S’more™ Privacy Policy

Effective Date: January 1, 2020

1. Introduction

The S’more mobile application (“Application” or “App”) provides you with the opportunity to earn points which can be redeemed for various rewards. S’more is brought to you by Lab465, LLC (“Lab465”, “we” or “us”). We have prepared this Privacy Policy to describe our practices regarding the information we collect, use, and share through the Application and our website located at http://www.smoreapp.co (collectively, “Services”).Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we treat it in connection with the Application and the Services. If you do not agree with this Privacy Policy, you should not use or register with the Application, and instead you should DELETE and UNINSTALL it.

I. Scope

This Privacy Policy explains our practices about collecting, using and sharing information, including personal information which is information used to identify you. See Section 2.I below for the complete definition of personal information (“Personal Information” or “PI”).

You authorize Lab465, LLC to collect your information when you interact with us. When you visit our website, register to use S’more or interact with the application, you agree to our collection, use and sharing of your information as described in this Privacy Policy. By signing up, you opt-in to the sharing of your Personal Information with third party advertisers and our third-party survey partners, allowing the Application to provide you with the opportunity to be awarded points which can be redeemed for various rewards. Once awarded, you may redeem points through purchases at any time. By signing up for Service you opt-in to any financial incentives associated with the awards program. If you wish to opt-out of any financial incentives or the selling or sharing of your Personal Information by us, third party advertisers, or our third-party survey partners, please UNINSTALL and DELETE this Application.

Your use of the Application is governed by this Privacy Policy and the S’more Terms and Conditions (“Terms and Conditions”). Please consult the Terms and Conditions for detailed information about the Services. Capitalized terms not defined in this Privacy Policy shall have the meaning ascribed to them in the Terms and Conditions.

This Privacy Policy does not apply to information that we (or our affiliates) may collect on any other websites or applications, including websites you may access through the Application, or any information that you provide to or that is collected by any third party. APPLE, GOOGLE AND AMAZON ARE NOT SPONSORS NOR ARE INVOLVED IN ANY WAY IN THIS CONTEST/DRAW. NO APPLE PRODUCTS ARE BEING USED AS PRIZES.

II. CHANGES TO THE PRIVACY POLICY

Lab465 may update this Privacy Policy at any time, at least annually to reflect new legal requirements, changes within our Services, or to clarify our practices. Please periodically refer back to this Privacy Policy to learn what changes, if any, have been made based on the effective date posted with the updated Privacy Policy. If we propose to use your information materially different than what was stated in the Privacy Policy at the time we collected it, Lab465 will obtain your consent in the appropriate manner, which may include an opt-out mechanism. Continued use of our Services, following notice of such changes, shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

Effective: January 1, 2020

Updates include: additional categories of Personal Information which we collect from you, statement of your rights as a California resident, and updates to the Cookie Policy.

III. ACCESSIBILITY

To make accessibility-related requests or report barriers, please contact us at support@smoreapp.co.

V. CHILDREN UNDER THE AGE OF 13

The Application is not intended for children under 13 years of age, and we do not knowingly collect Personal Information from children under 13. If we learn that we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information. If you believe that we might have any Personal Information from or about a child under 13, please contact us at support@smoreapp.co.

VI. THIRD PARTY WEBSITES AND APPLICATIONS

When you click on a link or otherwise leave the Services and go to another site, another entity may collect Personal Information or Anonymous Information from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of data after you click on links or swipe left to connect to such outside websites.

VII. SECURITY OF PERSONAL INFORMATION

Lab465 uses a variety of commercially reasonable and appropriate safeguards to protect precise location information residing on its systems from unauthorized access or disclosure including, without limitation, server firewalls and physical facility security. We retain this location information only so long as needed to provide and support location-based services or our mobile applications, or as required by law. Should we retain location information for a longer period, we shall do so only for business purposes and may convert such location information into aggregated or de-identifiable data. No security is perfect, however, and Lab465 cannot guarantee the security of GPS or precise your location information derived from your device settings.

We take reasonable security safeguards to protect against such risks as loss or unauthorized access, destruction, use, modification, or disclosure of Personal Information.

You should not provide your Account information to unauthorized parties. You are encouraged to protect your mobile device, computer, and passwords against unauthorized access. When accessing information online, you should sign off when finished using a shared computer and always log out of any website after viewing Personal Information.

2. INFORMATION WE COLLECT

I. PERSONAL INFORMATION WE COLLECT

Personal Information is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include anonymous or de-identified information that cannot personally identify you, your accounts or devices.
The following sections summarize:

  • The categories of and descriptions of Personal Information we collect;
  • The categories of sources from which the Personal Information was collected;
  • The business or commercial purpose for which the Personal Information was collected; and
  • The categories of third parties with whom S’more shares Personal Information.

II. INFORMATION YOU PROVIDE TO US

Category of Personal Information: Account Information

  • Description: We may collect information from you, such as your name, gender, age, birth month and year, ethnicity, marital status, employment status, educational level, income, content interests, e-mail address, state of residence, zip code of residence, phone number and Application passwords when you create an account within the Application (“Account”).
  • Source: You provide this information to us.
  • Business or Commercial Purpose(s): Provide you with the Services; Direct Advertisements and Content to you; Maintaining the Quality and Integrity of the Application and Services; Internal Research for Technological and Product Development; Identifying and Repairing Errors; Detecting and Preventing Security Incidents and Fraud; Auditing Digital Interactions.
  • Category of Third Parties Shared With: Service Providers; Local, State, or Federal Government Authorities or Other Entities with Legal Authority; third party advertisers.

Category of Personal Information: Redemption Information

  • Description: When you redeem points for rewards through the Application, we may collect additional the Personal Information required to complete the transaction, such as your name, e-mail and shipping information.
  • Source: You provide this information to us.
  • Business or Commercial Purpose(s): Provide you with the Services; Detecting and Preventing Security Incidents and Fraud.
  • Category of Third Parties Shared With: Service Providers; Local, State, or Federal Government Authorities or Other Entities with Legal Authority; third party advertisers

Category of Personal Information: Feedback Information

  • Description: If you provide us feedback or contact us via e-mail through the Services, we will collect your name and email address, as well as any other content included in the e-mail, in order to send you a reply.
  • Source: You provide this information to us.
  • Business or Commercial Purpose(s): Provide you with the Application and Services; Direct Advertisements and Content to you; Maintaining the Quality and Integrity of the Application and Services; Internal Research for Technological and Product Development; Identifying and Repairing Errors; Auditing Digital Interactions.
  • Category of Third Parties Shared With: Service Providers; Local, State, or Federal Government Authorities or Other Entities with Legal Authority; third party advertisers.

Category of Personal Information: Survey Responses

  • Description: If you engage in surveys on the Application, your survey responses may be collected by the Application and by the third parties who are conducting the survey. Survey questions may ask you for your Personal Information, and you should only provide your Personal Information if you are comfortable doing so. The privacy policies of the survey providers will be available through the Application for you to review.
  • Source: You provide this information to us.
  • Business or Commercial Purpose(s): Provide you with the Application and Services; Direct Advertisements and Content to you.
  • Category of Third Parties Shared With: Service Providers; Local, State, or Federal Government Authorities or Other Entities with Legal Authority; third party advertisers.

Category of Personal Information: Tax Information

  • Description: If the value of the points you redeem through the Application exceeds the amount which we are required to report to any taxing authority, we will collect your social security number or other tax identification number.
  • Source: You provide this information to us.
  • Business or Commercial Purpose(s): Provide you with the Application and Services; Detecting and Preventing Security Incidents and Fraud.
  • Category of Third Parties Shared With: Service Providers; Local, State, or Federal Government Authorities or Other Entities with Legal Authority; third party advertisers.

Category of Personal Information: Other Information

  • Description: We may also collect other Personal Information at other points in the Services that state that Personal Information is being collected, such as requests for your e-mail made through the Services.
  • Source: You provide this information to us.
  • Business or Commercial Purpose(s): Provide you with the Application and Services; Internal Research for Technological and Product Development; Identifying and Repairing Errors; Detecting and Preventing Security Incidents and Fraud; Auditing Digital Interactions.
  • Category of Third Parties Shared With: Service Providers; Local, State, or Federal Government Authorities or Other Entities with Legal Authority; third party advertisers.

III. INFORMATION COLLECTED VIA TECHNOLOGY

To make the Services more useful to you, the Services use technology to automatically collect certain Information, including but not limited to:

Category of Personal Information: Location Information

  • Description: The Application may collect, transfer and use information about your device’s precise location to provide a more personalized and relevant experience, including precise location-relevant advertising delivered by third party partners. This includes GPS-based, Wi-Fi based and cell tower based location information. You will be provided the choice of sharing your location information when you first register in the Application. If you opt-in to sharing your location information, the Application will allow Lab465 and third parties to collect, transfer, and use your device’s precise location information. Lab465 does not guarantee the accuracy or completeness of location information delivered through the Application, and any location-based service or may be disrupted or fail due to environmental factors and factors affecting satellite usage. You can opt out of the future collection, transfer and use of precise location information through device settings. Lab465 abides by the International Association for the Wireless Telecommunications Industry (CTIA) Best Practices and Guidelines for Location Based Services which can be found on the CTIA’s website at http://www.ctia.org. See Opting Out to learn about disabling the collection of location information.
  • Source: Our Services use technology to automatically collect this information.
  • Business or Commercial Purpose(s): Provide you with the Services; Direct Advertisements and Content to you; Maintaining the Quality and Integrity of the Application and Services; Internal Research for Technological and Product Development; Identifying and Repairing Errors; Detecting and Preventing Security Incidents and Fraud; Auditing Digital Interactions.
  • Category of Third Parties Shared With: Service Providers; Local, State, or Federal Government Authorities or Other Entities with Legal Authority; third party advertisers.

Category of Personal Information: Usage Details

  • Description: The Services may automatically collect certain details of your access to and use of the Services, including traffic data, engagement with advertisements, the points you have accumulated, surveys answered, your Redemption Purchases, clickstream information (which is the recording of the parts of the screen or Application that you click on), search terms, content views and date and time of usage/visit.
  • Source: Our Services use technology to automatically collect this information.
  • Business or Commercial Purpose(s): Provide you with the Services; Direct Advertisements and Content to you; Maintaining the Quality and Integrity of the Application and Services; Internal Research for Technological and Product Development; Identifying and Repairing Errors; Detecting and Preventing Security Incidents and Fraud; Auditing Digital Interactions.
  • Category of Third Parties Shared With: Service Providers; Local, State, or Federal Government Authorities or Other Entities with Legal Authority; third party advertisers.

Category of Personal Information: Computer or Device Information

  • Description: The Services may collect information about your computer or mobile device and internet connection, including the unique advertising identifier (Ad ID) of a device, IP address, operating system, mobile network information, network connection type (e.g., Wifi, cellular), a device’s telephone number, other device identifiers, and device model, manufacturer and type.
  • Source: Our Services use technology to automatically collect this information.
  • Business or Commercial Purpose(s): Provide you with the Application and Services; Direct Advertisements and Content to you; Maintaining the Quality and Integrity of the Application and Services; Internal Research for Technological and Product Development; Identifying and Repairing Errors; Detecting and Preventing Security Incidents and Fraud; Auditing Digital Interactions.
  • Category of Third Parties Shared With: Service Providers; Local, State, or Federal Government Authorities or Other Entities with Legal Authority; third party advertisers.

Category of Personal Information: Survey Serving Technology

  • Description: The App uses Pollfish SDK. Pollfish is an on-line survey platform, through which, anyone may conduct surveys. Pollfish collaborates with Developers of applications for smartphones in order to have access to users of such applications and address survey questionnaires to them. When a user connects to this app, a specific set of user’s device data (including Advertising ID which will may be processed by Pollfish only in strict compliance with google play policies- and/or other device data) and response meta-data (including information about the apps which the user has installed in his mobile phone) is automatically sent to Pollfish servers, in order for Pollfish to discern whether the user is eligible for a survey. For a full list of data received by Pollfish through this app, please read carefully Pollfish respondent terms located at https://www.pollfish.com/terms/respondent. These data will be associated with your answers to the questionnaires whenever Pollfish sends such questionnaires to eligible users. By downloading the application you accept this privacy policy document and you hereby give your consent for the processing by Pollfish of the aforementioned data. Furthermore, you are informed that you may disable Pollfish operation at any time by using the Pollfish “opt out section” available on Pollfish website . We once more invite you to check the respondent’s terms of use, if you wish to have more detailed view of the way Pollfish works.
  • Source: Our Services use technology to automatically collect this information.
  • Business or Commercial Purpose(s): Provide you with the Application and Services; Direct Advertisements and Content to you; Auditing Digital Interactions.
  • Category of Third Parties Shared With: Service Providers; Local, State, or Federal Government Authorities or Other Entities with Legal Authority; third party advertisers

IV. THIRD PARTY COLLECTION

When you use the Application, certain third parties may use automatic information collection technologies to collect information about your device and your behaviors. Third parties may include: advertisers, ad networks, survey providers, ad servers and analytics companies (collectively “third party advertisers”).

Through the Application, these third parties may collect information, such as your device type, operating system, device’s Ad ID, IP address and other device identifiers, browser type, your usage of the Application, cookie information, and your engagement with advertisements (e.g., which ads were served, viewed, clicked on and whether you visited an advertiser’s website or purchased a product or service advertised). We may also share other information with these third parties, such as technical device information including your operating system and whether you connect through WIFI or a network, and profile information about you stored in your Account including your age, gender, precise location and your device’s Ad ID.

All of this Information is shared in order to provide you with interest-based (behavioral) advertising and other relevant content on the Application. These third parties are not bound by this Privacy Policy and may use the information for any lawful purposes. These third parties may also collect other information about you (including Personal Information) outside of the Application, such as your online activities over time and across different websites and applications. Lab465 is not responsible or liable for the information collected directly by these third parties or their privacy policies or practices. See “About Our Ads”.

You may connect to other services you use through the Application, such as social networking sites. If you connect your Account with a third party service (including logging in to the Application through Facebook), we may collect information through that service. This information varies depending on the service and your privacy settings there, but may include your profile information on that service, your e-mail address, your contacts on that service and your content on that other service.

3. USE

In general, the information that you provide to us or that we collect in connection with the Application or Services is used to respond to requests that you make or to aid us in serving you better. We may use this information in the following ways:

  1. Provide you with the Services: We may use your information to provide you with the Services, including, but not limited to: establish and maintain your account; place ads and content on your device; provide customer support; process or fulfill point redemptions; verify customer information; provide advertising and marketing services. We may use your information to communicate with you about the Application and Services; enforce our Terms and Conditions; respond to issues related to the Services; notify you when Application updates are available and of changes to the Application or Services; improve the Services to deliver a better and more personalized experience.
  2. Direct Advertisements and Content to you: We may direct certain advertisements and content to you so that you are more likely to see advertisements and content that are relevant to you; send offers and promotional materials related to the Services and for other marketing purposes. See About Our Ads for more information.
  3. Maintaining the Quality and Integrity of the Services: We may use your information to undertake activities to verify or maintain the quality of the Services; improve, upgrade or enhance the Application and Services; provide support and security for the Services.
  4. Internal Research for Technological and Product Development: We may use your information to undertake internal research for testing, research, analysis, technological and product development and demonstration. We may use your information to administer contests, sweepstakes and promotions; conduct industry or consumer surveys; analyze use of Services; share it with our affiliates, including to allow our affiliates to market their products and services to you; and other activities to learn about the effectiveness of our Services.
  5. Identifying and Repairing Errors: We may use information to debug, identify and repair errors that impair existing intended functionality within our Application and Services. We may monitor and evaluate internal controls for compliance with service level standards and identify bugs or errors. We may use your information to respond to inquiries or issues about bugs or errors you may be experiencing.
  6. Detecting and Preventing Security Incidents and Fraud: We may use information to detect or prevent security incidents, protect against deceptive, fraudulent or other activity, and prosecute the responsible parties. We also may use information to protect our Application and Services network from fraudulent, abusive or unlawful practices; authenticate individuals; and monitor Application and Services usage for potential fraud, abuse or violations of the S’more Terms and Conditions. We may access or disclose your information to respond to legal investigations; protect and defend our legal rights and property; protect the safety and security of users or members of the public including during emergency circumstances; and comply with the law or legal processes such as court orders and subpoenas. We may also use your information to evaluate internal controls and audits for compliance, including those conducted by our internal and external audit service providers.
  7. Auditing Digital Interactions: We may use information to audit activities related to digital interactions with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors on our website, verifying positioning and quality of ad impressions in our Application and Services, and auditing compliance with this specification and other standards. We may use your location to identify and authenticate you, provide access to our Application and Services, and direct certain advertisements and content. We may also use information collected from Cookies, including location information, to improve our website (as defined below in our Cookie Policy), complete transactions you request, make recommendations and deliver advertising or similar content.

I. ANONYMOUS INFORMATION

We reserve the right to use Anonymous Information for any purpose and disclose Anonymous Information to third parties in our sole discretion. We may create Anonymous Information records from Personal Information by removing or manipulating information that makes the data personally identifiable to you. We use Anonymous Information to analyze usage patterns of the Application and to enhance the content of Services and improve the Application.

We may use and disclose Anonymous Information without restriction.

4. SHARE

Lab465 may disclose information to Third Parties. “Third Parties” are agents, vendors, service providers, suppliers, subcontractors, and independent contractors with whom we have a business relationship. Unless we have your express or implied consent, we will not share or disclose your information outside of S’more or our affiliated Third Parties other than as described in this Privacy Statement. We may disclose information to our affiliated Third Parties to provide the Application and Services that you have requested and for administrative, analytical, and marketing purposes as described in this Privacy Statement.

We may share your information to the following categories of Third Party entities as follows:

Service Providers: We may share your information without your consent with third parties acting as our service providers (“Service Providers”) that perform activities on our behalf, such as assisting in operating the Application and Services; managing our platforms and websites; fulfilling and distributing redemption orders; providing customer support; setting up customer accounts; fulfillment of event and sweepstake prizes; promoting and marketing our Application and Services; and managing our business. Service Providers that receive information are prohibited from using the information for any purpose other than those for which they are permitted by law or they have contractually agreed to; and if they are processing your information, they have agreed to appropriate privacy and security provisions for the type of information shared.

Local, State, or Federal Government Authorities or Other Entities with Legal Authority: We may share certain information, for purposes permitted by law, without your consent such as to prevent fraud; comply with legal requirements; provide emergency assistance; enforce our Terms of Service; protect our rights and property, and in the event of the sale of part or all assets or other corporate reorganization.

5. ABOUT OUR ADS

The Application uses common tracking tools that allow the Application to feature advertisements and content that are relevant to you and usually are presented by our partner advertisers or advertising networks. These ads and content are presented based on your actions on the Application as well as your other online activities. This is called interest-based or behavioral advertising – advertising that uses information collected on an individual’s web browsing or mobile application behavior (including your engagement with advertisements and the Application) in order to target advertising or content to the user based on this behavior. This information is then used to select which advertisements or content are displayed to you on the Application.

If Personal Information is voluntarily provided by you and collected in the Application via an advertisement, that Personal Information is collected and used solely by us or the relevant advertiser, not any network that served the advertisement to the Application.

Lab465 adheres to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising (DAA Self-Regulatory Principles).

You have a choice about receiving interest-based ads and content. See Opting Out for more information.

6. MANAGE YOUR PREFERENCES

I. ACCESSING & CHANGING YOUR ACCOUNT INFORMATION

You may access and change your Account Information directly in the Application. To do this, open the Application, click Settings and then click View Profile.

II. COMMUNICATION PREFERENCES

We may send you e-mails to promote the use of our Services. When you receive those e-mails, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive, by terminating your Account or by contacting us directly at support@smoreapp.co.

Push Notifications

Certain services may give you the option to receive push notifications. In order to serve push notifications, we may need to collect both your IP address and a persistent identifier from your device. You can turn push notifications on or off by modifying the settings within the applicable service, or within your device’s settings.

These choices do not apply to the display of online advertising or the receipt of mandatory service communications that are considered part of the Services, which you may receive periodically unless you close your Account.

III. OPTING OUT

We understand that, at a future date, you may no longer want to have your information collected and used to receive interest-based ads or content on the Application or to have your device’s precise location data collected. If you do not agree to this collection, transfer and use, you may disable location-based services in your device settings. Use of precise location is not required for the Application. However failure to provide it will limit relevant content and functionality of the Application.

The DAA offers AppChoices, a separate choice tool for users to exercise control over the collection and use of data across and through mobile applications for interest-based advertising and other related uses. To exercise choice for participating companies, you can install the DAA’s AppChoices application on your mobile device. Visit here for more information on DAA’s AppChoices tool athttp://youradchoices.com/appchoices.

Nevertheless, without this information, we won’t be able to provide you with enough interesting or relevant content on the Application, which means you will not have a meaningful opportunity to earn points. Therefore, to “opt out” of allowing the future collection, use and transfer of your behavioral information or the device’s precise location information, you must stop using and un-install the Application from your mobile device.

7. STATE CONSUMER PRIVACY RIGHTS

The California Consumer Privacy Act of 2018 (“CCPA”) provides current California residents with specific rights regarding their personal information as defined by the CCPA (“CCPA PI”). Lab465respects the rights of our California resident customers to exercise these rights, including to:

  • Request categories of or the specific pieces of your CCPA PI which we have collected in the previous 12 months in readily usable format, (Right to Access);
  • Review a list of the third parties with which the CCPA PI was disclosed or sold in the previous 12 months, (Disclosure of Personal Information);
  • Request the erasure of your CCPA PI which we have collected, subject to certain exemptions, (Right to Deletion);
  • Opt-out of the sale of CCPA PI, (Do not Sell my Personal Information); and
  • Be free from discrimination for exercising your privacy rights.

I. RIGHT TO ACCESS

You have the right to request that we disclose certain CCPA PI collected about you in the 12 months prior to our receipt of your request. Once we receive your request and verify you as an authorized requestor, we may disclose to you some or all of the following:

  • The categories of CCPA PI we collected about you.
  • The categories of sources for the CCPA PI we collected about you.
  • Our business or commercial purpose for collecting or selling that CCPA PI.
  • The categories of third parties with whom we share that CCPA PI.
  • The specific pieces of CCPA PI we collected about you.
  • If we sold or disclosed your CCPA PI for a business purpose, two separate lists disclosing: sales, identifying the CCPA PI categories that each category of recipient purchased; and disclosure for a business purpose, identifying the CCPA PI categories that each category of recipient obtained.

II. RIGHT TO DELETION

You have the right to request that we delete and direct any service providers that have received that CCPA PI to delete, the CCPA PI about you that we collected and retained, unless an exemption applies. We may deny your deletion request, should the information be necessary for us or our service providers to:

  • Complete the transaction for which we collected the CCPA PI, provide a 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.
  • Exercise free speech ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546seq.).
  • 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.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

III. DO NOT SELL MY PERSONAL INFORMATION

In the preceding twelve (12) months, we may have shared, disclosed, or transferred your CCPA PI collected through the Application.

In the preceding twelve (12) months, we may have shared, disclosed, or transferred your CCPA PI collected through our website’s Cookies to our third party advertisers. If you would like to manage your Cookie Preferences or opt-out of the sharing of your CCPA PI collected via Cookies, you can do so at http://www.smoreapp.co. For more information on Cookies, please refer to our Cookie Policy.

IV. DESIGNATED METHODS FOR SUBMITTING CCPA PRIVACY RIGHTS REQUESTS

Right to Access

Note: When you make this request, we will send you a link to a ZIP archive which contains a CSV file. This CSV file will contain a copy your information.

To request the specific pieces of your CCPA PI which we have collected in the previous 12 months in readily usable format:

  1. Open the S’more Application
  2. Click ‘Settings’
  3. Click ‘Privacy’
  4. Click ‘Download Your Information‘
  5. Specify where to send the link to the ZIP archive.
  6. Click ‘Send’
  7. Access the link, open the ZIP archive and then the CSV file.

Disclosure of Personal Information

To review a list of the third parties with which the CCPA PI was disclosed or sold in the previous 12 months:

  1. Open the S’more Application
  2. Click ‘Settings’
  3. Click ‘Ad Partners’

Right to Deletion

To request the erasure of your CCPA PI which we have collected, subject to certain exemptions:

  1. Open the S’more Application
  2. Click ‘Settings’
  3. Click ‘Privacy’
  4. Click ‘Delete Your Account‘
  5. Click ‘Delete’

Do not Sell my Personal Information

To opt-out of the sale of CCPA PI, you must uninstall or delete S’more. To delete S’more:

  1. Open the S’more Application
  2. Click ‘Settings’
  3. Click ‘Privacy’
  4. Click ‘Delete Your Account‘
  5. Click ‘Delete’

V. AUTHORIZED AGENTS

You may designate an agent to submit requests on your behalf. The agent can be a natural person or a business entity that is registered with the California Secretary of State.

Authorized Agents are required to verify your identity by providing us with certain Personal Information as described above, depending on whether you hold an account with us and the nature of the information you require, which we will endeavour to match the information submitted to information we maintain about you. Additionally, we will require that you provide us with written confirmation that you have authorized the agent to act on your behalf, and the scope of that authorization. The agent will be required to provide us with proof of the agency relationship, which may be a declaration attesting to the agent’s identity and authorization by you to act on their behalf, signed under penalty of perjury.

If the agent is a business entity, it will also need to submit evidence that it is registered and in good standing with the California Secretary of State.

Information to identify and verify your agent can be submitted via email to support@smoreapp.co. Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with California law pertaining to powers of attorney.

VI. RIGHT TO NON-DISCRIMINATION

Lab465 does not discriminate against you for exercising any of your rights. If you exercise your rights, 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, to earn the points and qualify for rewards available within this Application, you must agree to share your information as described within this Privacy Policy. The financial incentive we offer is reasonably related to the value of your CCPA PI to us, as determined by Lab465, and is described our Terms of Service and within the Application.

If you wish to opt-out of any financial incentives or the selling or sharing of your Personal Information by us, third party advertisers, or our third-party survey partners, please UNINSTALL and DELETE this Application.

VII. CALIFORNIA CIVIL CODE SECTION 1798.83

California Civil Code Section 1798.83 permits the users of the Application who are California residents to request and obtain from us a list of what Personal Information (if any) we disclosed to third parties for their direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge.

If you are a California resident and would like to make such a request, please submit your request in writing to Lab465 at the following address:

Lab465, LLC
Attn: Director, Privacy and Legal Counsel
8410 W. Bryn Mawr Ave
Chicago, IL 60631-3486

8. COOKIE POLICY

The S’more website (http://www.smoreapp.co/) uses cookies, web beacons, pixels, and other tracking technology (collectively “Cookies”). This Cookie Policy describes the information we collect through Cookies, how we use it and how you can manage your Cookie Preferences.

This Cookie Policy applies to the S’more website located at http://www.smoreapp.co/. By continuing to access or use the S’more website, you agree to our use of Cookies. The S’more website uses Cookies and any device which interacts with our website will receive them. S’more may work with third parties to place S’more advertisements on their websites and place Cookies in your browser when you visit their websites.

I. WHAT ARE COOKIES?

A Cookie is a small text file sent to and stored on your internet connected device to identify your browser or store information. A first party Cookie is set up by the website being visited by the user. A third party Cookie is set up by a domain that is not the entity hosting the website. Cookies are widely used to make websites work, work in a more efficient way, and identify and track users.

Web beacons are small graphic images that works with Cookies to monitor web usage, link web pages to servers, interact with emails, and personalize advertising.

II. WHY DO WE USE COOKIES?

S’more and our third parties may use Cookies on our website to improve our website and provide you with the best possible experience. We may use Cookies to enable your navigation of our website and use its features; deliver advertising that is more relevant to you and your interests; monitor the number of times you see an advertisement; measure the effectiveness of an advertising campaign; remember choices that you make; personalize your experience; and monitor web site performance. The information we collect from Cookies also may allow us to identify you across devices, such as smartphones, tablets, computers or related browsers.

S’more may allow third parties to place their Cookies on our websites or within our advertisements. And, your web browser may request advertisements directly from independent third party advertising network servers which do not have a business relationship with us. These advertisements may place Cookies that can view, edit, or set third party Cookies, just as if you had requested a web page from the third party site. S’more is not responsible for the practices, including the use of Cookies, employed by third party websites, mobile applications or online services linked to or from our website, or for the content contained therein.

Third party websites, mobile applications, and online services that you can access on the Internet are outside the control or limits of this Cookie Policy.

III. HOW CAN I MANAGE MY COOKIE PREFERENCES?

To provide you with the best possible website experience, we use different types of Cookies. We categorize these Cookies as follows:

Cookie Type Description Can these cookies be disabled
Strictly Necessary Essential in order to enable you to navigate the website and use its features, such as accessing secure areas of the website. No.
Marketing Used to deliver advertising that is more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. Yes.
Personalization Allows the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For example, a website may be able to provide you with local weather reports or traffic news by storing data about the region in which you are currently located. Yes
Analytics Provides information about how a web site performs, how each page renders, and whether there are technical issues on the web site to the web site operator. This storage type generally doesn’t collect information that identifies a visitor. Yes.

You can manage your Cookie Preferences on our website by either interacting with our cookie banner or by clicking on the cookie icon in the lower right-hand corner of the website.

IV. HOW CAN I STOP MY INTERNET BROWSER FROM TRACKING MY INFORMATION?

Most web browsers accept Cookies by default. Depending upon your computer and mobile devices, you may be able to set your web browser to control Cookies. If you do not want to receive Cookies, you may adjust your web browser’s settings to reject or delete Cookies. To do so, please follow the instructions provided by your web browser, which are usually located within the “Help,” “Tools,” or “Edit” menus. Deleting or rejecting Cookies may impact your ability to effectively interact with our website, third party websites or advertisements or otherwise limit your experience.

As a company that follows the DAA Self-Regulatory Principles, we support the position taken by the DAA that many browsers’ default settings are set by their manufacturers and, therefore, do not represent the preferences of consumers. However, you may exercise your preferences as described in this Cookie Policy, including through the use of your web browser settings, blocking cookies and taking advantage of the DAA’s AppChoices tool at http://youradchoices.com/appchoices.

Please note that the S’more website does not respond to web browser “Do-Not-Track” signals.