Main Source Media, LLC (“Main Source Media,” “we,” “our,” or “us”) operates this website and other websites (“Website” or “Websites”) that enable users to earn gift cards and/or merchandise (“Rewards”) and to purchase products and services (“Deals” or “Promotions”) made available on our Websites from our advertiser clients and marketing partners (collectively, “Marketing Partners”). We provide the following Privacy Policy ("Privacy Policy” or “Policy”), which describes how we collect, use, disclose, and share or sell information that is personally identifiable to a user (“Information”). Capitalized terms used but not defined herein shall have the same meaning as in the Website’s Terms and Conditions, which are fully incorporated herein by reference. 

WHO WE ARE  

Main Source Media, LLC is a company located in the United States of America (“U.S.”) and is registered in the State of Delaware with offices at 300 Vesey Street, 9th Floor, New York, NY 10282. Our General Counsel and Chief Compliance Officer, Daniel Barsky, is responsible for our data protection practices, including handling any complaints or inquiries. Daniel Barsky can be contacted at barskydpo@fluentco.com. 

ACCEPTANCE OF PRIVACY POLICY  

By accessing and using one of our Websites, you signify your acceptance of this Privacy Policy and your agreement to the collection, use, disclosure, and sharing or sale of your Information as described herein. If you do not intend to agree to the terms of this Privacy Policy, DO NOT use the Website. You may also exercise those choices we describe in this Policy.  

PRIVACY POLICY UPDATES  

This Privacy Policy is subject to change from time to time. Your continued use of the Website following the posting of changes to these terms will confirm your acceptance of all changes made, except for changes that expand the use of your Information. If we change this Privacy Policy, we will (i) publish the updated Privacy Policy on our Website and (ii) notify users by means suitable to reach indiviuals concerned by the Privacy Policy as required under applicable law.   

FOR CANADIAN RESIDENTS ONLY   

Please note if you are not a resident of Canada, you are not permitted to use the Website and/or otherwise access any other Rewards or Deals. 

CATEGORIES OF INFORMATION WE COLLECT  

We may collect the following categories of Information: 

• Identifiers (such as real name, alias, postal, email and/or IP addresses, telephone numbers, birth date, and government-issued identification cards); 

• Personal information (such as the Identifiers listed above and personal attributes such as gender, education, marital status, employment history, financial information, home or auto ownership, political affiliation, views on various issues and responses to wellness questions); 

• Biometric Data, in the form of users uploading a government-issued identification card along with a selfie or live video for the purpose of verifying their identity prior to claiming Rewards; 

• Commercial information (including preferences, products or services purchased, obtained, or considered, or other purchasing data);  

• Information related to a user’s interaction with us (such as customer service interactions and interactions with communications we may send); 

• Internet or similar network activity (such as browsing and search history and information about a consumer’s interaction with a website, application, or advertisement) and information made available via Internet activity (such as device types, user agent data including browser type, and display and language settings, referring URLs, and IP addresses); 

• Information related to a user’s consent to receive telemarketing calls, SMS messaging, push notifications, commercial email, and other forms of communication (which may include the creation of a report and session recordation of a user interacting with page(s) that seek to obtain a record of a user’s prior express consent to receive such messages; and 

• Inferences drawn from other categories of Information (for example, a profile reflecting a person’s preferences, characteristics, psychological trends and attitudes). 

HOW WE COLLECT INFORMATION  

We may collect Information from the following sources: 

• Directly from users via registration forms, surveys, communications (including, with consent when required, business and commercial emails, telephone calls, mail, and other contacts received from users), and, in the case of Biometric Data, when you upload your Information as part of the Rewards claim process for Identity Verification; 

• Via our hosting servers, which collect Information from users through various technological means when users access and interact with the Website; 

• From our service providers and contractors who assist us in hosting the Websites, providing customer support, and fulfilling Rewards; 

• From parties under our common control (which includes our parent, subsidiaries, and other entities under common control with us - collectively “Related Parties”); 

• From business that we share or sell Information to, including our Marketing Partners, where users have provided their consent where required who may (a) send emails, push notifications, or SMS messages or make telemarketing calls to users, (b) drive users to our Website, and/or (c) advertise goods and services on the Website; 

• From cookies (small text files placed on a user’s browser by a website such as the Website that track online behavior), web beacons (single-pixel GIF image files), and other technological means (collectively, “Cookies”); and 

• By combining Information collected from the various sources listed above, including our Marketing Partners and Related Parties, to augment and verify Information and to improve the overall quality of our services. 

HOW WE MAY USE INFORMATION 

We may use Information in the following ways: 

• For the purpose of providing you with information about our Rewards, Deals, and other content and products and/or services that we believe may be of interest to you, including sending email, direct mail, text/SMS message alerts, telemarketing messages and other communications that users have requested or consented to receive or that we are required to send concerning users’ registrations;  

• For Website operations, content improvements, testing, research, analysis, and product development. For example, we use Internet or similar network activity and device information to improve our services and performance of our Website, and to ensure it displays correctly; 

• To verify whether users are entitled to participate in the Rewards Program and, if so, to fulfill Rewards; 

• To provide users with customer service and respond to customer inquiries; 

• To carry out our obligations and enforce our rights arising from any contracts entered into between users and us, including for purposes of our Arbitration Agreement, any inquiry related to our compliance with applicable laws and regulations, or as we otherwise think needed to protect our rights, including in the course of litigation; 

• To detect, investigate, and respond to any fraudulent or malicious activity or any other activity we determine is or may be a violation of our Terms and Conditions, this Policy, or existing laws, rules, and regulations; 

• As necessary or appropriate to protect the rights, property, and/or safety of us and our Marketing Partners, Related Parties, service providers, and any other third-party with whom we have a contractual relationship for commercial or business purposes; 

• To maintain suppression or opt-out lists so that we won't contact users who have asked not to be contacted; 

• To augment Information (such as Identifiers, personal preferences, and commercial preferences) by enhancing it with other data sources provided by our Marketing Partners, Related Parties, and service providers to enable us, for example, to gain deeper insights into our users, and provide better services and Website experiance; and 

• To respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims, or when we determine it is necessary to comply with applicable laws and/or regulations. 

HOW WE SHARE AND/OR SELL INFORMATION 
 

We may share and/or sell Information in the following ways: 
 

• With our service providers (which include vendors and other third parties we contract with for business purposes), and/or our Marketing Partners in connection with the conduct of our business, including marketing activities, such as the delivery of email messaging, telemarketing calls, text/SMS messaging, and push notifications, provided that we have obtained any required consent; 

• With our interest-based Marketing Partners to create sets of Information which are made available for use by third-party Marketing Partners for programmatic advertising purposes; 

• With our Related Parties to augment and verify the Information we collect and to develop and enhance their products and services; 

• With one or more service providers who provide independent verification of consent to receive communications from us and our Marketing Partners; 

• To enable third parties, including our Marketing Partners and data and list management partners, to market products and services to you; 

• To enable our customer service vendors to perform their respective tasks, including for fulfillment of Rewards (including our Identity Verification process); 

• To enable our Information verification and fraud detection service providers to perform contracted-for services; and 

• To submit users’ contact information to comment and petition campaigns run by governmental agencies, elected officials, or other parties where users have provided their express consent to endorse and be a part of the campaign, including, in some instances, appending the user contact information with specific comment language. 

When we share and/or sell Information, we enter into agreements that describe the purpose for which the Information is shared/sold, restrict its use to the agreement’s specified purpose, and require that all Information remain confidential and be protected from unauthorized disclosure. 

We may also share Information with applicable third parties as necessary if we become the subject of bankruptcy proceedings, or in connection with the sale, assignment, merger, or other transfer of all or a portion of our business. If we are involved in these types of transactions, we will notify users via email and via a Privacy Policy update on the Website regarding any material details pertaining to Information. 

WELLNESS INFORMATION 

Our surveys may ask health-related questions which we may share with our Marketing Partners who advertise health-related products and services on our Websites, or who otherwise promote health-related products or services. We will use this health-related Information - with your consent - to display offers for health-related products and services or to provide Information to these providers so they can contact you.   

DATA TRANSFERS AND STORAGE 

The Information we collect about you will be transferred to and stored in the U.S. It may also be processed by personnel operating outside of Canada who work for us or for one of the third parties with whom we share Information. 

Personal information processed and stored in another country may be subject to disclosure or access requests by the governments, courts or law enforcement or regulatory agencies in that country, according to its laws. If you have any questions about our use of service providers outside of your province or of Canada, you may contact us using the information below.  

DATA RETENTION 

We keep your Information for as long as it is necessary to accomplish the purposes for which it was collected, outlined above. We may retain your Information for up to six (6) years from when we stop providing our services to you, in accordance with laws in Canada and the U.S. on legal limitation periods, unless a longer retention period is required or permitted by law. 

WHAT IF I DECIDE NOT TO PROVIDE MY INFORMATION?  

You are not obligated to provide us with your Information, such as answers to survey questions, in order to use our Website. However, if you choose not to provide Information regarding your identity and/or how to contact you, your ability to use this Website may be limited.  For example: 

• We will not be able to register you on our website (as we don’t know who you are);  

• We will not be able to contact you if you have a query (as we won't have your name and contact details);   

• We will not be able to tailor the Rewards and Deals we offer you to your personal preferences; and 

• Our Website may not work properly on your device if we cannot collect any information about your visit. 

EIGHTEEN (18) YEARS OR OLDER 

Our Websites are intended for use only by Canadian residents who are eighteen (18) years of age or older. We do not knowingly collect or retain Information from children under the age of fourteen (14) years and any minor under the age of fourteen (14) years is not permitted to claim Rewards.  

COOKIES, INTEREST-BASED ADVERTISING AND THIRD-PARTY ANALYTICS 

Our website uses Cookies to determine whether users have previously visited the Website and to streamline the registration process so, for example, users don’t have to re-enter their basic registration information when they return to the Website. We may also use Cookies to enhance a user’s experience while on the Website. Some of our third-party Marketing Partners may place Cookies on the Website to track users’ online behavior while on the Website and after they leave the Website. These third-party Cookies may enable the delivery of interest-based advertisements (to find out more about Cookies, please visit www.cookiecentral.com) based on a user’s visit to our Website and/or other websites.  In addition, our Marketing Partners may use information gathered in this manner to recognize you across different channels and platforms, including computers, mobile devices, and Smart TVs and may use this information over time for advertising, analytics, attribution and reporting purposes.  

We may use Google Analytics and similar tools provided by third parties to help analyze how users interact with the Website and to display customized ads and other content to our users during a current browsing session or in the future when the user is online.  For more information on how Google Analytics collects and processes information, please visit: www.google.com/policies/privacy/partners/.  For information about how to opt out of having your information used by Google Analytics, visit: https://tools.google.com/dlpage/gaoptout/.  

Most computers are initially set up to accept Cookies, but users can reset their Internet browsers to refuse all Cookies or to indicate when a Cookie is being sent. To disable and reject certain Cookies, follow the instructions associated with your Internet browser. Even where you reject a Cookie, you may still use the Website but your ability to use certain features or offerings may be impaired.  For example, if you return to our Website, you may have to re-enter information that you previously supplied to us.   

Users may opt-out from interest-based advertising delivered to their web browser by companies who have elected to participate in one of the interest-based advertising opt-out mechanisms, such as the Digital Adverting Alliance’s opt-out program located here or the National Advertising Institute’s opt-out program located here.  Users may also choose to opt-out of interest-based advertising on their mobile devices.  For more information, please click here.   

Please note that opting out of interest-based advertising does not mean you will no longer see advertising online. Rather, it does mean that the company or companies from which you opt-out will no longer show ads that have been tailored to your interests. 

OPTING-OUT FROM MARKETING 

Users may opt-out from receiving future contact from us using the following methods: 

• Email Opt-Out. To opt-out from email marketing and to remove your data from programmatic advertising enabled by contacting customer service, click the “Unsubscribe” link on the bottom of every page or click here; 

• Telemarketing Consent Opt-Out. Providing consent to receive telemarketing communications is not required to qualify for a Reward. You may continue to use all other aspects of the Website, regardless of whether you elect to provide consent to receive telemarketing communications. Users who elected to provide consent to receive telemarketing communications but later wish to revoke it can opt out from future telemarketing calls by following prompts to stop individual telemarketing calls on recorded calls, by informing calling parties that they wish to be placed on their do not call list, or by contacting, as appropriate, the Marketing Partner(s) or our customer service team here;

• SMS/Text Messaging Opt-Out. To opt-out from SMS/text messaging, reply STOP to the text/SMS message received; 

• Push Notification Opt-Out. To opt-out of browser-based push notifications, please disable the notifications at the time you receive the notification or disable notifications through your browser’s settings; and 

• Targeting Advertising Opt-Out. To-opt out of cookies, interest-based advertising and/or third-party analytics, please see the section above. 

OPTING OUT OF SHARING/SALE OF INFORMATION 

To opt-out of the sharing/sale of your Information click on the “Do Not Sell My Personal Info” link on the bottom of the Website page(s) that you have visited and/or provided Information to and complete the form. You can also send an email to help@myprivacyrequest.com, stating that you want to opt-out of the sale and sharing of your Information. We do not require a verification process to opt-out, but we reserve the right to confirm this request by sending you an email containing a final “Do Not Sell My Personal Info” link and requesting that you respond to the email. Please note that it may take us several days to process an opt-out request. 

YOUR RIGHTS, INCLUDING ACCESSING, CORRECTING, AND DELETING YOUR INFORMATION 

You have certain data protection rights subject to applicable laws. For example, supported by a written request and proof of identification, you may consult what Information has been collected, used or shared, and/or ask that it be corrected. In addition, you may withdraw your consent to the collection, use, or sharing of your Information, including its sale. You may also be entitled to additional rights such as (i) the right to control the dissemination of your personal information; (ii) the right to receive computerized personal information collected from you in a structured, commonly used and technological format and to have this information transferred directly to another organization; (iii) the right to be informed of and submit observations regarding automated decision-making; and (iv) the right to request information about data processing. 

Users who provide Information to us may contact us here to withdraw their consent, correct their Information and/or access what Information we have collected, used, and shared/sold. We will endeavor to respond to user requests within thirty (30) days. If you withdraw your consent and your Information is subsequently deleted, please note that your Information will be suppressed from further use as described in this Policy. However, please remember that if we have already shared your Information with our third-party Marketing Partners, you will need to contact those Marketing Partners individually to have them suppress or delete your Information. Note that we may retain and use your Information as necessary to comply with our policies including legal obligations, dispute resolution, and enforcement of our agreements.  

When you make a request regarding accessing or correcting your Information, or to withdraw your consent, we will ask individual users to identify themselves and the Information requested to be accessed or corrected before processing such requests. To the extent permitted by applicable law, we may decline to process requests that we are unable to verify, are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning Information residing on archive servers). 

SECURITY OF YOUR INFORMATION 

We use commercially reasonable efforts to prevent unauthorized access, disclosure, or accidental loss or destruction of your Information. Access to your Information is strictly limited to our employees, representatives, and service providers who require access to carry out the purposes we describe in this privacy policy or that are otherwise permitted or required by law, and we take reasonable measures to ensure that your Information is not accessible to the public. We restrict access to users’ Information to only those persons who need access to perform or provide their job or service, both internally and with our third-party service providers. Where required by applicable law or we deem it appropriate,  Information is encrypted with advanced TLS (Transport Layer Security) when collected, stored, and/or transmitted. 

While we have endeavored to create a secure and reliable Website for users, we are not able to fully eliminate security risks associated with Information. Given the nature of the Internet, your Information passes through entities that we are unable to control. Therefore, we cannot guarantee that our security measures or those of third parties who access or transmit your Information will prevent your Information from being improperly accessed, stolen, or altered. When required by applicable law, we shall notify you and any applicable regulatory agencies of a breach of your Information.  

BIOMETRIC DATA   

Biometric Data is any information based on a biometric identifier used to identify an individual, including scans of facial geometry. As part of the Rewards claims process, we ask your consent to use Biometric Data to verify your identity by uploading an image of your government-issued identification document and a photographic image or brief live video (often called a “selfie”) from your mobile phone or other device. We use these images to create facial geometry recognition or a “faceprint,” which we use to verify your identity (“Identity Verification” or “Face Verification”). We collect and process your Biometric Data only for the following purposes:   

• To verify your identity when you submit a claim for a Reward; and   

• To prevent fraudulent uses of our Website or the creation of multiple accounts.  

We will never sell, rent, or trade your Biometric Data. Biometric Data is decentralized and hosted securely. We implement security measures such as encryption, firewalls, and intrusion detection and prevention systems. We permanently delete and destroy your Biometric Data six (6) months after submission. You may also request that your Biometric Data be deleted any time after it has been submitted for Identity Verification.  

You may refuse to consent to the collection and processing of your Biometric Data. If you choose not to consent, we will provide you with alternate options for verifying your identity. 

QUESTIONS, SUGGESTIONS, OR TO CONTACT US 

If you have any questions, comments, complaints, or suggestions regarding this Policy or our Website(s), please contact us here.