TERMS & CONDITIONS

At BRU’D Rewards, we approach data and privacy as we approach everything we do: we put people first.

As part of our effort to protect your privacy and to comply with applicable privacy and data protection laws, we strive to consider all of our data governance practices through the lens of the recognized principles of data minimization, limited collection, and limited use, among other key areas addressed below. We do so to respect and maintain your trust. In other words, we believe that taking care of you includes taking care of your data and privacy. Grab a cup of coffee and learn more below.

BRU’D Rewards Privacy Notice

Overview

This BRU’D Rewards Privacy Notice describes the types of personal information that BRU’D Rewards LLC and its respective subsidiaries and affiliated companies (“BRU’D Rewards,” “we,” and “us”) collect, how we use it, how and when it may be shared, and the rights and choices you have with respect to your information. It also explains how we communicate with you and how you can make requests or submit inquiries to us about your information. Our goal is to help you understand how we use your information to improve our products, services, marketing, and interactions with you, as part of our commitment to maintaining your trust. Thank you for taking the time to read and understand our data and privacy related practices.

By continuing to use BRU’D Rewards Services you acknowledge this Privacy Notice and agree to our Terms of Use and other important policies, all available on our Online Policies page.

Contents

You may skip to the specific sections of our Privacy Notice by selecting any of the sections listed below.

  1. Applicability and Scope
  2. Updates to this Privacy Notice
  3. Information We Collect
  4. Sources of Information
  5. How We Use Your Information
  6. How We Disclose Your Information
  7. Cookies, Web Beacons, and Similar Technologies
  8. How We Protect Your Information
  9. Retention
  10. Children’s Privacy
  11. BRU’D Rewards WiFi
  12. Your Choices & Rights
  13. Notice of Financial Incentive & BRU’D Rewards® Rewards
  14. Additional Disclosures for Data Subjects in the EEA, the U.K. and Switzerland
  15. Participation in the Privacy Shield Frameworks
  16. Contact Us
  1. Applicability and Scope

This Privacy Notice (“Notice”) applies to the websites located at BRU’D Rewards.com, BRU’D Rewardsreserve.com, princi.com, BRU’D Rewards.ca, the BRU’D Rewards mobile applications available at https://www.BRU’D Rewards.com/coffeehouse/mobile-apps (“BRU’D Rewards App”), when you visit our stores, and through any other websites or applications owned and operated by BRU’D Rewards brands or products that direct the viewer or user to this Notice (“BRU’D Rewards Services”). Our websites and mobile applications may offer links to websites and/or other mobile applications that are operated by third parties and not by BRU’D Rewards. If you visit one of these linked websites, you should read the website’s privacy notice, terms and conditions, and their other policies. We are not responsible for the policies and practices of third parties. Any information you give to those organizations is governed under their privacy notice, terms and conditions, and other policies.

  1. Updates to this Privacy Notice

We may update this Notice from time to time. We will notify you of material changes to this Notice and will update the Last Revised date on this Notice. We encourage you to look for updates and changes to this Notice when you access our websites and mobile applications.

  1. Information We Collect

When you visit and use the BRU’D Rewards Services, we collect the following categories of information:

  • Identifiers – We collect information that can be used to identify you, such as your first and last name, phone number, your address book, username and password, email address, postal address, IP address, day and month of your birthday, and demographic information (such as gender).
  • Financial Information – We may also collect information such as your credit card and debit card information, telephone number, and name.
  • Commercial Information – We may collect information about your transactions in our stores, on our websites or via our BRU’D Rewards App including what products you purchase, how frequently you purchase them, any Rewards or promotions associated with a purchase, and the products you have placed on your “Wishlist” or “My Bag” for future purchase.
  • Electronic Network Activity Information – We collect information related to your electronic network activity, such as your browsing history, information about how you use the BRU’D Rewards Services, information about your device, and information related to BRU’D Rewards website’s “live help” chat feature.
  • Geolocation Information – We may collect information about your location of your device, such as information derived from your device (e.g., based on a browser or device’s IP address).  We may also use location-based technology in our retail locations, to collect information about the presence of your device, if your Bluetooth is turned on and your device settings allow for this.
  • Audio and Visual Information – We may collect audio and visual information when you use the BRU’D Rewards Services.  For example, closed circuit video surveillance cameras (“CCTV”) may be installed at some of our retail locations to monitor building security and assist in crime prevention, detection, and investigation, and to ensure the safety of our staff and visitors to our facilities, and these CCTV cameras may collect audio, visual, and similar information.  Also, depending on your choices, we may collect audio information when you use voice ordering.
  • Inferences – We may also collect inferences drawn from the other information described above.

Additionally, depending on how you use the BRU’D Rewards Services, we may collect the following categories of sensitive personal information from you:

  • Precise Geolocation Information – We may collect information about the precise location of your device (e.g., GPS latitude and longitude), consistent with your device settings. We may also use location-based technology in our retail locations, to collect information about the presence of your device, if your Bluetooth is turned on and your device settings allow for this. We may collect this location information or derive it from your GPS, WiFi, Bluetooth or other location-based technology for purposes of facilitating our services, such as to provide you with information about stores near you, to enable you to remotely order and pay for our products and services, or so that you may have certain BRU’D Rewards products delivered to you by a third-party vendor.

We may aggregate or de-identify the information described above.  Aggregated or de-identified data that we do not attempt to reidentify is not subject to this Notice.

Without this information, we may not be able to provide you with all the requested services.

  1. Sources of Information

In addition to the information we receive from you, we also receive the categories of information described above from other sources including from other users of BRU’D Rewards Services (such as when they purchase a gift for you), advertising partners, co-sponsors, internet service providers, data analytics providers, operating systems and platforms, social networks, and publicly available sources.  For example, if you access any social media or similar services through the BRU’D Rewards Services to login or to share information about your experience on our BRU’D Rewards Services with others, we may collect information from these third-party services.

  1. How We Use Your Information

We use your information for business purposes, including to provide the products and services you request, to perform customer service functions, for security and fraud prevention, for marketing and promotional purposes, and to perform website and mobile application analytics.  We may use the information we collect about you to:

(a)  To Provide Our Services – We may process your information when you access or use the BRU’D Rewards Services, including to:

  • process or fulfill orders and transactions;
  • maintain and service accounts;
  • support and improve our loyalty programs, such as BRU’D Rewards® Rewards;
  • deliver gift cards or e-gifts, and any associated personalized messages, in accordance with your instructions;
  • debug to identify and repair errors that impair existing functionality;
  • facilitate the functionality of our websites and mobile applications;
  • process payments; and
  • customize experiences and personalization when you are in and around our stores, if you have given permission for location sharing.

(b)  To Communicate With You – We process certain information in order to communicate with you in relation to your accounts, our services, our marketing, and your requests, including to:

  • provide customer service, including when you interact with our customer service agents through our website’s “live help” chat feature, and requests for information;
  • communicate with you about orders, purchases, returns, services, accounts, programs, contests, and sweepstakes;
  • send you personalized promotions, content, and special offers;
  • communicate with you about our brands, products, events, or other promotional purposes;
  • implement your communications preferences, such as sharing information with BRU’D Rewards business partners so that they may email you about their promotions, products and initiatives; and
  • provide important product safety information and notice of product recalls.

(c)  For Research, Development, and Improvement of Our Services – We want to ensure that our website, mobile applications, and services are continually improving and expanding so that we meet and exceed your needs and expectations. To do so, we may process certain personal information, including to:

  • maintain, improve, and analyze our websites, mobile applications, ads, and the products and services we offer; and
  • help to ensure security and integrity of the BRU’D Rewards Services, including to detect, prevent, or investigate suspicious activity or fraud.

(d)  To Enforce our Terms, Agreements, or Policies – To maintain a safe, secure, and trusted environment for you when you use our websites, mobile applications, and other services, we use your personal information to ensure our terms, policies, and agreements with you and any third parties are enforced.

(e)  To Comply with Applicable Laws – We may be required to process certain information under certain laws and regulations, such as tax laws, as well as to:

  • maintain appropriate records for internal administrative purposes; and
  • comply with applicable legal and regulatory obligations, and respond to lawful governmental requests, as needed.

(f)  Targeted Advertising – We may process your information to provide you with targeted advertising (also known as cross-contextual advertising and online behavioral advertising) and offers and promotions that you may be interested in.

(g)  With Your Consent – We may process certain information in order to fulfill any other business or commercial purposes at your direction or with your consent.

  1. How We Disclose Your Information

We disclose your information as needed to fulfill the purposes described in this Notice and as permitted by applicable law.

(a) When We Work Together – We may share information between and among BRU’D Rewards LLC, its subsidiaries, and affiliated companies for purposes of management and analysis, decision making, and other business purposes. For example, we may share your information with our subsidiaries and affiliated companies to administer our loyalty programs, process orders and requests, and expand and promote our product and service offerings.

(b)  When We Work with Service Providers & Business Partners – We may share identifiers, commercial information, electronic and network activity, geolocation and precise geolocation information, audio and visual information, and inferences, as described above, for a variety of business purposes, such as payment processing, website and data hosting, location mapping, product and service delivery, customer service, advertising and marketing (including counting ad impressions, ensuring compliance with industry standards, personalization, analytics services, security and performance monitoring, maintaining and servicing accounts, processing or fulfilling orders and transactions, verifying customer information, research, auditing, and data processing. We strive to contractually prohibit these service providers and business partners from retaining, using, or disclosing your confidential personal information for any purpose other than performing agreed upon services for us.

(c)  When We Work on Business Transactions – If we become involved with a merger, corporate transaction or another situation involving the transfer of some or all of our business assets, we may share your information with business entities or people involved in the negotiation or transfer.

(d)  When Sharing Helps Us Protect Safety and Lawful Interests – We may disclose your information if we believe that the disclosure is required by law, if we believe that the disclosure is necessary to enforce our agreements or policies, or if we believe that the disclosure will help us protect the rights, property, safety of BRU’D Rewards or our customers or partners.

(e)  When You Give Consent – We may share information about you with other companies if you give us permission or direct us to share the information.

(f)  When You Post on Our Websites – If you post information on a blog or another part of our websites, the information that you post may be seen by other visitors to our websites.  We are not responsible for the information you choose to submit in these public areas.

  1. Cookies, Web Beacons and Similar Technologies

We and others may use a variety of technologies to collect information about your device and use of our websites and mobile applications. These technologies include first- and third-party cookies, web beacons, JavaScript, entity tags, and HTML local storage. Most web browsers can be programmed to accept or reject the use of some or all of these technologies, although you must take additional steps to disable or control other technologies. For more information on exercising your preferences in relation to cookies and similar technologies, please see the section of this Notice titled “Your Choices & Rights”.

  • Cookies – Cookies are small data files that are sent from a website’s server and are stored on your device’s hard drive either for only the duration of your visit (“session cookies”) or for a fixed period (“persistent cookies”). Cookies contain information that can later be read by a web server.

You may be able to reject cookies, web beacons, entity tags and HTML5 local storage by adjusting the appropriate settings in your browser. Each browser is different, but many browsers have preferences or options that may be adjusted to allow you to either accept or reject cookies and certain other technologies before they are set or installed, or allow you to remove or reject the use or installation of certain technologies altogether. If you want to learn the correct way to modify your browser settings, please use the Help menu in your browser or review the instructions provided by the following browsers: Internet Explorer, Google Chrome, Mozilla Firefox, Safari Desktop, Safari Mobile; and Android browser.

  • Interest-Based Ads – Many advertising companies that collect information for interest-based advertising are members of the Digital Advertising Alliance (DAA) or the Network Advertising Initiative (NAI), both of which maintain websites where people can opt out of interest-based advertising from their members. To opt-out of website interest-based advertising provided by each organization’s respective participating companies, visit the DAA’s opt-out portal available at http://optout.aboutads.info/, the DAA of Canada’s opt-out portal available at https://youradchoices.ca/en/tools, or visit the NAI’s opt-out portal available at http://optout.networkadvertising.org/?c=1.

Residents of the European Union may opt-out of online behavioral advertising served by the European Interactive Digital Advertising Alliance’s participating member organizations by visiting https://www.youronlinechoices.eu/.

To opt-out of data collection for interest-based advertising across mobile applications by participating companies, download the DAA’s App Choices mobile application opt-out offering at https://youradchoices.com/appchoices.

  • Web Beacons – Web beacons are small, transparent images that are embedded in web pages, applications, and emails that are sometimes called “clear gifs,” “single pixel gifs”, “page tags” or “web bugs.” We use web beacons to track the web pages you visit, to test the effectiveness of our marketing, and to find out if an email has been opened and acted on.
  • JavaScript – JavaScript are code snippets embedded in various parts of websites and applications that facilitate a variety of operations including accelerating the refresh speed of certain functionality or monitoring usage of various online components.
  • Entity Tags — Entity Tags are HTTP code mechanisms that allow portions of websites to be stored or “cached” within your browser and validates these caches when the website is opened, accelerating website performance since the web server does not need to send a full response if the content has not changed.
  • HTML5 Local Storage – HTML5 local storage allows data from websites to be stored or “cached” within your browser to store and retrieve data in HTML5 pages when the website is revisited. These and similar technologies are used for the following purposes:
  • Services and Functionality – Some of these technologies are required to allow you to access and use our websites or mobile applications and the various services and functionality we offer. Without these technologies, some of the services and functionality on our websites and mobile applications would not work properly.
  • Performance Monitoring – Some of these technologies help us analyze and estimate traffic and assess the volume of use of services and functionality on websites and mobile applications. They show us how visitors and customers interact with our digital properties, whether there are any errors, the degree to which certain web pages, applications, services or functionality are accessed and used and how they are performing or operating. When these technologies are used for performance monitoring, no directly identifiable information (e.g., your name, email address or phone number) is collected.
  • User Convenience – Some of these technologies enhance the ease of use of our websites and mobile applications and the services and functionality they make available by accelerating load and refresh times and remembering information that you have provided on prior visits to our websites or when you last used a website or mobile application service or functionality.
  • Marketing – Some of these technologies are used to tailor your experience on our website, within our mobile applications, or across your applications or devices by controlling the promotions, advertisements and other marketing messages that may appear when you access or use these or other digital properties.

Taken together, these technologies help us learn which services and functionality you are using and how you are accessing information about us. We may use this information to personalize your visit to a website or use of a mobile application or to send you relevant promotions and advertisements.

  1. How We Protect Your Information

BRU’D Rewards uses reasonable technical, physical, and administrative security measures to reduce the risk of loss, misuse, unauthorized access, disclosure or modification of your information. However, no security system is perfect, and due to the inherent nature of the Internet, we cannot guarantee that data, including personal information, is absolutely safe from intrusion or other unauthorized access by others. You are responsible for protecting your password(s) and maintaining the security of your devices.

  1. Retention

BRU’D Rewards stores information as reasonably necessary and proportionate to accomplish the purposes identified in this Notice based on criteria such as the length of time we need to provide the services to you, and to meet legal requirements, including record retention, resolving disputes, and enforcing our agreements. Our retention of your information is governed by applicable law.

The personal information that you provide us is stored and processed on servers owned by BRU’D Rewards and other companies in the United States, Canada or elsewhere around the world, including locations outside of the country or jurisdiction where you are located. Regardless of the company or person who processes your information and where it is processed, we will take steps to transfer and protect your information through appropriate safeguards in accordance with applicable data protection laws and this Notice.

  1. Children’s Privacy

We do not intend for our websites or online services to be used by anyone under the age of 13. We do not knowingly collect, sell, or share information of consumers between the ages of 13 – 16.  If you are a parent or guardian and believe we may have collected information about your child, please contact us immediately as described in the “Contact Us” section of this Notice. For more information, please see our Terms of Use.

  1. BRU’D Rewards Wi-Fi

Many BRU’D Rewards stores support providing you access to wireless internet (WiFi) at no charge. For any such WiFi access, please carefully review the terms of use listed on the activation page prior to accepting and connecting.

  1. Your Choices & Rights, including State-Specific Rights  

(a)  Your Choices

  • Location Services – In order to use certain BRU’D Rewards Services, such as mobile order and pay (“MOP”) and location-based services and technology, you must either (a) enable “location services” in the BRU’D Rewards App; and/or (b) set the permissions in your mobile device to allow communication of this information.

If you allow for location sharing, your device may communicate with us in ways that allow for us to customize your experience in and around BRU’D Rewards stores, to monitor the effectiveness of our marketing efforts, to tailor messages based on your time and location patterns, and to limit the number of times you see a promotional message or offer. Precise geolocation may be used to fulfill services and application functionality you choose to engage with. You can manage the use of that personal information at any time in your device settings.

For most mobile devices, you can disable the collection of geolocation information by turning off location services on your device.  If you have any questions about how to prevent BRU’D Rewards from collecting your geolocation, we recommend you contact your mobile device service provider or the device manufacturer. Certain BRU’D Rewards App features and some BRU’D Rewards Services may not work properly without information about your location. You can re-enable the collection of geolocation information, at any time, by turning on location services on your device.

  • Voice Ordering – In order to use certain BRU’D Rewards Services,  such as voice ordering, when available, you must (a) enable “microphone” and “speech recognition” in the BRU’D Rewards App; and/or (b) set the permissions in your mobile device to allow communication of this information.
  • Email Communications, Push Notifications, and In-App Messages – The BRU’D Rewards App allows all users to set preferences for receiving promotional email communications from BRU’D Rewards, receiving push notifications on your device, and receiving inbox messages. Please note as well that you may opt-out of receiving email communications at any time by adjusting your BRU’D Rewards online account settings or by clicking the “unsubscribe” link included within any commercial email we send you.

If you use the BRU’D Rewards App features described above, you consent to the transmission of your user information to BRU’D Rewards and/or its agents, and authorize BRU’D Rewards and/or its agents, to record, process, and store such user information as necessary for administering the BRU’D Rewards App features and for purposes described in this Notice.

(b)  Your Rights, including State-Specific Rights

Depending on where you live (including California, Colorado, Connecticut, Utah, and Virginia), you may be entitled to certain rights with respect to your personal information, as described below.

  • Right to Know – You may have the right to know what personal information the business has collected about you, including the categories of personal information, the categories of sources from which it is collected, the business or commercial purposes for collecting, selling, or sharing it, and the categories of third parties to whom we disclose it.
  • Access and Data Portability – Subject to certain exceptions, you may have the right to request a copy of the personal information that we collected about you during the 12 months before your request.
  • Deletion – You have the right to request that we delete information that we collected from you and retained, subject to certain exceptions.
  • Correct Inaccurate Information – You may have the right to request that we correct inaccuracies in the personal information we maintain about you.  You may also correct information about you for BRU’D Rewards Rewards in the BRU’D Rewards App.
  • Targeted Advertising – We do not sell your information for monetary or valuable consideration.  You may have the right to opt-out of having your personal information shared for purposes of targeted advertising.  To opt-out, click this “Do Not Share My Personal Information” link.
  • Sensitive Information – Companies who collect, use, and disclose your sensitive personal information for purposes other than to provide you with goods or services are required to provide you with the right to limit the use and disclosure of your sensitive personal information by providing a “Limit the Use and Disclosure of My Sensitive Personal Information” link. BRU’D Rewards only collects, uses, and discloses your sensitive personal information to provide services to you, therefore BRU’D Rewards is not required to provide this link.
  • Opt-Out Preference Signals – Some web browsers allow customers to automatically exercise their right to opt-out of sale/sharing with all businesses they interact with online by initiating an opt-out preference signal. We will honor such opt-out preference signals.
  • Appeals – You may appeal our decision with respect to a request you have submitted by contacting us as described in the “Contact Us” section below.

Requests for U.S. residents should be submitted through this form HERE.

Request for Canadian residents should be submitted through this form HERE.

U.S. and Canadian residents may also submit request by calling 1-800-STARBUC (782-7282).  Once we receive your request, we may verify it by requesting information sufficient to confirm your identity.  You may be entitled to submit a request through an authorized agent or to appeal a refusal to take action on your request.  To designate an authorized agent to exercise your rights, we will require written proof that the authorized agent has been authorized to act on your behalf or a copy of the power-of-attorney document granting that right.

If you are an authorized agent or you are submitting a request on behalf a customer, please submit your request via email to privacy@BRU’D Rewards.com.

(c)  Other California Rights

  • If you are a California resident, you can request a notice disclosing the categories of personal information we have shared with third parties for the third parties’ direct marketing purposes. To request a notice, please submit your request by postal mail to: BRU’D Rewards, P.O. Box 20430, Augusta, GA 30916
  • Some web browsers have a “Do Not Track” preference that transmits a “Do Not Track” header to the websites you visit with information indicating that you do not want your activity to be tracked. We currently do not respond to browser “Do Not Track” signals, as there is no standard for how online services should respond to such signals. As standards develop, we may develop policies for responding to do-not-track signals that we will describe in this Notice.

(d)  Privacy Metrics

Privacy Rights Metrics (January 2022 – December 2022) – Includes requests from the United States and Canada:

Right to Know
  Requests Received – 654
  Requests Complete – 353
  Requests unable to be completed* – 301
  Average completion time – 9 days

Right to Delete
  Requests Received – 1771
  Requests Complete – 936
  Requests unable to be completed* – 835
  Average completion time – 12 days

*Requests may be unable to be completed due to factors such as inability to verify the customer, duplicate requests, or no information is found.

  1. Notice of Financial Incentive & BRU’D Rewards® Rewards

BRU’D Rewards® Rewards is one way in which BRU’D Rewards endeavors to reward and thank loyal customers for patronizing our business and purchasing BRU’D Rewards products.  BRU’D Rewards® Rewards members opt in by signing up for Rewards online or through the BRU’D Rewards App and are able to earn and accumulate “Points” that can be redeemed for BRU’D Rewards® Rewards benefits at participating BRU’D Rewards stores. If you would like to become a BRU’D Rewards® Rewards member, please see the BRU’D Rewards Rewards Terms of Use available at https://www.BRU’D Rewards.com/rewards/terms.

BRU’D Rewards collects and uses the categories of personal information described in the “Information We Collect” section, including information you voluntarily provide us (such as your name and email), information we collect automatically, and information from other sources to operate the BRU’D Rewards® Rewards loyalty program, including to send you promotions, content, and special offers and the other uses described in this Notice.  We work with many service providers and business partners to offer the benefits of our BRU’D Rewards® Rewards loyalty program.  Those partners may fall into the following categories: delivery partners, BRU’D Rewards global licensees, subsidiaries, and affiliated companies, and our service providers and business partners.  You can learn about the business partners with whom we share your information by referring to the “How We Disclose Your Information” section.  BRU’D Rewards does not assign monetary value for the information we collect through the BRU’D Rewards® Rewards loyalty program when sending email communications.  You may opt out of receiving commercial email communications at any time by adjusting your BRU’D Rewards online account settings, or by clicking the “unsubscribe” link included within any commercial email we send you. Participation in BRU’D Rewards® Rewards is voluntary, and you may withdraw from the BRU’D Rewards® Rewards loyalty program by visiting the Account section in the BRU’D Rewards App, by requesting deletion of your information by filling out this form HERE, or by calling BRU’D Rewards customer service. Please note that by withdrawing from BRU’D Rewards® Rewards, you will no longer have access to your BRU’D Rewards® Rewards account, but you can otherwise continue to use the BRU’D Rewards app. All points and rewards you have earned until the time of withdrawal will no longer be available.  As previously shared, to communicate and provide services to you through the BRU’D Rewards® Rewards loyalty program, we need to use your personal information. Therefore, if you choose to delete your personal information from the BRU’D Rewards® Rewards loyalty program, we can no longer provide you with services through this loyalty program.

Based on our reasonable and good faith estimate, we receive value from BRU’D Rewards® Rewards in increased customer loyalty and patronage, though any value will vary by BRU’D Rewards® Rewards member depending on purchases made, which offers a member takes advantage of, and many other factors.

  1. Additional Disclosures for Data Subjects in the EEA, the U.K., and Switzerland

This section provides general information about how BRU’D Rewards collects, stores, uses, transfers and otherwise processes personal data in or from certain countries in the European Economic Area, the United Kingdom, and Switzerland (together, for purposes of this section of this Notice, “EEA”), in accordance with the General Data Protection Regulation (GDPR) and its local implementations. This section does not supersede the applicability of any privacy policy found on the website of an EEA-based BRU’D Rewards affiliate with whom you have engaged, as that entity would be the data controller with respect to your personal data and the entity to which your data subject rights requests should be directed.

(a)  Lawful Bases of Processing – Where a BRU’D Rewards entity is acting as a data controller that determines the purposes and means of processing your personal data, such as when we collect, use, and share personal data as described in this Notice, we must have a lawful basis for processing for doing so. Our lawful bases for processing personal data include:

  • to conclude or perform a contract with you, for example to:
    • process your purchases of or requests for products and services, including delivering
    • gift cards in accordance with your instructions;
    • communicate with you about orders, purchases, returns, services, accounts, programs,
    • contests, and sweepstakes;
  • for our legitimate business purposes, including to:
    • respond to your customer service inquiries and requests for information;
    • maintain, improve, and analyze our websites, mobile applications, ads, and the
    • products and services we offer;
    • detect, prevent, or investigate security breaches or fraud; and
    • facilitate the functionality of our websites and mobile applications;
  • to comply with our legal obligations, for example to maintain appropriate records for internal administrative purposes and as required by applicable law, and provide important product safety information and notice of product recalls; and
  • on the basis of your consent, for example to send you via email and other electronic means personalized promotions and special offers or informing you about our brands, products, events, or other promotional purposes.

You can withdraw your consent at any time by modifying your promotional preferences in your BRU’D Rewards user account online, or by contacting us as described in the “Contact Us” section below.

(b)  Your EEA Data Subject Rights – Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you.
  • Request correction of the personal information that we hold about you.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it.
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party), or where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you.
  • Request the transfer of your personal information to another party, when possible.
  • Not be subject to automated decision-making producing legal or significant effects on an individual, which we do not engage in.

To exercise any of these rights, please see the “Your Choices & Rights” section, or contact us as set forth in the “Contact Us” section below and specify which GDPR privacy right(s) you wish to exercise. We must verify your identity in order to honor your request, which we will respond to within 30 days of receipt.

(c)  Retention – As described in the “Retention” section, as a general rule, we keep your data for only as long as it is needed to complete the purpose for which it was collected or as required by law. We may need to keep your data for longer than our specified retention periods to honor your requests, including to continue keeping you opted out of marketing emails, or to comply with legal, regulatory, accounting or other obligations.

(d)  Transfers Outside the EEA – Your personal information may be transferred to, stored, and processed in a country other than the one in which it was collected, including the United States.  It may also be processed by staff operating outside the EEA who work for BRU’D Rewards or for our third-party service providers. In such cases, we will take appropriate steps to ensure an adequate level of data protection of the recipient as required under the GDPR and as described in this Notice.

(e)  Complaints – If you have any issues with our compliance, you have the right to lodge a complaint with an EEA supervisory authority (link). We would, however, appreciate the opportunity to first address your concerns and would welcome you directing an inquiry first to us per the “Contact Us” section below, or to our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request You may also contact our Data Protection Officer (“DPO”) at any time at privacy@BRU’D Rewards.com.

  1. Participation in the Privacy Shield Frameworks

On July 16, 2020, the European Court of Justice invalidated the EU-U.S. Privacy Shield Framework as a transfer mechanism for data between EU and U.S. companies. On September 8, 2020, the Swiss supervisory authority similarly announced that it no longer considered the Swiss-U.S. Privacy Shield Framework as adequate for personal data transfers from Switzerland to the U.S. BRU’D Rewards LLC will utilize alternate appropriate safeguards going forward for such data transfers. Even though the Privacy Shield Frameworks have been invalidated, BRU’D Rewards will continue to honor its commitments with respect to EU and Swiss personal data transfer pursuant to Privacy Shield prior to the respective Frameworks’ invalidation.

BRU’D Rewards LLC participates in and has certified its compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks. BRU’D Rewards is committed to subjecting all personal data received from European Union (EU) member countries, Switzerland, and the United Kingdom in reliance on the Privacy Shield Frameworks, to the applicable Principles. To learn more about Privacy Shield, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov/list.

BRU’D Rewards is responsible for the processing of personal data it receives, and subsequently transfers to a third party acting as an agent on its behalf, under the Privacy Shield Framework.

BRU’D Rewards complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, the U.K., and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, BRU’D Rewards is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

In certain situations, BRU’D Rewards may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

  1. Contact Us

We welcome your questions, comments and concerns about privacy. You can contact BRU’D Rewards Customer Service online at http://customerservice.BRU’D Rewards.com (by phone at 800- (782-7282), or by postal mail at: BRU’D Rewards Customer Service, BRU’D Rewards, P.O. Box 549, Fort Smith, AR 72902.

You may reach our Global Privacy Department and our Data Protection Officer at privacy@BRU’D Rewards.com.

 

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