AU POINTS AND AWARDS CONSULTING SERVICES, LLC PRIVACY POLICY

Welcome to aupacs.com, offered by Au Points and Awards Consulting Services Au Points and Awards Consulting Services”, “us” or “we”). This Privacy Policy addresses how information is collected, stored, and utilized through our website, aupacs.com (the “Website”). This Privacy Policy will also detail how you can access the information that we have and make changes or remove it. By accessing or using our services, you signify that you have read, understood and agree to our collection, storage, use and disclosure of your information, as applicable, as described in this Privacy Policy, the Website’s Terms and Conditions and Terms of Use.

This Privacy Policy is issued based upon our good faith efforts to protect your privacy and in conformity with California Business and Professions Code and The EU General Data Protection Regulation (“GDPR”). Au Points and Awards Consulting Services respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect and process your personal information when you visit our websites aupacs.com. It also applies to personal information you may provide through our websites when you sign up to our newsletters, or purchase our products and services.

If you’re under the age of 16, please don’t give us your personal information unless you’ve first asked your parents or legal guardian, and they’ve allowed you to provide us your personal information. For EU and California residents, special considerations may apply as set forth below.

Au Points and Awards Consulting Services reserves the right to change this Privacy Policy. See the section entitled “Changes to this Privacy Policy” below.

Topics:

• What data do we collect?
• How do we collect your data?
• How will we use your data?
• How will we share your data?
• How do we store your data?
• Marketing
• What are your data protection rights?
• Privacy policies of other websites
• Protecting the Privacy of Children
• California Privacy Rights
• European Union-GDPR
• “Do Not Track” signals
• Changes to this Privacy Policy
• How to contact us

What data do we collect?

We collect the following Personally Identifiable Information (“PII”) data:

• Personal Identification Information including name, email address, phone number, date of birth, location, physical address and billing information.
• Profile Information includes your username, password, password hints and other information for authentication and account access, purchases or orders made by you, your interests, preferences, content of the messages you send us including feedback, reviews and survey responses.
• Technical Information includes URL information, internet protocol (IP) address, your login information, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our websites.
• Payment Information, including your payment instrument (such as a credit card number) and associated security code in order to process your payments if you make a purchase.
• Transaction Information includes details about payments to and from you and other details of products and services you have purchased from us.
• Usage Information includes information about how you use our websites, products and services.
• Marketing and Communications Information includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect Aggregated and De-Identified Information includes information derived from the above-mentioned categories that does not directly or indirectly reveal your identity.

How do we collect your data?

You directly provide us with most of the data we collect. We collect data and process data when you:

• Access this Website.
• Enter a competition, promotion or survey.
• Register online or place an order for any of our products or services.
• Voluntarily complete a customer survey or provide feedback on any of our message boards or via email.
• Subscribe to our service or publications.
• Use or view our Website via your browser’s cookies.

We may also receive your data indirectly from the following sources:

• social networks when you reference our products or services;
• partners or affiliates with which we offer co-branded services, sell or distribute our products or services, or engage in joint marketing activities;
• publicly-available sources such as data in the public domain.

How will we use your data?

We collect your data so that we can:

• process your order and manage your account;
• collect any outstanding balance on your account;
• enforce our rights and/or ensure your compliance with our Terms and Conditions and/or Terms of Use;
• disclose your PII as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our site;
• email you with special offers on other products and services we think you might like.
• collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for our Website and to understand more about the demographics of our users. In gathering this information, we are able to enhance your experience when visiting our Website (including keeping your preferences and items placed in your shopping cart between visits) and to provide custom, personalized content and information, including targeted content and advertising.

How will we share your data?

From time to time, we can share your data with the following third-parties:

• our partner companies so that they may offer you their products and services, if you agree;
• third-party vendors, service providers, contractors and agents in connection with the performance of services on our behalf, as needed to carry out their work for us, which may include identifying and serving advertisements, providing mailing services, providing financial services, web hosting, or providing analytic services. These service providers are prohibited from using your information except as needed to perform our work or as required by law, although we may permit them to use aggregate information which does not identify you or de-identified data for scientific research purposes;
• other companies and brands owned or controlled by Au Points and Awards Consulting Services and other companies owned by or under common ownership as Au Points and Awards Consulting Services, which also includes our subsidiaries (i.e., any organization we own or control);
• our business partners and affiliates in connection with offering you co-branded services, selling or distributing our products, or engaging in joint marketing activities. For example, we may share information about you with a retailer for purposes of providing you with relevant product support or in connection with a warranty;
• when Au Points and Awards Consulting Services processes your order, it may send your data to, and also use the resulting information from, credit reference agencies to prevent fraudulent purchases.

How do we store your data?

We take precautions to protect your information. When you submit sensitive information via the Website, your information is protected both online and offline according to generally accepted industry standards.

Wherever we collect sensitive information (such as credit card data), that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a lock icon in the address bar and looking for “https” at the beginning of the address of the Web page.

While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to PII data. The computers/servers in which we store PII data are kept in a secure environment.

No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

If you have any questions about security on our Website, you may contact us at  [email protected].

Marketing

We would like to send you information about products and services of ours that we think you might like, as well as those of our partner companies for example with our business partners and affiliates in connection with offering you co-branded services, selling or distributing our products and services, or engaging in joint marketing activities.

If you have agreed to receive marketing, you can always opt out at a later date. You have the right at any time to stop us from contacting you for marketing purposes or giving your data to other members of the Au Points and Awards Consulting Services group.

If you no longer wish to be contacted for marketing purposes, you can tell us you are withdrawing your consent by:

• Unsubscribing (just click on the ‘unsubscribe’ link in any message we send you and follow the instructions – please note that it might take a short period of time to process your unsubscribe request) or
• Sending an email to [email protected], with ‘Unsubscribe’ or “Opt-Out” as the subject of the email.

What are your data protection rights?

Au Points and Awards Consulting Services would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access – You have the right to request us for copies of your personal data. We may charge you a small fee for this service.

The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request us to complete the information you believe is incomplete.

The right to erasure – You have the right to request that we erase your personal data, under certain conditions.

The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.

The right to object to processing – You have the right to object to us processing your personal data, under certain conditions.

The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

The right to opt-out at any time where we are relying on consent to process your personal information. If you withdraw your consent, we may not be able to provide certain products or services to you. We’ll advise you if this is the case at the time you withdraw your consent.

Lodge a complaint with the relevant regulator if you feel that your personal information hasn’t been handled correctly, or you’re not happy with the way we’ve responded to anything you’ve asked us to do with your personal information. For EU citizens, HERE’S a list of EU data protection authorities with their contact details.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: [email protected]

Privacy policies of other websites

This Website contains links to other websites that are not owned or controlled by us. Our privacy policy applies only to our Website, so if you click on a link to another website, please review their privacy policies carefully to understand how they process your data.

Protecting the Privacy of Children

Persons under 18 years old are not the target audience for our Website.

California Privacy Rights

If you are a California customer, you have the right to receive, once per year, free of charge, 1) the identity of any third party company to which we have disclosed your personal information as defined by California’s “Shine the Light” law for that company’s own direct marketing purpose; and 2) a description of the categories of personal information disclosed.  To request this information, please contact us at [email protected] or the mail address set forth in the section entitled “Contact Us” below. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are not required to respond to requests made by means other than through the provided email or mail address.

European Union-GDPR

Additional provisions apply to PII collected by Au Points and Awards Consulting from European Union residents. You may access, update, delete or request we cease the use of your PII for marketing purposes by contacting us at [email protected]. On receiving the above-identified categories of request, exceptions may apply for data maintained:

• Pursuant to any legal or contractual obligation;
• In relation to resolving, defending or enforcing our rights;
• For accurate business and financial reporting.

Any questions concerning our GDPR policies may be directed to: [email protected]. Requests must include “GDPR Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and post code.

“Do Not Track” signals

Please note that we currently do not have or participate in any “Do Not Track” frameworks that would allow us to respond to any “Do Not Track” signals in the HTTP header on your browser or mobile application settings.

Changes to our privacy policy

Our Company keeps its privacy policy under regular review and places any updates on this web page. This Privacy Policy was last updated on March 13, 2020.

How to contact us

If you have any questions about Au Points and Awards Consulting Services’s Privacy Policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

Email us at: [email protected]

Information for California Consumers: Your California Privacy Rights

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Effective Date: March 18, 2020

This California Privacy Notice complements the information provided in our Privacy Policy and applies solely to all visitors and users who reside in the State of California (“consumers,” “your” or “you”). “We,” “us,” “our,” and AuPACS” refers to Au Points and Awards Consulting Services, LLC. We adopt this notice in good faith to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms used in this notice have the same meaning as defined in the CCPA.

INFORMATION WE COLLECT

The aupacs.com website (the “Site”) collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device (“Personal Information”). Personal Information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
• 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;
• information collected as part of a clinical trial subject to the Federal Policy for the Protection of Human Subjects (also known as the Common rule) pursuant to good clinical practice guidelines issued by the International Council for Harmonisation or pursuant to human subject protection requirements of the U.S. Food and Drug Administration;
• personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, the Site has collected the following categories of Personal Information from its consumers within the last 12 months:

1. Identifiers. This category includes a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). This category includes a name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

1. Protected classification characteristics under California or federal law. This category includes age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
2. Commercial information. This category includes records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
3. Internet or other similar network activity. This category includes browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
4. Geolocation data. This category includes physical location or movements.
5. Inferences drawn from other personal information. This category includes profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

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

• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from observing your activities on our Site.

USE OF PERSONAL INFORMATION

We may use or disclose the Personal Information we collect for one or more of the following business purposes:

• To fulfill or meet the reason you provided the information.
• To provide, support, personalize, and develop our Site, products, and services.
• To create, protect, maintain and customize your account with us.
• To process your requests, purchases, transactions and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Site experience and provide you with relevant information.
• For research, testing, analysis, and product development, including to build and improve our Site, products, and services.
• To comply with applicable law, court order, or statutory regulations and to respond to law enforcement requests.
• As described to you when collecting your Personal Information or as otherwise set forth in the CCPA. Also, if you submit feedback about your experience with our products and services, we may post that story on our Site or social media accounts, without identifying you by name or address.

SHARING AND DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE

We may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep Personal Information confidential and not use it for any purpose except performing the contract.

We share your Personal Information with the following categories of third parties:

• Subsidiaries and affiliates.
• Contractors and service providers.
• Third parties with whom we partner to offer products, services and promotions to you.

In the preceding 12 months, we have disclosed the following categories of Personal Information for a business purpose to the parties identified above:

1. Identifiers. This category includes a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). This category includes a name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

1. Protected classification characteristics under California or federal law. This category includes age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
2. Commercial information. This category includes records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
3. Internet or other similar network activity. This category includes browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
4. Geolocation data. This category includes physical location or movements.
5. Inferences drawn from other personal information. This category includes profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

SALES OF PERSONAL INFORMATION

In the preceding 12 months, we have not sold Personal Information.

YOUR RIGHTS AND CHOICES

This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the preceding 12 months. Once we receive and confirm your verifiable consumer request, we will disclose the following to you:

• The categories of Personal Information we have collected about you.
• The categories of sources for the Personal Information we have collected about you.
• Our business or commercial purpose for collecting or selling that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• The specific pieces of Personal Information we collected about you (also called a data portability request).

If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:

• sales, identifying the Personal Information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we collect from you and saved, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the Personal Information, provide as good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Comply with a legal obligation.
• Exercise of free speech to ensure the right of another consumer to exercise their free speech rights, or exercise other rights under the law.
• Comply with the California Electronic Communications Privacy Act
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

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

By email: [email protected]

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice for free within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days and respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

PERSONAL INFORMATION SALES OPT-OUT AND OPT-IN RIGHTS

If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information at any time (the “right to opt-out”). We do not sell the Personal Information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer who is between 13 and 16 years of age. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time.

NON-DISCRIMINATION

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by law, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives allowed by the CCPA that can result in different prices, rates, or quality levels. Any such financial incentive will contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

OTHER CALIFORNIA PRIVACY RIGHTS- ‘SHINE THE LIGHT’ LAW

As a California customer, you also have the right to receive, once per year, free of charge, 1) the identity of any third party company to which we have disclosed your Personal Information as defined by California’s “Shine the Light” law for that company’s own direct marketing purpose; and 2) a description of the categories of Personal Information disclosed.

To request information under CCPA or Shine the Light law, please contact us at [email protected], the phone number or the mail address set forth in the section entitled “Contact Us” below. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are not required to respond to requests made by means other than through the provided email, phone number or mail address.

CHANGES TO OUR PRIVACY POLICY

The effective date of this notice is March 18, 2020. AuPACS reserves the right to amend this privacy notice at any time. When we make changes to this privacy notice, we will post the updated notice on the Site and update the notice’s effective date.

CONTACT INFORMATION

If you have any questions or comments about this notice, or wish to exercise your rights under California law, please contact us at:

Email: [email protected]