Punchh (“Punchh,” “us,” “we,” or “our”) offers a variety of services on behalf of our business Partners (our “Partners”). We provide many of our services to you and other patrons of our Partners (“Users,” “you,” or “your”) through the Punchh website and through mobile, point of sale, and online applications provided by and on behalf of Punchh and our Partners (collectively, our “Platform”). By patronizing the businesses of our Partners, you access and use these services through our Platform.
We are committed to protecting the privacy of the users of our Platform. This Privacy Policy describes our practices regarding the collection, use, and sharing of personal information through our Platform. However, in many cases the privacy policy of our Partners, not this policy, applies to your information. You should refer to the Partner’s privacy policy to learn about their data privacy practices.
You may contact any of our Partners for a copy of their own privacy policy applicable to the information they collect directly from you.
Punchh reserves the right to, at any time, modify this Privacy Policy. If we make revisions that change the way we collect, use, or share personal information, we will post those changes in this Privacy Policy. Our Privacy Policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy. Please review this Privacy Policy periodically to keep up to date on our most current policies and practices.
You can jump to specific sections of this Privacy Policy by clicking the links below:
Personal information refers to information connected to Users that may be used to identify them.
Personal information refers to information connected to Users that may be used to either directly or indirectly identify them.
Punchh collects personal information when Users voluntarily submit it to us or when Partners submit User information on their behalf. For example, we may collect or receive information from a Partner about a User when the User creates an account on our Platform, edits their profile on our Platform, uses or accesses services or content through our Platform, or otherwise interacts with us, our Partners, or other Users of the Platform. Many methods that Punchh uses to collect personal information require User opt-in. As discussed above, in most cases Punchh is collecting personal information for our Partner’s and our Partner’s privacy policy applies.
Punchh may collect personal information about Users in the following ways:
Punchh may collect personal information about other third parties, including our Partners, in the following ways:
Punchh retains your personal information for as long as necessary for the purpose that it was collected, unless a different amount of time is required or allowed by law. If we have collected your information on behalf of a Partner, the Partner determines how long we keep your personal information.
Punchh’s primary purpose in collecting personal information is to provide our Partner’s with the services they have contracted with Punchh for, such as providing Users with services, loyalty programs, and rewards programs that Users request through the Platform or that match User interests.
In addition to the uses stated above, Punchh may use personal information for various other purposes, including without limitation to:
Our collection and use of your information is based, in different contexts, upon your consent, our need to perform a contract, our obligations under law, and our legitimate interest in conducting our business. When we collect information on behalf of our Partners, our Partners determine the basis for that collection and processing.
In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations. In addition, we do not sell your personal information.
Partners. We share User personal information with our Partners. In doing so, we require that our Partners use the User personal information they receive from us subject to the terms of their Privacy Policy. Please understand, however, that our Partners may also obtain User personal information directly from Users (e.g., when those Users patronize their restaurants, visit their websites, use their mobile apps, etc.). Any information collected directly by our Partners or at the direction of our Partners is not subject to this Privacy Policy. You may contact any of our Partners for a copy of their own privacy policy.
Marketing. We do not share User information with third parties to directly market to Users, but Partners may market to Users using our Platform. We may market to Users on behalf of our Partners or other third parties that would like to send Users information about their products and services. For example, Punchh may offer a promotion in conjunction with a cosponsor that may have special offers or services that might be of interest to Users.
Within the Platform. Users may have the ability to share information within the Platform, either with other Users or with individuals who are not yet Users. For example, information may be shared within the Platform in the following circumstances:
Service Providers. Punchh may share User personal information with service providers that perform services for Punchh, such as providing hosting services, marketing assistance, analyzing User data, and processing payment card information.
Sharing Without Your Consent. There may also be instances when Punchh may disclose User personal information without providing Users with a choice. This may happen if we need to protect the legal rights of Punchh, other affiliated companies or their employees, agents, and contractors; honor a request that Users have made through the Platform; protect the safety and security of other Users; protect against fraud or for risk management purposes; if required to do so by court order, subpoena, or warrant; or to comply with the law or national security requirements.
Sharing With Your Consent. We may also ask for your consent to share your personal information in other ways.
Affiliates and Acquisitions. If Punchh sells all or part of its business or makes a sale or transfer of assets or is otherwise involved in a merger or business transfer, Punchh may transfer User personal information to a third party as part of that transaction.
Social Networking. The Platform may offer Users the ability to share personal information through a social networking site (e.g., Facebook, Twitter, LinkedIn), using such site’s integrated tools (e.g., Facebook “Like” button, or Twitter “Tweet” button). The use of such integrated tools enables Users to share personal information about themselves with other individuals or the public. For more information about the purpose and scope of data collection and use in connection with such social networking site or a site’s integrated tools, please visit the privacy policies of these social networking sites.
Users can access, modify, and delete some types of personal information through their Platform account or by contacting Punchh using the contact information in the “Data Protection Officer, Communications, and Requests” section below. If we have collected your information on behalf of one of our Partners, we will direct your request to our Partner for fulfillment. We recommend that Users reach out directly to the Partner rather than to Punchh.
You may also contact Punchh to make a request regarding your personal information, such as asking Punchh to:
As required by law, we will require you to prove your identity. We verify identity by comparing the information you provide when submitting your request with the information in our database. Depending on your request, we may ask for additional information such as the email address you used to place an order. We may also ask you to provide a signed declaration confirming your identity.
In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. We will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us. If you are an authorized agent submitting a request on behalf of an individual you must attach a copy of the following information to the request:
If we do not receive both pieces of information, the request will be denied.
Please note that although Punchh takes all requests seriously, depending on applicable law and Punchh’s legal rights, we may not be able to grant your request. Additionally, some of your personal information may be controlled by our Partners. If your request relates to personal information controlled by our Partners, we will direct you to communicate with that Partner directly. Finally, in limited cases, under applicable law Punchh is allowed to charge for certain requests.
We do not discriminate against California residents who exercise any of their rights described in this Privacy Policy.
Promotional Emails. Users who no longer wish to receive our weekly email updates or other email notifications may opt-out of receiving these communications by following the instructions contained in the applicable email or by logging-in and changing their settings in the account settings.
Do-Not-Track. Some web browsers and devices permit Users to broadcast a preference that they not be “tracked” online. At this time Punchh does not modify User experience based upon whether such a signal is broadcast.
The Platform is not meant for or targeted to children and should not be used by children under 13.
Punchh employs reasonable and appropriate security measures to protect personal information. While there is no such thing as “perfect security” on the Internet, we will take reasonable steps to ensure the safety of personal information. Please keep your password and account information secure, and notify us of unauthorized use of your account.
In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
User privacy is important to us and we encourage you to submit all questions and complaints to Punchh using the information in the “Data Protection Officer, Communications, and Requests” section below. However, you may also have the right to complain to a government or regulatory body about our privacy practices.
Our contact information for privacy-related communications is our data protection officer, who can be reached at: