Privacy Policy

WHOSE PRIVACY PRACTICES ARE DESCRIBED BY THIS PRIVACY POLICY?

This Privacy Policy describes the policies and practices of Inmar, Inc. and its U.S. wholly owned subsidiaries and affiliates Inmar – YouTech, LLC; BrightBridge, LLC; Inmar Clearing, Inc.; Inmar Brand Solutions, Inc.; Inmar Services, LLC; Inmar Analytics, Inc.; Inmar Supply Chain Solutions, LLC; Inmar Rx Solutions, Inc.; Digitus Solutions LLC; and Inmar Government Services, LLC (collectively and individually referred to as “we,” “our,” or “us”) regarding our collection of personal information directly from consumers and our use and disclosure of that information.

This Privacy Policy also addresses our practices where we receive personal information from businesses, government entities, and other entities to which we provide our services (“Business Customers”) or otherwise process personal information on behalf of our Business Customers in connection with services we provide to them. The manner in which we collect, use, and disclose personal information on behalf of our Business Customers is subject to our Business Customers’ directions, but will generally align with the descriptions provided below.

WHAT BUSINESS ACTIVITIES DOES THIS POLICY COVER?

This Privacy Policy addresses our different lines of business:

• Promotional Services. We assist businesses who are seeking to promote the sale of goods and services and the consumers for those goods and services by managing different promotional offerings such as marketing, rebates, coupons, and loyalty programs. We also operate websites and provide mobile applications that enable consumers to choose and redeem discount offers for goods and services that are of interest to them.
• Supply Chain Services. We assist businesses and consumers with supply chain needs related to reverse logistics including facilitating better management of consumer returns processing, managing product recalls, enabling the liquidation of returns or overstocked inventory, and conducting supply chain studies to generate data analytics that facilitate better supply chain management.
• Healthcare Services. We assist and support retailers, hospitals and pharmacies with financial management activities related to the provision of healthcare, such as by processing insurance payments for prescriptions and providing performance analytics.
• Government Services. We assist government entities that administer various consumer benefits programs, including but not limited to the Supplemental Nutrition Assistance Program (“SNAP”) and Temporary Assistance for Needy Families (“TANF”) programs by, among other things, processing electronic benefits transfer (“EBT”) payments and providing informational assistance to benefits recipients through an online cardholder portal and mobile application.

WHAT PERSONAL INFORMATION DOES INMAR COLLECT OR RECEIVE? 

We may collect personal information directly from consumers in a variety of ways, such as:

• When a consumer registers and/or creates an account with us, we may collect authentication and other information provided by the consumer as part of the registration, such as a username, password, and contact information such as name, email address, or phone number, and security questions and answers. 
• When we provide Government Services, we may collect additional authentication and other information provided by the consumer as part of the registration, such as EBT card number, PIN, case number, benefit access type, language preference, date of birth, and the last four digits of the consumer’s Social Security number.
• When a consumer interacts with or makes selections on our websites and applications, we may collect records of those interactions or selections. For example, if a consumer selects a digital coupon that is offered within an application or website, we may make a record of that selection so we will be able to inform retailers that the consumer is entitled to the benefit of the coupon.
• When a consumer submits redemption information to us as part of a rebate program, such as a receipt, or other information that is otherwise necessary for us to process the rebate.
• When a consumer otherwise submits information or communicates with us, such as through features like feedback forms or otherwise contacting us via telephone, email, fax, or postal mail.

We may also collect other personal information automatically when a consumer visits or uses our websites, applications, or other online services, including as described below:

• Browser and Device Information. Certain information may be automatically collected by most browsers or devices, such as information about consumer’s devices (such as IP addresses and MAC addresses), operating systems, and browsers. We may use this information to ensure that our websites and applications function properly. We may also collect advertising device identifiers, such as IDFA for iOS devices and AAID for Android devices.
• Information Stored in Cookies. Our websites may also use available web-based technologies to collect consumer data, such as cookies or web beacons. Cookies are pieces of information stored directly on users’ computers or devices. Cookies allow us to collect information such as browser type, time spent on the online services, pages visited, referring URL, and other traffic and usage data. We may also use cookies for purposes such as determining what features interest our users, revising our site features or operations, and as further described below. For more information, see the “What Options and Choices Do Consumers Have Regarding Personal Information?” section below. 
• Pixel Tags and Log Files. Our websites may also use other tracking systems such as log files and pixel tags. For example, pixel tags, sometimes called web beacons, are similar in function to a cookie and can tell us certain information like what content has been viewed.
• Information Collected in Connection with Analytics Technology: We may use various technologies to learn more about how visitors use our websites, applications, or other online services, such as Google Analytics. Google Analytics uses cookies to help us analyze how visitors use the Website. The information generated by the cookies about your use of the Website includes your IP address. If you so choose, you may be able to opt out by turning off cookies in the preferences settings in your browser. For more information on Google Analytics, including how Google Analytics collects, uses, and discloses information, refer to the following page: www.google.com/policies/privacy/partners/. We may also use other technologies to monitor your activities on our website. 
• IP Address: An IP address is a number that is automatically assigned to the computer that a consumer uses by their Internet Service Provider (“ISP”). An IP address may be identified and logged automatically in our server log files whenever a user accesses our websites, applications, or other online services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications, and other services. We may use IP addresses for purposes such as calculating usage levels, diagnosing server problems, and administering our websites, applications, and other online services.
• Location Information. We may receive consumers’ approximate location or data that indicates their approximate location, such as their IP address and locations where they redeem coupons or discounts. Such data assists us in improving our applications in future versions of our services, and also enables us to offer better services both to consumers and to our Business Customers.

We may also receive various types of personal information about consumers from our Business Customers as part of the services we provide, such as:

• When we manage a retailer’s customer loyalty program, we may obtain a consumer’s registration information, such as the consumer’s name, address, phone number and any unique ID associated with their registration. We may also receive records of consumers’ purchase histories, discounts, and other benefits to which the consumer is entitled.
• When we provide Supply Chain Services, we may receive personal information, such as consumer names, mailing addresses, and other contact information, in order to receive and manage returns for our Business Customers.
• When we provide Healthcare Services, we may receive consumers’ personal information, such as consumer names, insurance providers, insurance plans, prescription purchases, and prescription costs, in order to invoice insurance companies for prescription purchases at our pharmacy customers.
• When we provide Government Services, we may receive consumers’ personal information from government entities, such as consumer names, mailing addresses, phone numbers, languages, case numbers, EBT card numbers, benefit access type, dates of birth, and Social Security numbers.
• When our Business Customers otherwise provide or direct us to receive personal information.

Whenever we receive personal information from our Business Customers, like retailers, manufacturers, or government entities, we may use and disclose such personal information as authorized by those Business Customers. We are not responsible for the policies or practices of our Business Customers with respect to the personal information those Business Customers provide to us or otherwise collect from consumers.

We may combine the information we obtain from third parties with information that we or our affiliated organizations have collected about you.

This Privacy Policy does not apply to anonymized or aggregated data that does not allow us or third parties to identify or contact you.

FOR WHAT PURPOSES AND IN WHAT MANNER DO WE USE PERSONAL INFORMATION?

We may use personal information for purposes that include the following:

• Providing and operating our services, including for and on behalf of our Business Customers.
• Completing transactions and performing contractual obligations.
• For internal business operations, such as evaluating and improving the effectiveness of our operations, including our services, websites, applications, and marketing efforts, conducting research and analysis, developing new services, and performing other internal business operations, including as described elsewhere in this privacy policy.
• To update or modify our websites, applications, or other online services features or operation.
• For marketing purposes.
• To communicate with consumers, our Business Customers, and others.
• To create aggregate or deidentified data.
• Storing information about consumer preferences, recognizing consumers’ activities associated with our services, and customizing consumers’ user experiences.
• Determining consumers’ locations in order to provide location-based services to consumers or our Business Customers.
• To evaluate an actual or potential merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, including as part of bankruptcy, liquidation, or similar proceeding.
• To debug, identify, or repair errors or effectuate similar functional enhancements in connection with our websites, applications, or other services.
• To maintain the safety, security, and integrity of our websites, applications, other technology assets, and our business.
• To protect against malicious, deceptive, fraudulent, or illegal activity, and participating in any prosecution or enforcement of laws or agreements meant to prevent or punish such activity.
• Protecting the legal rights, property, safety, and security of our organizations, employees, customers and others.
• To comply with applicable law, other legal requirements, and industry standards. 
• To enforce our policies, terms of use, or rights arising from contracts.
• For such purposes as consumers may authorize at the time they submit the information.
• For any other purpose with consumer consent.

TO WHOM AND FOR WHAT PURPOSES DO WE DISCLOSE PERSONAL INFORMATION?

We may disclose personal information, including for the purposes described above:

• To our Business Customers and the contractors, service providers, and other third parties our Business Customers may use to support their operations. For example, if a consumer provides us their contact and purchase information to join a retailer loyalty program, we may disclose that contact and purchase information to the retailer for whom we manage that program.
• To our affiliate organizations. 
• To our contractors, service providers, and other third parties we use to support our organization. 
• To communicate with consumers, our Business Customers, and others.
• To comply with applicable law, other legal requirements, and industry standards. 
• To enforce our policies, terms of use, or rights arising from contracts.
• To investigate or prevent unlawful activities or misuse of our services. 
• To protect the legal rights, property, safety, and security of our organizations, employees, customers and others and to prevent fraud and other harm.
• To a buyer or other successor or organization in the event of an actual or potential merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, including as part of bankruptcy, liquidation, or similar proceeding.
• For such purposes as the consumer may authorize at the time they submit the information.  

THIRD-PARTY TREATMENT OF CONSUMER INFORMATION

Inmar’s mobile applications and websites may include links to applications, websites, information and services provided by third parties. Inmar is not responsible for the privacy practices of those third parties. We encourage consumers to review the applicable privacy policies of such third parties if they elect to follow the links provided.

This site is being monitored by one or more third-party monitoring software(s), and may capture information about your visit that will help us improve the quality of our service. You may opt-out from the data that https://smart-pixl.com is collecting on your visit through a universal consumer options page located at https://smart-pixl.com/Unsub/unsub.html

WHAT OPTIONS AND CHOICES DO CONSUMERS HAVE REGARDING PERSONAL INFORMATION? 

Consumers may choose not to provide the personal information we collect directly from them. However, not providing information we request may restrict consumers’ ability to use certain features of our services or our Business Customers’ services where we collect or receive personal information on behalf of our Business Customers. For example, consumers may be able to restrict the collection of personal information or functionality through their device’s operating system or by disabling cookies, but doing so may prevent them from using the functionality of the relevant website, application, or online service.

Some internet browsers have a “do not track” feature that lets users tell websites that they do not want to have their online activities tracked. At this time the websites, applications, and online services do not respond to “do not track” signals. We may allow third parties to use our websites, applications, and online services to collect personal information about consumers’ online activities over time and across different websites, applications, and other online products or services.

You may follow instructions contained in our marketing and promotional emails to opt out of future marketing and promotional emails. Please note that you may still receive promotional or marketing emails after opting out, but that marketing may not be tailored to you or your interests.

Your mobile device may also have settings that allow you to prevent sharing geolocation information with us. You should consult your mobile device’s settings or help documentation for more information about exercising these options. As described above, much of the personal information we process is received from or collected on behalf of our Business Customers, such as retailers and manufacturers. Where we are processing personal information received from or collected on behalf of our Business Customers, we may have no direct relationship with the individuals whose personal information we process under these circumstances. If we receive your personal information from one of our Business Customers or if we process your personal information on behalf of one of our Business Customers and you would like to make an inquiry, complaint, or otherwise exercise choices that Business Customer may provide, please contact the Business Customer that you interact with directly.

Additional Information for EBT Users: If you are a registered LifeInCheck EBT user, you may access, update and change certain information we have collected about you by accessing the “My Account” tab after signing into your account on www.LifeInCheckEBT.com. Please note that certain information may require you to make updates with our government customers directly. 

RETENTION OF INFORMATION

We may maintain personal information in our databases indefinitely. While we may remove personal information from the databases that we use in active operation of our business, some or all of that personal information may be retained in archival backups of those databases.

INFORMATION SECURITY

We maintain appropriate administrative, technical, and physical safeguards designed to protect personal information in our possession. We cannot guarantee the security of the information that we collect and store. If you believe that information about you has been compromised, please let us know by emailing privacy@inmar.com. 

PRIVACY POLICY CHANGES

Inmar reserves the right to update this Privacy Policy from time to time. We will make any such updates publicly available for review, and will indicate the date as of which the revised Privacy Policy becomes effective. As permitted under applicable law, by using our services after such notice, you consent to our updates to this policy as of the Effective Date listed below.

Additional Information for EBT Users: If we make material changes, we will notify you of the changes through email, on the website, or in the LifeInCheck EBT mobile app. 

INTERNATIONAL USERS

Our services are not targeted to individuals outside of North America. If you are located outside the United States, please be aware that information we collect may be transferred to, processed and stored by us or our service providers outside the country in which you are located, including in the United States, in accordance with this Privacy Policy and applicable laws.

ADDITIONAL INFORMATION FOR RESIDENTS OF CALIFORNIA

We provide this “Additional Information for Residents of California” section pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. This section applies only to the extent an Inmar Company directs the purposes and means of processing of California Personal Information (as defined below) and otherwise qualifies as a “business” as defined in the CCPA. This section is not applicable where we act as a “service provider” as defined in the CCPA, such as circumstances where we collect and process California Personal Information (as defined below) from or on behalf of our Business Customers as a service provider.

As used in this section, “California Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household except for:

• Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and the California Confidentiality of Medical Information Act (“CMIA”) or clinical trial data;
• Publicly available information from government records;
• Deidentified or aggregated consumer information; 
• Personal information, emergency contact information, and benefits administration information we collect about a California resident in the course of that California resident acting as our job applicant, our employee, our owner, our director, our officer, our medical staff member, or our contractor to the extent we use that information within the context of that California resident’s role as our job applicant, employee, owner, director, officer, medical staff member, or contractor; and
• Other information excluded from the CCPA’s scope, including:
  • personal information that we may collect, process, sell, or disclose pursuant to the federal Gramm-Leach-Bliley Act, and implementing regulations, or the California Financial Information Privacy Act (Division 1.4 (commencing with Section 4050) of the Financial Code); and
  • personal information covered by other sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”) and the Driver's Privacy Protection Act of 1994.

The table below describes the categories of California Personal Information we may have collected from consumers within the last twelve months:

We may obtain the categories of California Personal Information listed above from the following categories of sources:

• Directly from you. 
• Indirectly from you.
• From our Business Customers.

We may use or disclose the categories of California Personal Information described above that we collect for one or more of the business purposes and commercial purposes described in the “For What Purposes and In What Manner Do We Use and Disclose Personal Information” provided above.

Disclosures of California Personal Information for a Business Purpose

We may disclose the categories of California Personal Information described above that we collect to the categories of third parties described in the “To Whom and for What Purposes Do We Disclose Personal Information” section above. In the preceding twelve months, we may have disclosed categories of California Personal Information described above that we collect for a business purpose.

Sales of California Personal Information

In the preceding twelve months, we have not sold the categories of California Personal Information described above that we collected. We do not sell your California Personal Information.

The CCPA and other California privacy laws provide California residents with specific rights regarding California Personal Information. This section describes the rights California residents have and explains how California residents can exercise those rights.

Access to California Personal Information and Data Portability Rights

California residents may request that we disclose certain information about our collection, use, and disclosure of their California Personal Information over the past twelve months. If we receive and confirm a verifiable consumer request from a California resident pursuant to the Exercising CCPA Rights section below, we will disclose to that California resident one or all of the following depending on the scope of the request:

• The categories of personal information we collected about that California resident over the past twelve months.
• The categories of sources for the personal information we collected about that California resident over the past twelve months.
• Our business or commercial purpose for collecting that personal information over the past twelve months.
• The categories of third parties with whom we share that personal information over the past twelve months.
• The specific pieces of personal information we collected about that California resident over the past twelve months.
• The categories of personal information about that California resident that we disclosed for a business purpose, to the extent we have made such disclosures over the past twelve months. 

Deletion Request Rights

Subject to certain exceptions, California residents may request that we delete the California Personal Information we collected about them. If we receive and confirm a verifiable consumer request from a California resident pursuant to the Exercising CCPA Rights section below, we will delete and direct our service providers to delete that California resident’s California Personal Information, unless an exception applies.

Exercising CCPA Rights

To request that we exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either: 

• Calling us at 844-392-1073; or
• Submitting this webform.

If you have an account with us, we may deliver our written response to that account. If you do not have an account with us, we will deliver our written response through email. Any disclosures we provide will only cover the 12-month period preceding your verifiable request's receipt. For data portability requests, we will select an industry-acceptable format to provide your California Personal Information.

Unless a request is manifestly unfounded or excessive, we will not charge a fee to process or respond to your verifiable consumer request. If we determine that a request is manifestly unfounded or excessive, we will tell you why we made that decision and reserve the right to either refuse to act on your request or charge you a reasonable fee to complete your request.

In order to protect your California Personal Information, please note that:

• You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
• The request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected California Personal Information or an authorized agent. In order to verify your request, we may ask you to provide information such as your first and last name, email address, mailing address, phone number, or any other information necessary to verify your identity. 
• The description of the request must provide sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with California Personal Information if we cannot verify your identity or authority to make the request and confirm the California Personal Information relates to you You may designate an authorized agent to submit requests on your behalf through a valid power of attorney in certain circumstances or through signed written permission that authorizes the agent to act on your behalf. We may mandate additional requirements when requests are submitted through an authorized agent, such as, requiring the submission of signed written permission for the agent to act on your behalf, requiring you to verify your identity directly with us, and/or otherwise requiring you to confirm the authorized agent’s permission to act on your behalf directly. 

You are not required to create an account with us to make a verifiable request. We will only use California Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

As described above, where we are processing personal information received from or collected on behalf of our Business Customers, we may act as a “service provider” as defined in the CCPA and have no direct relationship with the individuals whose personal information we process under these circumstances. If we receive your personal information from or on behalf of one of our Business Customers or if we process your personal information on behalf of one of our Business Customers and you would like to make an inquiry or complaint, please contact the Business Customer that you interact with directly.

Non-Discrimination

Subject to certain exceptions, you have the right to not receive discriminatory treatment for exercising your access, data portability, and deletion rights described above.

Direct Marketing Disclosure Request Rights

California residents who have an established business relationship with us may request information regarding third parties, if any, to whom Inmar may have disclosed personal information (as defined by Cal. Civ. Code § 1798.83(e)(7)) for the direct marketing purposes of those third parties during the preceding calendar year.

All such requests should be submitted in writing to the Inmar Privacy Office at the postal address provided in the “Contacting Us” section below.

CONTACTING US 

If you have any questions or comments about this Privacy Policy or would like to exercise any applicable rights under this Privacy Policy, please contact Inmar’s Privacy Office at:

Inmar, Inc.
Attention: Privacy Office
635 Vine St.
Winston-Salem, NC 27101
privacy@inmar.com

Please include your name, contact information, and the nature of your request so that we can respond appropriately and promptly to your communication.

This Privacy Policy is effective as of and was last updated on: June 3, 2021.