activities on our Services. For example, information collected
by our Services via a mobile device may include the following: (i) the names of the other applications on your mobile
device and, if you use an Android-based mobile device, how you use them (e.g.,
frequency and duration of use); (ii) if you use an Android-based mobile device,
the URL addresses of the webpages you access; (iii) information about your
mobile device (e.g., make, model, operating system, and other similar
information, but not phone number); (iv) information about your use of
features, functions, or clicks on notifications or content; and (v) the
strength of signal, temperature, battery level, and unique identifier of a
nearby Bluetooth® proximity beacon.
We collect Personal Information when you use
our Services on one or more of your devices that interact with the Services.
For example, we may track the coupons you view, submit
or redeem via a desktop computer, the gift cards that you purchase from us via your
mobile device.
If you use a social media platform, a mobile
device or other third-party method of communication to interact with Rocky
Mountain Student Media or the Services, that platform may have a specific
privacy statement that governs the use of Personal Information related to that
platform. If you have questions about the security and privacy settings of your
mobile device, please refer to instructions from your mobile service provider
or the manufacturer of your device to learn how to adjust your settings.
If you use the Services on a mobile device and
your mobile device's settings allow it, we may collect Personal Information
from your mobile device. For example, if you have permitted your mobile device
to transmit location data, we may collect your geolocation and time of day. In
addition, if you have also enabled Bluetooth® functionality on your mobile
device, our Services may determine your presence and duration within a
location, such as a mall or store, based on the detection of signals from
nearby Bluetooth® proximity beacons. Our application may be designed to collect
information even if you are not logged into one of the Services. In some cases,
for example, we may use your Internet Protocol ("IP") address to
estimate your general location even if you have not logged in or enabled
location tracking on your mobile device. Please see the Your Choices section
under the heading "mobile" for more information on how to limit the
Location Information that Rocky Mountain Student Media may collect from the
Services operating on a mobile device.
From time to time, we may also supplement
Personal Information with information collected from third parties, including
demographic information, information about your interests, and similar
information that the third parties have collected from other sources (which may
include analytics data from third party websites). For example, we may collect
information from third parties to enhance other information we have about you,
to help us better understand you, to provide you with targeted advertising, and
to otherwise enhance the Services.
a.
Operate and improve
our Services;
b.
Provide users with
content and advertisements across their devices for products and services from
merchants, including coupons based on variables such as stated and anticipated
user interests, personal characteristics, and location;
c.
Evaluate eligibility
of users for certain coupons, products or services;
d.
Evaluate the types of
coupons, products or services that may be of interest to users;
e.
Track redemption of
coupons and perform other analytics;
f.
Provide user support,
including to merchants or business partners;
g.
Fulfill requests for
Rocky Mountain Student Media services;
h.
Communicate and
provide additional information that may be of interest to you about Rocky
Mountain Student Media and featured merchants and business partners, such as
Rocky Mountain Student Media news, special offers and coupons, announcements,
and marketing materials;
i.
Send you reminders,
technical notices, updates, security alerts and support and administrative
messages service bulletins, or marketing;
j.
Provide commercial
notifications when you arrive at, linger near or leave places;
k.
Infer the location of
the places you visit most often, determine your frequency at these locations,
and send notifications when you arrive at or leave those places;
l.
Provide advertisements
to you through the Services, third-party sites, email messages, text messages,
mobile-push notifications, or other methods of communication;
m.
Administer surveys,
sweepstakes, contests, or other promotional activities or events sponsored by
us or our partners;
n.
Create user profiles
that may contain inferences about users such as age range, income range,
gender, and interests;
o.
To help verify
accounts and activity, and to promote safety and security on and off of our
Services, such as by investigating suspicious activity or violations of our
terms or policies and assessing the relative risk that a particular activity
(e.g., the purchase or sale of a gift card) may be unauthorized or fraudulent;
a.
With affiliated
companies (e.g., subsidiaries and other companies owned by or controlled by
Rocky Mountain Student Media) who may only use the Personal Information for the
purposes described in Section 3 above;
b.
With our service
providers that provide services for us to assist us in carrying out the
purposes described in Section 3 above such as sending emails, push
notifications, or SMS messages on our behalf, assessing potential fraud (such
as in connection with the purchase or sale of gift cards) and conducting
surveys or sweepstakes on our behalf. Rocky Mountain Student Media enables
certain geo-location features of our mobile-device applications. Consequently,
Rocky Mountain Student Media and its affiliates collect, store, and process,
certain Location Information and related data on
servers in the United States. Rocky Mountain Student Media is bound by law or
contract to protect Personal Information and are only allowed to use the
Personal Information in accordance with the terms of our service agreements
with them. In some limited cases, such as for purposes of investigating
suspicious activity and assessing the likelihood for fraud, some of our service
providers may use the Personal Information that we provide them for the purpose
of improving their own services;
c.
Coupon Merchants, but
only to the extent you have redeemed a coupon offered by the merchant, or
participated in an offer, contest or other activity sponsored or offered
through Rocky Mountain Student Media on behalf of the merchant;
d.
Rocky Mountain Student
Media business partners or advertisers, as part of an offer, contest, or other
activity that is provided by or in conjunction with Rocky Mountain Student
Media and its business partners and in which you have elected to participate.
For example, if you are referred to Rocky Mountain Student Media from a
business partner's website or through an invitation facilitated by or in conjunction
with a Rocky Mountain Student Media business partner, Rocky Mountain Student
Media may provide that business partner with Contact Information and
Transactional Information to validate the referral and to support the terms of
the relationship between Rocky Mountain Student Media and the business partner,
which may allow such business partner to contact you directly and to advertise
to you. Rocky Mountain Student Media does not use Identifiers for Advertisers
(IFDA) to track user behavior across websites, or offline properties for the
purposes of targeting, personalization, and measurement.
e.
To affect a merger,
acquisition, or otherwise; to support the sale or transfer of business assets;
to enforce our rights or protect our property; to protect the rights, property or safety of others, investigate fraud, respond to
a government request; or as needed to support auditing, compliance, and
corporate governance functions. We may also disclose Personal Information to
defend ourselves in litigation or a regulatory action, and when required or
advised to do so by law, such as in response to a subpoena, a reporting
requirement or similar legal process, including to law enforcement agencies,
regulators, and courts in the United States and other countries where we
operate. If Rocky Mountain Student Media is involved in a merger, acquisition,
or sale of all or a portion of its assets, you will be notified via email
and/or prominent notice on one or more of our Services of any change in
ownership or uses of your Personal Information, as well as any choices you may
have regarding your Personal Information; or
f.
Otherwise with your
consent.
We encourage Rocky Mountain Student Media
merchants and business partners to adopt and post privacy policies. However,
the use of your Personal Information by such parties is governed by the privacy
policies of such parties and is not subject to our control. When you choose to
interact with a Rocky Mountain Student Media merchant or business partner, we
encourage you to read any privacy policy they may have posted on their website.
We may also disclose information about you
that is not personally identifiable. For example, we may provide merchants,
business partners, or other third parties with reports that contain aggregated
and statistical data about our users.
a.
Email. You can manage your subscriptions by
following subscription management instructions contained in the commercial
messages that we send you. If you wish to opt out of receiving offers directly
from Rocky Mountain Student Media merchants or business partners, you can
follow the opt-out instructions in the emails that they send you.
b.
Mobile
App. If you access
any of our Services through one of our mobile applications, you may manage how
your Personal Information is shared with Rocky Mountain Student Media. You may
adjust the settings on your mobile device to allow or restrict the sharing of
Location Information. For example, the "Location" permissions (or
"Privacy" >> "Location Services" on iOS-based
devices) on your mobile device will allow you to elect whether to never share
Location Information with Rocky Mountain Student Media, to share Location
Information only while you are using the application (e.g., to help you find
nearby offers), or always share Location Information even while you are not
using the application (e.g., alert you of nearby offers when you approach a
shopping mall). You may also elect to only disable "Bluetooth" to
prevent just the sharing of information collected via nearby Bluetooth ®
proximity beacons. Please note that if you elect to not share your Location
Information, you may be unable to access some features of our Services that are
designed for mobile devices. Also, in the event that
you prevent the sharing of Location Information, we may still estimate your
general location based on the IP address you use to access our Services.
You may also manage how your mobile device
handles ad-related tracking technologies by adjusting your mobile device
privacy settings. For example, the "Privacy" settings of an iOS
device will allow you to "Limit Ad Tracking" and reset your mobile
device's "Advertising Identifier." Please refer to instructions
provided by the manufacturer of your device to learn how to adjust your mobile
device settings.
You may also opt-out of receiving different
types of push notifications or alerts by toggling off the
"Notifications" options within the "Profiles" menu of our
mobile applications. This feature is available in the most recent versions of
our iOS-based and Android-based applications.
c.
Connecting
through Social Networks. You
may manage the sharing of certain Personal Information when you register with
us through a social media platform or application, such as through Facebook
Connect. Please refer to the privacy settings of the social media platform or
application to determine how you may adjust our permissions and manage the
interactivity between Rocky Mountain Student Media and your social media
account. By registering with Rocky Mountain Student Media through a social
media platform, you grant Rocky Mountain Student Media permission to access all of the elements of your social network profile information
that you have made available to be shared and to use it in accordance with the
social network's terms of use and this Privacy Policy.
If you want to close your account or have
other questions or requests, or if you would like to access or request a
correction to any other Personal Information we hold regarding you, please
(email [email protected])
We will retain your information for as long as
your account is active or as needed to provide you services. If you wish to
cancel your account or request that we no longer use your information to
provide you services, (email [email protected]). In response, we will
cancel or remove your information but may retain and use copies of your
information as necessary to comply with our legal obligations, resolve
disputes, and enforce our agreements.
To ensure adequate protection of personal data
of the European Economic Area (the "EEA"), any transfers of such data
outside of the EEA will be pursuant to the Model Clauses approved by the
European Commission. Rocky Mountain Student Media commits to resolve complaints
about your privacy and our collection or use of your personal information. We
encourage anyone with inquiries or complaints regarding this privacy policy
should first (email [email protected]).
Merchants and business partners may have their
own privacy statements, too. We encourage you to familiarize yourself with the
privacy statements provided by these other parties prior to providing them with
information or taking advantage of an offer or promotion.