GROUPON, INC. PRIVACY STATEMENT
Last Updated: January 9, 2015
By using the Site, you agree to the terms of this Privacy Statement. If you do not agree with the practices described in this Privacy Statement, please do not provide us with your personal information or interact with the Site.
We may modify this Privacy Statement at any time. If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of notice on the Site prior to the change becoming effective. You can determine when this Privacy Statement was last revised by referring to the date it was “Last Updated” above. You can review the last version of this Privacy Statement here.
This Privacy Statement is organized as follows:
- Types of Information We Collect
- Your Choices
- How Groupon Uses Information
- When and Why Groupon Discloses Personal Information
- How Groupon Collects Information
- Security of Personal Information
- Accessing and Correcting Personal Information
- Social Networks
- Privacy Practices of Third Parties
- Notice to Residents of Countries outside the United States of America
- Children’s Privacy
- Contact Us; California Privacy Rights and Other Countries
- Glossary of Terms
- Self Regulatory Frameworks
- access or use the Site;
- register, subscribe, or create an account with Groupon;
- open or respond to our e-mails;
- contact customer service or use other customer support tools;
- provide information to enroll or participate in Other Programs provided on behalf of, or together with, Business Partners;
- visit any page online that displays our ads or content;
- purchase products or services on or through the Site;
- connect or link to any Site via social networking sites;
- post comments to Online Communities; and
- provide information to our Vendors.
This Privacy Statement does not apply to the collection of information in any way other than as listed above.
We think that you benefit from a more personalized experience when we know more about you and what you like. However, you can limit the information you provide to Groupon, and you can limit the communications that Groupon sends to you.
(a) Commercial E-mails
You may choose not to receive commercial e-mails from us by following the instructions contained in any of the commercial e-mails we send or by logging into your account and adjusting your e-mail preferences. Please note that even if you unsubscribe from commercial email messages, we may still e-mail you non-commercial e-mails related to your account and your transactions on the Site. You may update your subscription preferences at any time.
(b) Cookies and Tracking
You may manage how your browser handles Cookies by adjusting its privacy and security settings. Browsers are different, so refer to instructions related to your browser to learn about cookie-related and other privacy and security settings that may be available. You can opt-out of being targeted by certain Third-Party Ad-Servers and Groupon served ads online using the National Advertising Initiative’s Opt-Out Tool, the About Ads Opt-Out Tool, or on TRUSTe’s site. For more information review our Cookies Policy. Currently, we do not alter our data collection and use practices in response to Do Not Track signals.
We use Non-Identifiable Information to directly serve you interest-based ads on third party websites. Interest-based ads served directly by Groupon on third party sites will display the AdChoices icon. If you prefer not to receive interest-based ads from Groupon on third party sites, you can click on the AdChoices icon in the ad, which will direct you to the Your Groupon AdChoices page where you can opt-out of receiving interest-based ads served by Groupon.
(c) Device Data
You may manage how your mobile device and mobile browser share certain Device Data with Groupon, as well as how your mobile browser handles Cookies by adjusting the privacy and security settings on your mobile device. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.
(d) E-mails from Business Partners
If you wish to opt out of receiving offers directly from our Business Partners, you can follow the opt-out instructions in the emails that they send you.
We (or our Vendors on our behalf), use information collected as described in this Privacy Statement to:
- Operate, maintain and improve the Site and our services, and Other Programs;
- Provide you with interest-based ads and offers for products and services from us and participating Business Partners;
- Facilitate and fulfill orders placed on the Site and Other Programs – for example, for Groupon vouchers and other goods and services, including tracking redemption;
- Evaluate your eligibility for certain types of offers, products or services that may be of interest to you, and analyze advertising effectiveness;
- Answer your questions and respond to your requests;
- Perform analytics and conduct customer research;
- Communicate and provide additional information that may be of interest to you about Groupon and our Business Partners, sometimes by combining your information with information from Other Sources;
- Send you reminders, technical notices, updates, security alerts, support and administrative messages, service bulletins, marketing messages, and requested information, including on behalf of Business Partners;
- Administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored by us or our Business Partners;
- Allow you to apply for a job, post a video or sign up for special offers from merchants, Business Partners, or third parties through the Site and Other Programs, and to
- Enhance other information we have about you directly or from Other Sources to help us better understand you and determine your interests.
We also may use information collected as described in this Privacy Statement with your consent or as otherwise required or permitted by law.
- with any Groupon Affiliate who may only use the Personal Information for the purposes described in this Privacy Statement;
- with our Vendors to provide services for us and who are required to protect the Personal Information;
- to report or collect on debts owed to us or our Business Partners;
- with relevant Business Partners:
- with whom we jointly offer products and services;
- to facilitate a direct relationship with you, including in connection with any program we administer on behalf of the Business Partner;
- to enable electronic communications with you as part of purchase, a sponsored reward, offer, contest, program, or other activity in which you have elected to participate;
- to the extent you have purchased or redeemed a Groupon voucher, goods or services offered by a Business Partner or participated in an offer, rewards, contest or other activity or Other Programs sponsored or offered through Groupon on behalf of that Business Partner;
- with a purchaser of Groupon or any of the Groupon Affiliates (or their assets);
- to comply with legal orders and government requests, or as needed to support auditing, compliance, and corporate governance functions;
- to combat fraud or criminal activity, and to protect our rights or those of our Affiliates, users, and Business Partners, or as part of legal proceedings affecting Groupon;
- in response to a subpoena, or similar legal process, including to law enforcement agencies, regulators, and courts in the United States and other countries where we operate; or
- with your consent.
We encourage Business Partners to adopt and post privacy policies. However, their use of Personal Information obtained through Groupon is governed by their privacy policies and is not subject to our control.
We may also disclose Non-Identifiable Information:
- for the same reasons we might share Personal Information;
- with Business Partners for their own analysis and research;
- to facilitate targeted content and ads; or
- with Third-Party Ad-Servers to place our ads and/or ads of our merchants or Business Partners on the Site and on third-party sites, and to analyze the effectiveness of those ads.
You provide us with your Personal Information when you register, subscribe, create an account, make a purchase, or otherwise when you provide us with your Personal Information during your interaction with the Site and Other Programs. We also collect Personal Information when you contact us online for customer service and other support using self-help tools, such as email, text, or by posting to an Online Community.
Device Data may be collected when your device interacts with the Site and Groupon, even if you are not logged into the Site using your device. If you have questions about the security and privacy settings of your mobile device, please refer to instructions from your mobile service provider or the manufacturer of your device to learn how to adjust your settings.
Groupon has implemented an information security program that contains administrative, technical and physical controls that are designed to reasonably safeguard Personal Information. For example, we use industry-standard encryption technology to secure Financial Account Information. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact us at firstname.lastname@example.org.
You can access, update and delete your
If you want to deactivate your Groupon account or have other questions or requests, please contact us. While we are ready to assist you in managing your subscriptions, deactivating your account, and removing your active profile, we cannot always delete records of past interactions and transactions. For example, we are required to retain records relating to previous purchases on the Site for financial reporting and compliance reasons.
We will retain your Personal Information for as long as your account is active or as needed to provide you services and to maintain a record of your transactions for financial reporting purposes. If you wish to deactivate your account or request that we no longer use your Personal Information to provide you services contact us at email@example.com. We will retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Social Community Areas
You also have the option to link social networks, such as Facebook, to your Groupon account. Once you register with Groupon and connect with the social network, you will be able to automatically post recent Groupon activity back to your social network. You can enable and disable social network connections from the “Connections” tab in your Groupon account.
This Privacy Statement only addresses the use and disclosure of information by Groupon through your interaction with the Site. Other websites that may be accessible through links from the Site and Other Programs may have their own privacy statements and personal information collection, use, and disclosure practices. Our Business Partners may also have their own privacy statements. We encourage you to familiarize yourself with the privacy statements provided by these other parties prior to providing them with information or taking advantage of a sponsored offer or promotion.
If you live outside the United States (including in the European Economic Area (“EE”) and Switzerland (“CH”) collectively the “EEA/CH”), and you use the Site or provide us with Personal Information directly via the Site, your information will be handled in accordance with this Privacy Statement. By using the Site or giving us your Personal Information, you are directly transferring your Personal Information and Non-Identifiable Information to us in the United States. The United States may not have the same level of data protection as your jurisdiction. However, you agree and consent to our collection, transfer, and processing of your Personal Information and Non-Identifiable Information in accordance with this Privacy Statement. You are solely responsible for compliance with any data protection or privacy obligations in your jurisdiction when you use the Site or provide us with Personal Information. Regardless of where we transfer your information, we still protect your information in the manner described in this Privacy Statement.
Groupon does not intend that any portion of the Site will be accessed or used by children under the age of thirteen, and such use is prohibited. The Site is designed and intended for adults. By using Groupon, you represent that you are at least eighteen years old and understand that you must be at least eighteen years old in order to create an account and purchase the goods or services advertised through the Site. We will promptly delete information associated with any account be obtain actual knowledge is associated with a registered user who is not at least eighteen years old.
Please contact us if you have any questions or comments about our privacy practices or this Privacy Statement. You can reach us online at firstname.lastname@example.org. You can reach us via postal mail at the following address:
Attention: Privacy Office
600 West Chicago Avenue
Chicago, Illinois 60654 USA
If you reside in Canada, you may have the right to be provided with access to Personal Information that we have collected about you and written information about our policies and practices with respect to the transfer of your personal information to Vendors outside Canada. E-mail us at email@example.com with questions.
Pursuant to Section 1798.83 of the California Civil Code, residents of California can obtain certain information about the types of personal information that companies with whom they have an established business relationship have shared with third parties for direct marketing purposes during the proceeding calendar year. In particular, the law provides that companies must inform consumers about the categories of personal information that have been shared with third parties, the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. To request a copy of the information disclosure provided by Groupon pursuant to Section 1798.83 of the California Civil Code, please contact us via the email or address stated above. Please allow 30 days for a response.
Affiliate means an entity owned, directly or indirectly, by Groupon, Inc. or that is controlled by or under common control with Groupon, Inc., and also includes joint ventures entered into by Groupon, Inc. and/or its Affiliates.
Business Partners means, collectively, third parties with whom we conduct business, such as merchants, co-marketers, distributors, and resellers.
Device Data means information concerning a device you use to access, use, or interact with the Site, such as operating system type or mobile device model, browser type, domain, and other system settings, the language your system uses and the country and time zone of your device, geo-location, unique device identifier or other device identifier, mobile phone carrier identification, and device software platform and firmware information.
Non-Identifying Information means information that alone cannot identify you, including data from Cookies, Pixel Tags and Web Beacons, and Device Data. Non-Identifying Information may be derived from Personal Information.
Online Communities means, collectively, our social networking pages or accounts, forums, bulletin boards, discussion groups, chat rooms or other methods of communication that may be offered on or linked through the Site.
Other Programs means special programs, features and functionality on our Site or other co-branded websites with Business Partners that we reasonably control and that have special use terms applicable to such special programs, features and functionality.
Other Sources means sources of information that legally provide Groupon with your information, and which are outside the scope of this Privacy Statement at the time of collection.
Personal Information means information about you that specifically identifies you or, when combined with other information we have, can be used to identify you. This includes the following types of information:
Contact Information: your name, postal addresses, email addresses, social networking website user account names, telephone numbers, or other addresses at which you are able to receive communications.
Relationship Information: information you provide that enables us to determine lifestyle, interests, and activities, including location information related to your state/province, city, or neighborhood; areas of interest, the types of deals that interest you, information collected through your interactions with social networks, demographic information (e.g., birth date, age, gender); information about persons for whom you have purchased Groupon vouchers as gifts or who have bought Groupon vouchers as gifts for you; and information about friends who refer you or whom you have referred;
Transaction Information: information you provide when you interact with us and the Site, such as the Groupon vouchers you are interested in, purchase and redeem; email and other communications; and how you interact with Business Partners and our Vendors; and
Financial Information: information collected from you as needed to process payments for Groupon vouchers or other products or services that you buy, or as provided by you to administer your participation in optional services and programs, such as your payment card number, expiration date, and card verification number.
Pixel Tags and Web Beacons means tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed specific actions.
Vendors means, collectively, third parties that perform business operations on behalf of Groupon, such as transaction processing, billing, mailing, communications services (e-mail, direct mail, etc.), marketing, data processing and analytics, servicing, collections, or ad management.
We self-certify compliance with:
(a) Safe Harbor
Groupon has certified to its compliance with the Safe Harbor privacy framework for the handling of Personal Information transferred from the EEA/CH.
The European Community has established a data protection regime pursuant to Directive 95/46/EC (the “Directive”). The Directive applies to the European Economic Area (“EEA”). Switzerland has also established a data protection regime pursuant to the Federal Act on Data Protection (“FADP”). These regimes restrict companies in the EEA and Switzerland (collectively, “EEA/CH”) from transferring Personal Information about individuals in the EEA/CH to the United States, unless there is “adequate protection” for such Personal Information when it is received in the United States. To create such “adequate protection” and allow our Affiliates, Vendors and Business Partners to overcome the restriction on international data transfers established by the Directive and the FADP, we adhere to the Safe Harbor Privacy Principles published by US Department of Commerce (“Safe Harbor Principles”) with respect to Personal Information about individuals in the EEA/CH that our subsidiaries and Business Partners in the EEA/CH send to us, (“EEA/CH Data”). More information on the Safe Harbor Principles and Groupon, Inc.’s scope of participation is available at http://export.gov/safeharbor/. Groupon’s policy concerning the processing of EEA/CH Data under its certification can be viewed at http://www.groupon.com/safe-harbor.
Groupon, Inc. has received TRUSTe’s Privacy Seal signifying that this Privacy Statement and practices have been reviewed by TRUSTe for compliance with TRUSTe’s program requirements including transparency, accountability and choice regarding the collection and use of your information. TRUSTe’s mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions. If you have questions or complaints regarding our Privacy Statement or practices, please contact us at firstname.lastname@example.org. If you are not satisfied with our response you can contact TRUSTe here. The TRUSTe program only covers information collected on the Web site www.groupon.com. The TRUSTe program only covers information collected on the Web site www.groupon.com and does not cover information that may be collected through our mobile applications and social networking applications.
(c) Digital Advertising Alliance
Groupon, Inc. is a member of the Digital Advertising Alliance (DAA), which is a media marketing and trade association that has issued self-regulatory guidelines for online advertising. Visit the DAA’s AdChoices page to learn more about interest-based advertising and to opt-out of having cookies placed by ad-serving companies.