Our Privacy Policy

Welcome to GivCounts® LLC. (“GivCounts®”, “we”, “us” and/or “our”). This
privacy policy (“Privacy Policy”) has been created to provide information about
our company and our mobile applications (together with the Site (as defined
below), the “Services”) to our users (“you”, “your”). The Services are provided
by GivCounts®, LLC (“GivCounts®” or “we” or “us” or “our”) located at 13210
Lone Creek Ln Pearland, TX 77584, ATTENTION: Legal Department,
email privacy@GivCounts.com. This Privacy Policy sets forth GivCounts®’s
policy with respect to information including personally identifiable data
(“Personal Data”) and other information that is collected from visitors to our
website located at GivCounts.com (the “Site”) and users of the Services.

Information we collect

When you interact with us through the Services, we may collect Personal Data
and other information from you, as further described below:
1. Collection of Information
We collect, process and use your information when you:

  • Register for our Services or sign in to an existing account
  • Visit our website(s)
  • Access our application(s)
  • Connect to our Services using third-party accounts, such as your email, social media or payment account(s)
  • Contact us for support
  • Participate in our shopping or influencer programs
  • Enter a sweepstakes, contest, promotion, survey or poll

Further, we and our service providers automatically collect certain information
about you through:

  • Interaction with our Services
  • Cookies and other tracking technologies
  • Location-identifying technologies
  • Monitoring and analyzing trends, usage and activities

The types of information you provide may include personal information.
“Personal information” means information that can be used to identify you
(whether alone or in combination). The personal information you may provide
to us includes:

  • First and last name
  • Email address
  • Mailing, billing and/or shipping address
  • Phone number
  • Payment information (such as payment account name, payment account number, payment card expiration date and billing address)
  • The product or service requested or purchased
  • How you connect to our Services, such as your IP address, unique device identifiers, device or session IDs and information regarding the network and connected hardware (e.g., computer or mobile device)
  • Browsing, shopping and purchase history
  • Your geolocation
  • Click-stream data (the page-by-page paths you take as you browse through our Services)

By signing into the Service through a third party social networking service
(“Social Networking Service”), such as Facebook or Google, you give us
permission to access, store and use any information that you permit the Social
Networking Service to share with us in accordance with the privacy settings
applicable to your account with that Social Networking Service. If you elect to
use Google to create or sign in to your Service account, your Google account
will be automatically linked to your Service account, and we will receive
access to your Google email content (“Gmail Data”). You can change these
settings in accordance with Section 4 (Your Choices). The Gmail Data and
any other information we collect in connection with Social Networking
Services is subject to this Privacy Policy, except where otherwise noted.

2. Use of Information We Collect
We may use information about you in the following ways.
Manage Your Account
If you provide us personal information, we may use it to: (i) process your
registration with our Services, including verifying whether your email address
is active and valid and enrolling you into our programs; (ii) facilitate and
manage your purchase transactions; (iii) track your shopping, deliver you
rewards or payments and identify opportunities for rewards and/or offers; (iv)
send you technical notices, updates, security alerts and administrative
messages; (v) provide you member services regarding your account and reply
to your questions, comments and requests; and (vi) comply with legal and
regulatory provisions in force and with the competent judicial authorities in
each geographical jurisdiction that the Company operates in. We may also
use your information to assess risk and prevent fraud.

Improve Our Services
We may process information through analyzing and monitoring usages and
trends and performing statistical analyses to improve our Services and the
websites, applications, marketing efforts and the products and services of our
affiliates to provide a better service to you in the future. We may also use this information to adapt Service content to be more likely to be of interest to you.
With the exception of Gmail Data, we may also share information with our
affiliates within the Rakuten Group for those affiliates to analyze and monitor
usage and trends to improve their services and websites.

Provide You Marketing Information
With the exception of Gmail Data, Company may use information to provide
you more personalized offers and/or special offers, discounts and similar
information. Company may send you newsletters, rewards, discounts,
promotion codes, events and general information about the service if you
consent. To match your profile and interest, we may use your information to
create a profile of your preferences and provide you content and features. We
may use your information (excluding Gmail Data) to provide you
Administer Contests, Sweepstakes and Promotions
From time to time, Company may invite you to enter various contests,
sweepstakes, surveys or promotions. If you choose to participate in a contest
or promotion, your personal information may be used to administer the
contest, such as to determine your eligibility for the contest or to award a
3. Sharing of Information
We may share the information we collect, including your personal information,
under the following circumstances.
Service Providers and Business Partners
We do not sell your Personal Information and only share it with third party
service providers (which may include Company affiliates) to operate our
Services. We may share your Personal Information with our service providers
that provide member support, process payments, and perform other business
operations on our behalf, under our instructions and in compliance with
appropriate technical and organizational security measures to protect your
data. For example, we may partner with other companies to provide you
support services, authentication services, prevent fraud on our Services,
administer our promotions, referral programs, sweepstakes, and surveys,
perform analytics, maintain the accuracy of our databases, facilitate your
travel reservations, fulfill your product purchases, and administer your rewards
or payments. Further, we may share your information (excluding Gmail Data)
with our financial institution partner, Chase Bank, for the purposes of providing
rewards or benefits to you and marketing our co-branded credit cards to you.
We will not sell your Personal Information, Gmail Data, or your payment
information, but we may rent, sell, and share other information that cannot be
used to identify you with merchant partners, third parties, or affiliates.

Personal Data That You Provide Through the Services: We collect
Personal Data from you when you voluntarily provide such information, such
as when you register for access to the Services (for example email address,
first name, and last name), use certain Services, contact us with inquiries, or
respond to one of our surveys. Wherever GivCounts® collects Personal Data,
we make an effort to provide a link to this Privacy Policy.
By voluntarily providing us with Personal Data, you are consenting to
our use of it in accordance with this Privacy Policy. If you provide
Personal Data to us, you acknowledge and agree that such Personal
Data may be transferred from your current location to the offices and
servers of GivCounts® and the authorized third parties referred to herein
located in the United States.
Non-Identifiable or Aggregated Data:
When you interact with GivCounts®
through the Services, we receive and store certain personally non-identifiable
data. Such information, which is collected passively using various
technologies, cannot presently be used to specifically identify you.
GivCounts® may store such information itself or such information may be
included in databases owned and maintained by GivCounts® affiliates, agents
or service providers. The Services may use such information and pool it with
other information to track, for example, the total number of visitors to our
Services, the number of visitors to each page of our Site or game of our apps,
the domain names of our visitors’ Internet service providers, and how our
users use and interact with the GivCounts® Services.
Also, in an ongoing effort to better understand and serve the users of the
Services, GivCounts® often conducts research on its customer demographics,
interests and behavior based on the Personal Data and other information
provided to us. This research may be compiled and analyzed on an aggregate
basis. GivCounts® 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. GivCounts® 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
In operating the Services, we may also use a technology called "cookies." A
cookie is a piece of information that the computer that hosts our Services
gives to your browser when you access the Services. Our cookies help
provide additional functionality to the Services and help us analyze Services
usage more accurately. For instance, our Services may set a cookie on your
browser or device that allows you to access the Services without needing to
remember and then enter a password more than once during a visit to the

Services. In all cases in which we use cookies, we will not collect Personal
Data 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 Services features.

Our Use of Your Personal Data and Other Information

GivCounts® uses the Personal Data you provide in a manner that is
consistent with this Privacy Policy. If you provide Personal Data for a certain
reason, we may use the Personal Data in connection with the reason for
which it was provided. For instance, if you contact us by email, we will use the
Personal Data you provide to answer your question or resolve your problem.
Also, if you provide Personal Data in order to obtain access to the Services,
we will use your Personal Data to provide you with access to such services
and to monitor your use of such services. GivCounts® and its subsidiaries and
affiliates (the “Related Companies”) may also use your Personal Data and
other personally non-identifiable data collected through the Services to help
us customize the Services or the messages you receive, improve the content
and functionality of the Services, to better understand our users and to
improve the Services. GivCounts® and its Related Companies may use this
information to communicate with you regarding the Services or to tell you
about services we believe will be of interest to you. If we do so, any marketing
communication we send you will contain instructions permitting you to "opt-
out" of receiving future marketing communications. In addition, if at any time
you wish not to receive any future marketing communications, or you wish to
have your name deleted from our mailing lists, please contact us as indicated
below. Note however that as user of the Service you cannot opt-out of some
administrative communications that are reasonably necessary to the Service,
such as billing or service notifications.

If GivCounts® intends on using any Personal Data 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 Data is collected.

Our Disclosure of Your Personal Data and Other Information

GivCounts® is not in the business of selling your information. We consider this
information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain
third parties without further notice to you, as set forth below:
Business Transfers: As we develop our business, we might sell or buy
businesses or assets. In the event of a corporate sale, merger, reorganization,
dissolution or similar event, Personal Data may be part of the transferred
Related Companies: We may also share your Personal Data with our
Related Companies for purposes consistent with this Privacy Policy.
Agents, Consultants and Related Third Parties: GivCounts®, like many
businesses, sometimes hires other companies to perform certain business-
related functions. Examples of such functions include mailing information,
maintaining databases and processing payments. 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.
Legal Requirements: GivCounts® may disclose your Personal Data 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, (ii) protect and defend the
rights or property of GivCounts®, (iii) act in urgent circumstances to protect
the personal safety of users of the Services or the public, or (iv) protect
against legal liability.

Your Choices

You can use the Site without providing any Personal Data. Some of our
mobile apps, for example those directed toward children under the age of 13,
also do not require the provision of Personal Data. The remainder of our
mobile apps, however, require users to provide Personal Data, specifically
email address, in order to access the entirety of that app’s functionality. You
may request that we delete your account, and any information associated with
your account, but please note that we may be required (by law or otherwise)
to retain certain information and not delete it (or to keep this information for a
certain time, in which case we will comply with your deletion request only after
we have fulfilled such requirements). When we delete your information, it will
be deleted from the active database but may remain in our archives.


For information specific to privacy of the Personal Data of children under 13
years of age, please read the “Children’s Privacy Policy” below.
Links to Other Web Sites: This Privacy Policy applies only to the Services.
The Services may contain links to other websites not operated or controlled by
GivCounts® (the “Third Party Sites”). The policies and procedures we
described here do not apply to the Third Party Sites. The links from the Services do not imply that GivCounts® endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their
privacy policies.

Integrating Third Party Services within the Services

One of the special features of the Service is that it allows you to enable
various online third party services, such as social media and networking
services, (“Third Party Services”) to be directly integrated into your
GivCounts® experience. To take advantage of this feature, we will ask you to
provide us your username and password for the relevant Third Party Services.
By enabling such Third Party Services, you are allowing us to pass your log-in
information to these service providers for this purpose. When you add a Third
Party Service account to the Service, we will collect your login information and
other relevant information necessary to enable the Service to access that
Third Party Service and your data contained within that Third Party Service.
However, please remember that the manner in which Third Party Services
use, store and disclose your information is governed solely by the policies of
such third parties, and GivCounts® shall have no liability or responsibility for
the privacy practices or other actions of any Third Party Service that may be
enabled within the Service.
Security: GivCounts® takes reasonable steps to protect the Personal Data
provided via the Services from loss, misuse, and unauthorized access,
disclosure, alteration, or destruction. However, no Internet, email 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.
Other Terms and Conditions: Your access to and use of the Services is
subject to the Terms of Service.
Changes to GivCounts®’s Privacy Policy: The Services and our business
may change from time to time. As a result, at times it may be necessary for
GivCounts® to make changes to this Privacy Policy. GivCounts® reserves the
right to update or modify this Privacy Policy at any time and from time to time
without prior notice. Please review this policy periodically, and especially
before you provide any Personal Data. This Privacy Policy was last updated
on the date indicated above. Your continued use of the Services after any
changes or revisions to this Privacy Policy shall indicate your agreement with
the terms of such revised Privacy Policy.
Access to Information; Contacting GivCounts®: To keep your Personal Data
accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession
that you have previously submitted via the Services.

Please also feel free to contact us if you have any questions about
GivCounts®’s Privacy Policy or the information practices of GivCounts®.
You may contact us as follows: privacy@GivCounts.com