Privacy Notice


U.S. Privacy Notice

Effective Date: January 1, 2020

This Privacy Notice explains how we collect, use, disclose, and otherwise process personal information in connection with our services. This Privacy Notice is not, however, a contract and does not create any legal rights or obligations.


Who We Are: cxLoyalty creates compelling customer engagement solutions for clients and manages end-to-end engagement and membership programs that may be available to you. When we use the terms “cxLoyalty”, “we”, “us”, or “our” in this Privacy Notice, we are referring to cxLoyalty Group, Inc. and its subsidiaries.

Our Services: When we use the term “services”, we are referring to our U.S.-facing Internet websites and our U.S.-facing end-to-end engagement and membership programs we offer and manage on our own behalf, including:

This Privacy Notice does not cover or address:

We make FCRA-related disclosures available on certain service-specific websites, and we separately provide GLB notices containing GLB and state-specific financial privacy law disclosures by mail or email in connection with GLB-covered services. If you would like to obtain another copy of a GLB notice previously provided, please contact us at privacy@cxloyalty.com.

For offerings provided on behalf of our clients, please refer to the privacy notice of the client with which you have a relationship for information on how they engage service providers, like us, to process personal information on their behalf.


State-Specific Disclosures

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain states. Please see below for disclosures that may be applicable to you:


What is Personal Information?

When we use the term “personal information” in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. It does not include aggregated or deidentified information that is maintained in a form that is not capable of being associated with or reasonably linked to you.


Our Collection and Use of Personal Information

The personal information we collect, the way we collect it and how we use it will depend on how you are interacting with us and the type of services you use.

Website & Online Services

Collection of Personal Information

As is true of most digital platforms, we and our third-party providers collect certain personal information automatically when you visit or interact with our websites and other online services:

Although we often collect the personal information described above directly from you, we also collect this information through service providers and other third parties that collect it on our behalf, such as communications providers, analytics providers, website hosting providers and marketing providers. Please note that our systems may record personal information that you type into our websites and other online services even if you do not choose to submit it.

Use of Personal Information

We use the personal information we collect through our websites and other online services to:

Please note that we link the personal information we collect through our websites and online services with the other personal information that we collect about you and may use it for the purposes we describe in more detail in the other sections of this Privacy Notice.

Surveys, Contest and Promotion Entries

Collection of Personal Information

From time to time we may provide you the opportunity to participate in surveys, contests and/or promotions. If you choose to participate, we will request personal information from you in connection with your entry, which typically includes:

Although we often collect the personal information described above directly from you, we also collect this information through service providers and other third parties that collect it on our behalf, such as communications providers, analytics providers, survey, contest and promotion entry providers and marketing providers.

Use of Personal Information

We use the personal information we collect in connection with surveys, contests and promotions to:

Unless noted otherwise in our initial request, we may link the personal information we collect through your contest, promotion and survey responses with the other personal information that we collect about you and for the purposes we describe in the other sections of this Privacy Notice. The survey, contest, or promotion request you receive may contain additional details about how any personal information you provide may be used or otherwise processed.

Service Enrollment and Account Management

Collection of Personal Information

When you enroll in our services or create/maintain an account with us, we collect certain personal information from you, which may include:

Although we often collect the personal information described above directly from you, we may also collect certain information through our business partners when you enroll through a partner that you already have a relationship with. In addition, we may also collect this information through service providers and other third parties that collect it on our behalf, such as communications providers, payment processors, payment system providers, and information technology providers.

Note about Biometric Information: Some of our mobile applications require you to log in to access your account. We may provide you the ability to log in using facial, fingerprint or other biometric recognition technology available through your mobile device. If you choose to utilize these login features, information about your facial geometry, your fingerprint or other biometric information will be collected by your mobile device for authentication purposes. We do not store or have access to this biometric information. Instead, your mobile device will perform the biometric authentication process and only let us know whether the authentication was successful. If the authentication was successful, you will be able to access the applicable mobile application without separately providing your account credentials.

Use of Personal Information

We use the personal information we collect in connection with your enrollment and/or account to:

Please note that we link the personal information we collect in connection with your enrollment and/or account with the other personal information that we collect about you and may use it for the purposes we describe in more detail in the other sections of this Privacy Notice.

Retail and Entertainment Services

Scope of Retail and Entertainment Services

Our retail and entertainment services include (but are not limited to):

Collection of Personal Information

When you use and interact with our retail and entertainment services, we collect personal information from you, our merchants, product/service vendors, payment processors, service providers and other third parties who collect personal information on our behalf, which may include:

Use of Personal Information

We use the personal information we collect in connection with our retail and entertainment services to:

Please note that we link the personal information we collect in connection with your retail and entertainment services with the other personal information that we collect about you and may use it for the purposes we describe in more detail in the other sections of this Privacy Notice.

Travel Services

Scope of Travel Services

Our travel services include (but are not limited to):

Collection of Personal Information

When you use and interact with our travel services, we collect personal information from you, our travel booking providers, travel partners, payment processors, service providers and other third parties who collect personal information on our behalf, which may include:

Use of Personal Information

We use the personal information we collect in connection with our travel services to:

Please note that we link the personal information we collect in connection with your travel services with the other personal information that we collect about you and may use it for the purposes we describe in more detail in the other sections of this Privacy Notice.

Automotive Services

Scope of Automotive Services

Our automotive services include (but are not limited to):

Collection of Personal Information

When you use and interact with our automotive services, we collect personal information from you, our automotive service partners, payment processors, service providers and other third parties who collect personal information on our behalf, which may include:

Use of Personal Information

We use the personal information we collect in connection with our automotive services to:

Please note that we link the personal information we collect in connection with your automotive services with the other personal information that we collect about you and may use it for the purposes we describe in more detail in the other sections of this Privacy Notice.

Homeowner Services

Scope of Homeowner Services

Our homeowner services include (but are not limited to):

Collection of Personal Information

When you use and interact with our homeowner services, we collect personal information from you, our homeowner services partners, payment processors, service providers and other third parties who collect personal information on our behalf, which may include:

Use of Personal Information

We use the personal information we collect in connection with our homeowner services to:

Please note that we link the personal information we collect in connection with your homeowner services with the other personal information that we collect about you and may use it for the purposes we describe in more detail in the other sections of this Privacy Notice.

Credit & Identity Benefit Services

Scope of Credit & Identity Benefit Services

Our credit and identity benefit services include (but are not limited to):

Collection of Personal Information

When you use and interact with our credit and identity benefit services, we collect personal information from you, our credit and identity benefit providers, payment processors, service providers and other third parties who collect personal information on our behalf, which may include:

Use of Personal Information

We use the personal information we collect in connection with our credit and identity benefit services to:

Please note that we link the personal information we collect in connection with your credit and identity benefit services with the other personal information that we collect about you and may use it for the purposes we describe in more detail in the other sections of this Privacy Notice.

Other Collection of Personal Information

In addition to the personal information collected above, we may also collect your personal information as follows:

Other Uses of Personal Information

In addition to the uses identified above, we use the personal information we collect to:


Our Disclosure of Personal Information

We disclose personal information in the following ways:


Your Communication Preferences

In connection with our services, we may send you email messages, direct mail offers, SMS messages, push notifications or other communications, including telephone calls, regarding our services. You may ask us not to send you marketing communications or request a change to the method or frequency of communication by:

cxLoyalty
Data Privacy Office
6 High Ridge Park
Stamford, CT 06905
1-844-300-4222

Please allow up to 10 days for your request to be processed. If you request to opt out of marketing communications, please note that we may continue to send you non-marketing communications, such as those directly related to the fulfillment of a specific transaction you requested, maintenance of your account or status of our ongoing business relations.


Children’s Personal Information

Our websites and online services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If you are under the age of 13, please do not use our websites or online services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 13 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 13, we will promptly delete that personal information.

We do, however, process personal information about children, including their Social Security numbers, when it is necessary for the services we are offering and you provide it to us. This personal information is used to provide you the full benefit of the service you have chosen, such as the protection of your child’s bank card or identity, coverage for your child under insurance products or for travel services such as flights, hotels or cruises.


Third-Party Websites

Our websites and online services may include links to or redirect you to third-party websites, plug-ins and applications, including social media services where you may connect with us. Third-party websites may also reference or link to our websites and online services. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices or policies.


Updates to this Privacy Notice

We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the “Effective Date” at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify you by prominent posting at the beginning of this Privacy Notice.


Contact Us

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to privacy@cxloyalty.com.

Alternatively, inquiries may be addressed to:

cxLoyalty
Data Privacy Office
6 High Ridge Park
Stamford, CT 06905
1-844-300-4222

Additional California Privacy Disclosures

Effective Date: January 1, 2020

These Additional California Privacy Disclosures supplement the information contained in our Privacy Notice by providing additional information about how we collect, use, disclose, and otherwise process personal information of individual residents of the State of California within the scope of the California Consumer Privacy Act of 2018 (CCPA). Unless otherwise expressly stated, all terms defined in our Privacy Notice retain the same meaning in these Disclosures and all other terms defined in the CCPAand not otherwise defined in these Disclosures have the same meaning when used in these Disclosures.


Personal Information Disclosures

When we use the term “personal information” in these Disclosures, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include aggregated or deidentified information that is maintained in a form that is not capable of being associated with or linked to you.

Collection, Disclosure, and Sale of Personal Information

In the last 12 months, we have not sold personal information about you, but we have collected and disclosed for a business purpose the following categories and examples of specific pieces of personal information, which reference the personal information described in the Our Collection and Use of Personal Information section of our Privacy Notice:

Category of Personal Information Collected Disclosed for Business Purpose Sold*
Identifiers such as Account Identifiers, Credit andIdentity Information relating to data used to identifyyou, full name, IP address, and governmentidentification number (including Social Securitynumber, passport number and driver’s licensenumber)
California Customer Records (Cal. Civ. Code §1798.80(e)): including your Contact Information,Security/Authentication Information, Joint AccountHolder and Family Information, TravelerInformation, Automotive Information, Credit andIdentity Information relating to your account,Account History relating to your account, PaymentInformation, Shipping Information relating to youraccount, Rewards Information relating to youraccount, Referrals, approximate income level andsignature No Personal Information Sold
Protected Classification Characteristics , includingage, date of birth, gender, and sex
Commercial Information,including Account Historyrelating to your purchases, Transaction Information,Shipping Information relating to your purchases,Coverage Information, Flight Information, HotelInformation, Rental Car Information, CruiseInformation, Travel Activity Information, RewardsInformation relating to your purchases orredemption, Service Profile Information relating toyour purchases and interests, and FeedbackInformation
Biometric Information
Internet/Network Information, such as Log Data,Analytics Data and Application Data
Geolocation Data, including your generalgeographic location or more precise location whenpermitted by law (such as in connection with youruse of our LocateMe® Technology for ourautomotive services)
Sensory Information, including recordings of phonecalls between you and us, where permitted by law
Profession/Employment Information, including thebusiness or organization you represent, your titlewith that business or organization and informationrelating to your role with the business ororganization
Non-Public Education Information (20 U.S.C. §1232g, 34 C.F.R. Part 99)
Other Personal Information, includingCommunication Preferences, Customer Service andCommunication History, personal information youpermit us to see when interacting with us throughsocial media, and personal information you provideus in relation to a question, request, inquiry, survey,contest or promotion
Inferences, including our predictions about yourinterests and preferences and related ServiceProfile Information

*Note about “Sales”: We do not and will not “sell” personal information as most people think of that term. However, we do utilize third-party providers to engage in online analytics and advertising involving the collection of personal information, including Identifiers, Internet/Network Information, and Geolocation Data, directly from your browser or device through cookies or related technologies when you visit or interact with our online services or otherwise engage with us online. We use these third-party providers to analyze and optimize our online services, provide more relevant content and ads to users of our online services and other third parties, and perform other services related to analytics or advertising consistent with these Disclosures and our Privacy Notice. These third-party businesses may use the information they collect directly from you for their own purposes in accordance with their own privacy notices, which may include using this information for services provided to other third parties, including other parties operating in advertising networks.

To the extent that these practices qualify as “sales” under the CCPA, you may have the right to opt out as described in the Your Privacy Rights section below.

Sources of Personal Information

As described in the Our Collection and Use of Personal Information section of our Privacy Notice, we collect personal information directly from you when you provide it to us, automatically when you visit our websites and other online services, and from service providers and other third parties. For representatives of our clients, vendors, service providers and other third parties, we also collect personal information directly from you and from the entity you represent.

Purposes for Collecting Personal Information

We collect personal information about you for the purposes described in the Our Collection and Use of Personal Information section of our Privacy Notice. For representatives of our clients, vendors, service providers and other third parties, we also collect your personal information to maintain an ongoing relationship between us and the entity you represent and to contact you in connection with our relationship with the entity you represent.

Recipients of Personal Information

As described in the Our Collection and Use of Personal Information section of our Privacy Notice, we share personal information within cxLoyalty and with a variety of third parties. For representatives of our clients, vendors, service providers and other third parties, we also share your personal information with the entity you represent.


Your Privacy Rights

As a California resident, you may be able to exercise the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations at law):

Right to Know The right to request any or all of the following personal information we havecollected and disclosed about you in the last 12 months:
  • The specific pieces of personal information we have collected aboutyou;
  • The categories and specific pieces of personal information we havecollected about you;
  • The categories of sources of the personal information we havecollected about you;
  • The categories of personal information we have disclosed about you tothird parties for a business purpose, and the categories of recipients towhom this information was disclosed;
  • The categories of personal information we have sold about you (if any),and the categories of third parties to whom this information was sold; and
  • The business or commercial purposes for collecting or, if applicable,selling personal information.
Right to Deletion The right to request the deletion of personal information we have collectedfrom you, subject to certain exceptions.
Right to Opt Out The right to direct us not to sell personal information we have collectedabout you to third parties.
Right to Non-Discrimination The right to be free from discrimination for exercising any of the rightsdescribed above.

The right to non-discrimination does not prohibit us from offering youcertain financial incentives that may result in different prices, rates orquality levels of products or services. In addition, please note that if theexercise of the rights described above limits our ability to process personalinformation (such as in the case of a deletion request), we may not be ableto provide our products and services to individuals who exercise theserights, or to otherwise engage with such individuals going forward.

Submitting Requests

To Exercise Your Right to Know or Right to Deletion

To Exercise Your Right to Opt Out


Updates to These Disclosures

We will update these Disclosures from time to time. When we make changes to these Disclosures, we will change the “Effective Date” at the beginning of these Disclosures. If we make material changes to these Disclosures, we will notify you by prominent posting at the beginning of these Disclosures or our Privacy Notice


Contact Us

If you have any questions or requests in connection with these Disclosures or other privacy-related matters, please send an email to privacy@cxloyalty.com.

Alternatively, inquiries may be addressed to:

cxLoyalty
Data Privacy Office
6 High Ridge Park
Stamford, CT 06905
1-844-300-4222

Cookie Notice

Effective Date: January 1, 2020

Unless otherwise expressly stated, capitalized terms in this Cookie Notice have the same meaning as defined in our Privacy Notice.


Scope of Cookie Notice

This Cookie Notice supplements the information contained in our Privacy Notice by explaining how we and our business partners and service providers use cookies and related technologies in the course of managing and providing our online services and our communications with you. It explains what these technologies are and why we use them, as well as your rights to control our use of them.

In some cases, we may use cookies and related technologies described in this Cookie Notice to collect personal information, or to collect information that becomes personal information if we combine it with other information. For more details about how we process your personal information and state-specific disclosures relating to your personal information, please review our Privacy Notice.


What Are Cookies and Related Technologies?

Cookies are small data files that are stored on your computer that allow us and our third-party providers to collect certain information about your interactions with our email communications, websites and other online services. We and our third-party providers may also use other, related technologies to collect this information, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”).


What We Collect When Using Cookies

We and our third-party providers may use cookies to automatically collect certain types of usage information when you visit or interact with our email communications, websites and other online services, including the personal information identified in the Website and Online Services section of our Privacy Notice. For example, we may collect log data about your device and its software, such as your IP address, operating system, browser type, date/time of your visit, and other similar information. We may also collect analytics data or use third-party analytics tools such as Google Analytics to help us measure usage and activity trends for our online services and better understand our customer/member base.

Third-party providers may also directly collect personal information about your online activities over time and across different websites when you use our websites and online services.


How We Use that Information

We may use the data collected through cookies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit our websites and other online services; (b) provide and monitor the effectiveness of our websites and other online services; (c) monitor online usage and activities of our websites and other online services; (d) diagnose errors and problems with our websites and other online services; (e) otherwise plan for and enhance our websites and other online services; and (f) facilitate the other purposes identified in the Website and Online Services section of our Privacy Notice. We and our advertising partners also use the information we collect through cookies to understand your browsing activities, including across unaffiliated third-party sites, so that we can deliver information and advertisements about our services that may be of interest to you.

Please note that we link some of the personal information we collect through cookies with the other personal information that we collect about you and for the purposes described in the Our Collection and Use of Personal Information section of our Privacy Notice.


Your Choice About Cookies

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using our websites and other online services, as some features and offerings may not work properly. Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

Many of our websites use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). For more information on the use of Google Analytics, please visit Google’s privacy policy here. You can also view Google’s currently available opt-out options here.

PLEASE NOTE THAT DISABLING COOKIES WILL CAUSE YOU TO BE UNABLE TO EARN AND RECEIVE YOUR CASH-BACK REWARDS AND REWARDS POINTS AUTOMATICALLY BECAUSE WE WILL BE UNABLE TO DETERMINE IF A PURCHASE HAS BEEN MADE IN CONNECTION WITH YOUR ACCOUNT.


Your Choice About Online Ads

We support the self-regulatory principles for online advertising (Principles) published by the Digital Advertising Alliance (DAA). This means that we allow you to exercise choice regarding the collection of information about your online activities over time and across third-party websites for online interest-based advertising purposes. More information about these Principles can be found at www.aboutads.info. If you want to opt out of receiving online interest-based advertisements on your internet browser from advertisers and third parties that participate in the DAA program and perform advertising-related services for us and our advertising partners, please follow the instructions at www.aboutads.info/choices, or http://www.networkadvertising.org/choices/ to place an opt-out cookie on your device indicating that you do not want to receive interest-based advertisements. Opt-out cookies only work on the internet browser and device they are downloaded onto. If you want to opt out of interest-based advertisements across all your browsers and devices, you will need to opt out on each browser on each device you actively use. If you delete cookies on your device generally, you will need to opt out again.

If you want to opt out of receiving online interest-based advertisements on mobile apps, please follow the instructions at http://www.aboutads.info/appchoices.

Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us on our websites or online services. It means that the online ads that you do see from DAA program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.


Updates to This Cookie Notice

We will update this Cookie Notice from time to time. When we make changes to this Cookie Notice, we will change the “Effective Date” at the beginning of this Cookie Notice.


Contact Us

If you have any questions or requests in connection with this Cookie Notice or other privacy-related matters, please send an email to privacy@cxloyalty.com.

Alternatively, inquiries may be addressed to:

cxLoyalty
Data Privacy Office
6 High Ridge Park
Stamford, CT 06905
1-844-300-4222