Partner Privacy Policy
Last Updated: March 11, 2024
NextGen Shopping, LLC, a System1 OpCo, LLC company (collectively, “we”, “us”, or “our”), respects your privacy.
This privacy policy (“Privacy Policy”) describes the type of information we collect from you and/or that you may provide to us when you use our browser extension (“Services”) or when you make inquiries or otherwise communicate with us in connection with the Services.
By accessing the Services, you acknowledge this Privacy Policy. If there is anything you do not understand, please email any inquiry to privacy@couponfollow.com.
If you are an EEA or UK user and you are using our browser extension as an embedded feature of a browser offered by one of our partners, please refer to the section below titled “Our role and contact information” for information about how to exercise your rights.
We reserve the right to change or update this Privacy Policy. Updates to this Privacy Policy will be posted at this URL and will be effective when posted. You can tell if this Privacy Policy has changed by checking the last updated date that appears at the top of this Privacy Policy.
This Privacy Policy covers the following topics:
● Information We Collect
● How We Use the Information We Collect
● Sharing Information with Third Parties
● Your Security
● Children’s Privacy
● How to Request Data Deletion
● Disclosure for Legal Purposes
● Your State Privacy Rights and Additional Disclosures
● Notice to California Residents
● Information for UK and EEA Users
● Retention of Information
1. INFORMATION WE COLLECT
We collect information through automated means when you use our Services such as:
Information you provide to us directly:
● Information you submit to us when you fill in a form or query field (where made available via our Services or website).
● Information contained in any messages, emails or other correspondence you have with us in the event that you contact us (including your contact details and the content of such communications)
Information we collect automatically through our Service:
Our browser extension operates via the use of an API (application programming interface); this API automatically provides us with information about the web page you are browsing which allows us to identify the relevant retailer and automatically apply available discount codes to your shopping cart. In order to ensure the functionality of our Service, we may also use Chrome storage, including Local Storage (where you have downloaded our browser extension on Chrome), to improve performance and speed and limit the amount of information that leaves the device and Chrome Sync Storage to ensure a consistent experience across a user’s devices including with respect to upgrades and diagnostics (when the user is utilizing Chrome); please see below for more information on our use of these technologies.
In order for the Service to work, we access, store or otherwise process the following information:
● the IP address of the device you use to connect to the internet (which may include information about your geographic location) (IP Address)
● the unique identifiers of your device (Device ID)
● your browser characteristics (such as browser name and browser version) (Browser Data)
● your operating system and device characteristics (such as Windows and the version) (Operating System)
● the website URLs on which you use our Services (URLs)
● actions taken or coupon codes entered when using our Services (e.g., if you use a coupon) (Actions)
● dates and times you use our Services (Date and Time)
● the merchants you have visited or from which you have purchased products using our Services on supported websites (Merchant Information)
● basic information about your shopping cart (cart amount subtotal, cart amount total, discount value, and promo code details) on supported websites required to run our Services (Basic Shopping Information)
In addition to API access, we may use the following technologies for automated data collection purposes to support the Services:
● Chrome Storage. A service provided by Google Chrome browser that allows extensions to store and access data within the user’s browser. It offers two main storage areas: (i) Local Storage (this data does not sync across the user’s devices) and (ii) Sync Storage (this data is synced using the user’s Google Account). The purpose of this storage is to ensure Service functionality, including to increase loading speeds and limit the amount of information that would otherwise need to leave the device, as well as to ensure a consistent experience across a user’s devices including with respect to upgrades and diagnostics (when the user is utilizing Chrome).
Note regarding the automatic data collection and storage: Depending on your location, it may be permissible for your web browser to automatically accept our use of technologies for data access and storage. In such cases, if you do not wish to allow our access or storage of data for the purpose described in this Privacy Policy, you may be able to set your browser to refuse them. Please review the specific instructions from your browser in order to do this. In other jurisdictions (including the United Kingdom and the European Economic Area) it may be required that we seek your permission prior to deployment of the services, including for the automatic access and storage of data. Our Services may be unavailable or difficult to view or use if we are unable to deploy these technologies.
Third-party use of cookies and other tracking technologies:
We may read existing cookie values and other tracking technologies that are set by supported merchants or other third-party websites, such as, for example, session ID, or cart ID, to attach them to the process of applying coupons to your cart. We do not control these third parties’ tracking technologies or how they may be used, during your session or over time. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
Commissions:
We track coupon codes from online merchants to help consumers save money. We may earn a commission when you use one of our coupons/links to make a purchase. You should check any coupon or promo code of interest on the merchant website to ensure validity before making a purchase.
2. HOW WE USE THE INFORMATION WE COLLECT
We process your information only for the purposes described in this Privacy Policy (or such other purposes which are compatible with the purposes described in this Privacy Policy). We have providing information below about the purpose for which we process your personal information and, for those users located in the UK or the EEA, we have also set out the legal basis upon which we rely for these processing activities.
| Purpose | Information Collected | Legal basis (for UK and EEA users) |
| Delivering the Service – identifying discount codes applicable to your shopping cart, automatically applying discount codes so that you get lower prices, reviewing changes to your shopping cart to ensure that discounts have been effectively applied, understanding and identifying information about your device, browser, system so that we can technically deliver discounts to you. | IP Address Device ID Browser Data Operating System URLs Actions Date and Time Merchant Information Basic Shopping Information | Consent – our Service only works where you have agreed to enable it. |
| Improving the Service – using information about the use of our Service to measure the effectiveness of discount codes, determine merchant popularity and the performance of our user interface in order to identify ways to improve. | IP Address Device ID URLs Actions Date and Time Merchant Information Basic Shopping Information | Legitimate interests – our legitimate interest in improving our services in order to encourage user uptake and increase our commissions; your legitimate interests in receiving the best version of our service. |
| Detecting and preventing fraud - for example, detecting abuse of the services by fraudulent users and taking steps to prevent damage that could be caused by such abuse. | IP Address Device ID Browser Data Operating System Date and Time | Legitimate interests – our legitimate interest in ensuring our Services are not abused by fraudulent users; the legitimate interests of merchants in reducing fraud on their sites, which may impact the success of their operations. |
| For reporting purposes - ensuring that appropriate commissions are paid to us and our partners | IP Address Device ID Date and Time Merchant Information Basic Shopping Information | Legitimate interests – our legitimate interests in pursuing our commercial objectives (generating commissions and ensuring continued success and availability of the Coupons business); your legitimate interests in the continuation of our business which provides access to discounts. |
| Resolving errors or bugs – where we identify a flaw, error or bug that limits the use or functionality of our service, resolving, patching or otherwise fixing the issue. | IP Address Device ID Browser Data Operating System URLs Actions Date and Time Merchant Information Basic Shopping Information | Legitimate interests – our legitimate interest in maintaining our Service in full working order; your legitimate interest in receiving the Service error and bug free. |
| For legal reasons - to enforce legal rights, comply with applicable laws, for fraud and crime prevention, to defend or undertake legal proceedings, or comply with court orders or similar obligations or otherwise in response to a legal, regulatory or judicial request. | IP Address Device ID Browser Data Operating System URLs Actions Date and Time Merchant Information Basic Shopping Information Information you provide to us directly | Depending on the circumstances: - to comply with our legal and regulatory obligations; - in other cases, for our legitimate interests (our interests in protected our business, interests and rights) |
| Business strategy - analysing statistics related to your use of our Services to inform our business planning and the design and selection of future features. | IP Address Device ID Browser Data Operating System URLs Actions Date and Time Merchant Information Basic Shopping Information Information you provide to us directly | Legitimate interests – our interest in improving our Services and the effectiveness of our business strategy. |
| Customer and user communications – responding to your questions and requests | Information you provide to us directly | Legitimate interests – our interest in promoting our business, establishing or further business relationships, providing good user or customer services and complying with legal obligations to respond to certain requests. |
3. SHARING INFORMATION WITH THIRD PARTIES
We are committed to maintaining your trust, and we want you to understand when and with whom we may share information collected about you. We do not share your information with any third parties except as set forth herein.
Service providers: We may disclose your information to outside individuals and/or companies that help us bring you the products and services we offer and to create, operate, and maintain our Services. Please find more information set out in the table below:
| Type of Service Provider | Services Provided | Information Shared |
| Data management | Data storage and hosting, management and maintenance of databases, data analysis. | All data types |
| Application hosting | APIs hosting, Configuration, Monitoring, Diagnostics Backups | All data types |
| Content delivery | Fast and reliable content delivery to users across the globe | All data types |
| Fraud prevention and security services | Detection of fraudulent behaviours, recommending actions to deal with fraud, blocking fraudulent activities, encryption, threat detection, vulnerability scanning, and secure data transmission | All data types |
| Customer support | Customer services, troubleshooting, responding to queries, business administration. | All data types |
| Professional services | Legal, accountancy, tax, consulting | All data types |
| Conversion Tracking | Track purchases made and commissions earned from merchants supported in the Service | IP Address Browser Data Operating System Date and Time Merchant Information |
We require that these outside companies agree to keep all information shared with them confidential and to use the information only to perform their obligations to us and in compliance with applicable law.
Buyers of some or part of our business: If we seek investors or go through a business transition, including but not limited to, a merger, acquisition by another company, or a sale of all or a portion of our assets, your information may be shared as part of the negotiation of the transaction and will likely be among the assets transferred in the event of a sale or partial sale of our assets.
In legal proceedings: We may disclose your information when legally required to do so, to cooperate with law enforcement investigations or other legal proceedings, to protect against misuse or unauthorized use of the Services, to limit our legal liability and protect our rights or to protect the rights, property or safety of users of the Services or the public.
4. YOUR SECURITY
We strive to keep your information private and safe. We take physical, electronic and administrative steps to maintain the security of information collected. We limit access to your information to those who have a genuine business need to access and are subject to a duty of confidentiality. We also have procedures to deal with any suspected or confirmed data security breach. We will notify you and any applicable regulator of a data security breach when and where we are legally required to do so.
Please be advised that, despite our best efforts, the transmission of data over the internet cannot be guaranteed to be 100% secure.
5. CHILDREN’S PRIVACY
We do not knowingly collect, use or disclose information from anyone under 16 years of age. If we determine upon collection that a user is under this age, we will not use or maintain his/her information. If we become aware that we have unknowingly collected personally identifiable information from a child under the age of 16, we will make reasonable efforts to delete such information from our records.
6. HOW TO REQUEST DATA DELETION
If for any reason you wish to delete all your data associated with our Services, you may do so at any time using the method below:
Send a data deletion request to privacy@couponfollow.com with the subject line “DELETE COUPONS DATA” to request to have your data deleted.
Once we verify your identity (which may require you to provide us with your unique user ID, per our instructions), all user data will be deleted from our active records, but essential data may be retained in our archives for fraud prevention and detection purposes.
7. DISCLOSURE FOR LEGAL PURPOSES
You hereby authorize us to disclose any of your information pursuant to judicial and administrative proceedings and to law enforcement or government agencies if we are legally required to do so. You also authorize us to disclose information if we believe the disclosure is necessary or appropriate in the event of an investigation of improper or illegal conduct in connection with the Services, such as fraud, misrepresentation, intellectual property infringement, or other activity that may put us at risk for liability.
8. YOUR US STATE PRIVACY RIGHTS AND ADDITIONAL DISCLOSURES
Depending on the state in which you reside, you may have certain privacy rights regarding your information. If you are a California resident, please see our “Notice to California Residents” section below. For other state residents, your privacy rights may include (if applicable):
● The right to confirm whether or not we are processing your personal information and to access such personal information;
● The right to obtain a copy of your personal information that we collected from and/or about you in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another controller without hindrance, where the processing is carried out by automated means;
● The right to delete personal information that we collected from and/or about you, subject to certain exceptions;
● The right to correct inaccurate personal information that we maintain about you, subject to certain exceptions;
● The right, if applicable, to opt out of the processing of your personal information for purposes of (1) targeted advertising; (2) the “sale” of your personal information (as that term is defined by applicable law); and (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
● If we are required by applicable law to obtain your consent to process sensitive personal information, the right to withdraw your consent; and
● The right not to receive discriminatory treatment by us for the exercise of your privacy rights.
We do not sell personal information or engage in targeted advertising. We do not use personal information for profiling in furtherance of decisions that produce legal or similarly significant effects concerning individuals.
To exercise your rights, please submit a request by email at privacy@couponfollow.com. If legally required, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the individual on whose behalf you are making such request. To do so, we will ask you to verify data points based on information we have in our records. If you are submitting a request on behalf of another individual, please use the same contact methods described above. If we refuse to take action regarding your request, you may appeal our decision by emailing us at privacy@couponfollow.com.
9. NOTICE TO CALIFORNIA RESIDENTS
The California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”), requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, sale, sharing, and retention of personal information and of the rights of California residents regarding their personal information. This section of the Privacy Policy is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this section does not apply to you and you should not rely on it.
The CCPA defines “personal information” to 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 California resident or household. Personal information does not include publicly available, deidentified or aggregated information or lawfully obtained, truthful information that is a matter of public concern. For purposes of this “Notice to California Residents” section we will refer to this information as “Personal Information.”
Notice at Collection of Personal Information
We currently collect and, in the twelve (12) months prior to the last updated date of this Privacy Policy, have collected the following categories of Personal Information:
● Identifiers (online identifier, Internet Protocol address)
● Unique personal identifiers (device identifier)
● Commercial information (records of products or services purchased)
● Internet or other electronic network activity information (information regarding consumer’s interaction with website or application)
● Geolocation data
We collect Personal Information directly from California residents and from internet service providers, data analytics providers, and operating systems and platforms. We do not collect all categories of Personal Information from each source.
We currently collect and have collected the above categories of Personal Information for the following business or commercial purposes:
● Performing services, including providing customer service
● Undertaking internal research for technological development and demonstration
● Undertaking activities to verify or maintain the quality or safety of a service that is owned by us, and to improve, upgrade, or enhance the service
● Advancing our commercial or economic interests
We have not sold or shared Personal Information in the twelve (12) months preceding the Last Updated date of this Privacy Policy. We did not disclose Personal Information for a business or commercial purpose in the twelve (12) months preceding the Last Updated date of this Privacy Policy.
We do not knowingly collect, sell or share the Personal Information of consumers under 16 years of age. We do not collect or process sensitive Personal Information for the purpose of inferring characteristics about individuals and, consequently, do not collect sensitive Personal Information or use it for purposes other than those allowed by the CCPA and its regulations.
Your Rights
If you are a California resident, you have the following rights with respect to your Personal Information:
● The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purpose for collecting, selling or sharing Personal Information (if applicable), the categories of third parties to whom we disclose Personal Information (if applicable), and the specific pieces of Personal Information we collected about you;
● The right to delete Personal Information that we collected from you, subject to certain exceptions;
● The right to correct inaccurate Personal Information that we maintain about you;
● If we sell or share Personal Information, the right to opt out of the sale or sharing;
● If we use or disclose sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure; and
● The right not to receive discriminatory treatment by us for the exercise of privacy rights the CCPA confers.
How to Submit a Request to Know, Delete, and/or Correct
You may submit a request to know, delete, and/or correct by emailing us at privacy@couponfollow.com.
If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, we will require additional information to verify your authority to act on behalf of the California resident.
Our Process for Verifying a Request to Know, Delete, and/or Correct
We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable. To do so, we will ask you to verify data points based on information we have in our records concerning you.
Shine the Light Law
If you are a California resident, California Civil Code § 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes (as those terms are defined in that statute). We do not make such disclosures and therefore do not have obligations under the Shine the Light Law.
10. INFORMATION FOR UK AND EEA USERS
Your rights
If you are located in the European Economic Area (EEA) or the United Kingdom (UK), you may have the following rights with respect to the personal information we process about you. Please note that these rights are not necessarily absolute (and certain qualifications may apply). If you have questions related to these rights and their applicability to you, you may contact us.
| Right | Information |
| Access | The right to be provided with information about the personal information we process about you and to receive a copy of your personal information. |
| Rectification | The right to require us to correct any inaccuracies in your personal information, as applicable. |
| Erasure (also known as the right to be forgotten) | The right to require that we delete your personal information, in certain situations, where certain grounds for deletion apply (including, for example, where we relied on your consent to process the personal information and you have withdrawn that consent and we have no other legal grounds on which to process the personal information). |
| Restriction of processing | The right to require us to restrict or limit the processing of your personal information in certain circumstances, for example where you contest the accuracy of the data |
| Data portability | The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or have that personal information transmitted to a third party (in certain circumstances, where technically feasible) |
| To object | The right to object: at any time to your personal information being processed for direct marketing (including profiling); in certain other situations to our continued processing of personal information, e.g., processing carried out for the purpose of our legitimate interests, unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims. |
| Not to be subject to automated individual decision making | The right not to be subject to automated decision making, that gives rise to a legal effect that has a significant impact upon you. |
| The right to withdraw consents | Where we have relied on your consent as the basis for processing your personal information, you may have a right to withdraw that consent at any time. You may withdraw consents by contacting us at: privacy@couponfollow.com Withdrawing a consent will not affect the lawfulness of our use of your personal information in reliance on that consent at any time before it was withdrawn. |
| The right to complain | You may submit a complaint about our processing of your personal information to us at any time; you also have the right to take your complaint to a data protection supervisory authority. |
If you would like to exercise any of the rights set forth above, please email us at privacy@couponfollow.com and let us know what right you want to exercise.
International transfers
Our Services are hosted primarily in the U.S. If you are accessing our Services from outside of the U.S., please be aware that personal information collected through our Services may be transferred to, stored in or otherwise processed in the U.S. (or such other jurisdictions where we have engaged a third party to provide services). The laws of such jurisdictions may be different from those of your country of residence, and in some cases, may not be as protective.
In the event that we transfer your personal information, we take steps to ensure your personal information is safeguarded in compliance with applicable data protection laws. In connection with personal information originating in the UK or the EEA, such safeguards may include our execution of the Standard Contractual Clauses and, where applicable, the UK International Data Transfer Addendum, with the recipient of such personal information. If you require more information about our international data transfers and the applicable safeguards, please contact us at privacy@couponfollow.com.
Our role and contact information
In some instances, the CouponFollow browser extension may be integrated into a browser offered by one of our partners. When our Services are offered to you in this way, we are processing your personal information under our partners’ instruction and on their behalf. In this capacity, we act as a data processor and our partner is the relevant data controller. In order to exercise your rights, you should contact the data controller (browser partner). Please refer to the privacy policy associated with the browser for information about the browser partner’s collection and use of your personal information and how to exercise your rights. We will provide assistance and cooperation to the browser partner, in line with applicable law, in connection with your request.
Alternatively, if we process your personal information for our own purposes as further described in this policy (for example, in connection with any customer or user communication or where you have downloaded our Services directly), we are the data controller.
You can contact us at any time at privacy@couponfollow.com.
Details for our representatives in the EEA and UK are set out below:
In the UK
VeraSafe has been appointed as our representative in the United Kingdom for data protection matters, pursuant to Article 27 of the United Kingdom General Data Protection Regulation. If you are located within the United Kingdom, VeraSafe can be contacted in addition to or instead of privacy@couponfollow.com, only on matters related to the processing of personal data.
To make such an inquiry, please contact VeraSafe using this contact form: https://verasafe.com/public-resources/contact-data-protection-representative or via telephone at: +44 (20) 4532 2003.
Alternatively, VeraSafe can be contacted at:
VeraSafe United Kingdom Ltd.
37 Albert Embankment
London SE1 7TL
United Kingdom
In the EU
VeraSafe has been appointed as our representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. If you are in the European Economic Area, VeraSafe can be contacted in addition to privacy@couponfollow.com, only on matters related to the processing of personal data.
To make such an inquiry, please contact VeraSafe using this contact form: https://verasafe.com/public-resources/contact-data-protection-representative or via telephone at: +420 228 881 031.
Alternatively, VeraSafe can be contacted at:
VeraSafe Ireland Ltd.
Unit 3D North Point House
North Point Business Park
New Mallow Road
Cork T23AT2P
Ireland
11. RETENTION OF INFORMATION
We retain your information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us.