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CINCH PRIVACY POLICY

Cinch, LLC (referred to herein as “Cinch,” “we,” “us” or like terms) has created this privacy statement (“Privacy Policy”) in order to demonstrate our firm commitment to privacy. The following discloses our policies for information gathering and dissemination practices for our current and future online and mobile websites, platforms, services, applications, and networks owned or operated by Cinch, including without limitation, www.Cinch.io and/or other sites or applications through which Cinch currently or in the future provides services and/or technology (the “Site” or “Sites”).

Information We Collect:

When you interact with us through the Sites, we may collect personal information and other information (“Personal Information”) from you, as further described below:

 

Personal Information That You Provide Through the Sites: We collect and store Personal Information from you when you voluntarily provide such information by registering for access to our services, using certain services, contacting us with inquiries or any other voluntary disclosure of your Personal Information. For example, we may collect your name, address, phone number, email address, third party service login credentials, and the messages you send or receive through our Sites and services. Wherever Cinch collects Personal Information we make an effort to provide a link to this Privacy Policy.

 

By voluntarily providing us with Personal Information, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Information, you acknowledge and agree that such Personal Information may be transferred from your current location to the offices and servers of Cinch and the authorized third parties referred to herein located in the United States.

 

Non-Identifiable or Aggregated Data: When you interact with Cinch through the Sites, we also receive and store certain personally non-identifiable information. Such information, which is collected using various technologies, will not be used in such a way to specifically identify you. Cinch may store such information itself or such information may be included in databases owned and maintained by Cinch affiliates, agents or service providers. We may use such information and pool it with other information to track, for example, the total number of visitors to or users of the Sites, the number of visitors to each page of our website, the domain names of our visitors’ Internet service providers, and how our users use and interact with the Site. Also, in an ongoing effort to better understand and serve the users of the Sites, Cinch may conduct research on its customer demographics, interests and behavior based on the Personal Information and other information provided to us. This research may be compiled and analyzed on an aggregate basis. Cinch may share this non-identifiable and aggregate data with its affiliates, agents and business partners, but this type of non-identifiable and aggregate information does not identify you personally. Cinch may also disclose aggregated user statistics in order to describe our services to current and prospective business partners and to other third parties for other lawful purposes.

 

In operating the Sites, we may also use a technology called “cookies.” A cookie is a piece of information that the computer that hosts our Sites gives to your browser when you access the Sites. Our cookies help provide additional functionality to the Sites and help us analyze Sites usage more accurately. For instance, our Sites may set a cookie on your browser that allows you to access the Sites without needing to remember and then enter a password more than once during a visit to the Sites. In all cases in which we use cookies, we will not collect Personal Information except with your permission. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Site’s features.

 

Our Use of Your Personal Information and Other Information

 

Cinch uses the Personal Information you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Information for a certain reason, we may use the Personal Information in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Information you provide to answer your question or resolve your problem. Also, if you provide Personal Information in order to obtain access to the Sites and services offered by the Company, we will use your Personal Information to provide you with access to such services and to monitor your use of such services. Cinch and its subsidiaries and affiliates (the “Related Companies”) may also use your Personal Information and other personally non-identifiable information collected through the Sites to help us improve the content and functionality of the Sites, to better understand our users, and to improve the services offered by Cinch. Cinch and its Related Companies may use this information to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each communication we send you will contain instructions permitting you to “opt-out” of receiving future communications. In addition, if at any time you wish not to receive any future communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.

 

If Cinch intends on using any Personal Information in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Information is collected.

 

Our Disclosure of Your Personal Information and Other Information

 

Cinch does not rent or sell your information. There are, however, certain circumstances in which we may share your Personal Information with certain third parties without further notice to you, as set forth below:

 

Related Companies: We may share your Personal Information with our Related Companies for purposes consistent with this Privacy Policy.

 

Agents, Consultants and Related Third Parties: Cinch, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include maintaining databases, sending emails and SMS messages, offering and developing certain features of the Sites, and maintenance and security. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function. We also disclose automatically collected data (card scans, promotional activities, and redemption information) to our business partners, clients, third-party ad servers and advertisers. These third parties may match this data with information that they have previously collected about you under their own privacy policies, which you should consult on a regular basis.

 

Commercial Clients:

 

Legal Requirements: Cinch may disclose your Personal Information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation or assist government enforcement agencies, (ii) protect and defend the rights or property of Cinch, business partners, clients, or our users, (iii) act in urgent circumstances to protect the personal safety of users of the Sites or the public, (iv) protect against legal liability; (v) protect business partners and clients from fraudulent, abusive, or unlawful uses; or (vi) protect the security or integrity of the Sites.

 

With the Ability to Opt-Out: Maintenance of Account Information/Opt-Out.  You may access and update information provided to Cinch when you created your account or opt-out of receiving communications from us at any time by logging into your account and updating the desired information or by contacting us using the contact information provided below.


The Sites will automatically send you SMS messages with updates and other information as part of the services offered by Cinch. You may stop receiving SMS messages from Cinch generally by replying STOP in response to any received SMS from the program. You may also opt-out of receiving SMS messages on the Cinch website. If you opt-out of receiving SMS messages, you may not be able to use certain Services.

Your Choices:

 

You can use our website without providing any Personal Information. If you choose not to provide any Personal Information, you may not be able to use certain services offered by Cinch.

 

Exclusions:

 

This Privacy Policy does not apply to any Personal Information collected by Cinch other than Personal Information collected through the Sites. This Privacy Policy shall not apply to any unsolicited information you provide to Cinch through the Sites or any other means (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Cinch shall be free to reproduce, use, disclose, distribute and exploit such Unsolicited Information without limitation or attribution.

 

Children:

 

Our Site is not specifically directed toward children, and we do not knowingly collect personal information from persons under the age of 13 on our Sites without parental consent.  We are committed to protecting the privacy of children and abide by the Federal Trade Commission’s Children’s Online Privacy Protection Rule. Please visit www.ftc.gov/kidsprivacy for information from the Federal Trade Commission about protecting children’s privacy online.

 

Links to Other Web Sites:

 

Our Site may provide links to third-party sites that are not operated by Cinch, including our Commercial Clients.  We are not responsible for the privacy policies or content of those sites and recommend that you check the relevant privacy policies of those sites to determine how your personal information will be used. 

 

Security:

 

Cinch takes reasonable steps to protect the Personal Information provided via the Sites from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet, email, mobile or other electronic transmission is ever fully secure or error free, so you should take special care in deciding what information you send to us in this way. If you create an account on our Site, you must maintain the confidentiality of your account and password and restrict access to your computer.  You agree to be responsible for all activities that occur under your account or password and agree to be responsible for all charges. We have the right to refuse service, terminate your account, or take other actions in our discretion. You agree to inform us of any unauthorized use and to take steps to prevent its further unauthorized use. 

 

Do Not Track Requests:

 

When this Site receives Do Not Track signals and other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal identifiable information, we honor those requests.

 

Other Terms and Conditions:

 

Your access to and use of the services offered by Cinch is subject to Cinch’s Terms of Use located at our website.

 

Changes to Cinch’s Privacy Policy:

 

We reserve the right, at our discretion, to change, modify, add, and/or remove portions of the Privacy Policy at any time.  When we make changes to the Privacy Policy, we will post the changes on the Site and update the revision date at the bottom of the Privacy Policy.  By continuing to access the Site after we have changed the Privacy Policy, you signify your acceptance of the changes.  Accordingly, we encourage you to check the Privacy Policy to remain informed of any changes.

 

Access to Information; Contacting Cinch:

 

To keep your Personal Information accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Information in our possession that you have previously submitted via the Sites.

 

Please also feel free to contact us if you have any questions about Cinch’ Privacy Policy or the information practices of the Sites.

 

You may contact us at:

 

Cinch, LLC

support@cinch.io

 

Effective Date: 11 Nov 2017