Effective Date: September 5, 2023
We value the privacy of our customers’ information and we are always striving to make our customer experience better. This Privacy Policy (the “Policy” or “Privacy Policy”) describes our information practices and, in particular, how we collect, use and share the Personal Information that we gather through our website (“Site”) and our Services, as defined below. If you have any questions about this Privacy Policy or our information practices, please contact us through the options provided below.
This Privacy Policy tells you how we use the personal information collected. For purposes of this Privacy Policy, personal information means data classified as personal data, personal information, personally identifiable information, or similar terms under applicable data privacy and security laws. It does not include data that is excluded or exempted from those laws and regulations, such as aggregated, anonymized, or deidentified data.
Please read this Policy before using the site or submitting any personal information. By providing your information through this site or other program sites, mobile entry or offline, you are accepting the practices described in this Policy. These practices may be changed, but any changes will be posted and changes will only apply to activities and information on a going forward, not retroactive basis. You are encouraged to review the Policy whenever you visit the site to make sure that you understand how any personal information you provide will be used.
BY USING OUR SERVICES, YOU CONSENT TO THE INFORMATION PRACTICES AND OTHER TERMS AS DESCRIBED IN THIS PRIVACY STATEMENT.
Who We Are
Arrowhead Promotion & Fulfillment Co. Inc. (Arrowhead) is a provider of Sweepstakes, Rebates, Premiums, Sampling, Loyalty Programs and other Promotion-related Fulfillment Management Services as well as Customer Support Services (the “Services”). We manage and execute these promotions and programs on behalf of our clients’ businesses. Many of these programs include the gathering of personally identifiable information as a requirement of consumer or business participation. This Policy does not govern any information we collect on behalf of those clients, and you should consult their privacy policies to become familiar with their data collection and usage practices.
Categories of Personal Information We Collect
The following list describes the categories of personal information we may collect.
How We Use and Share Personal Information
We reserve the right to collect, use, or share personal information for the following purposes:
How We Use Cookies and Other Tracking Technologies
We may send one or more cookies to your computer or other device. We may also use other similar technologies such as tracking pixels, tags, or similar tools when you visit our Services. These technologies can collect data regarding your operating system, browser type, device type, screen resolution, IP address, and other technical information, as well as navigation events and session information as you interact with our Services. This information allows us to understand how you use the Services.
What Are Cookies?
Cookies are small files created by websites, including our Services, that reside on your computer’s hard drive and that store information about your use of a particular website. When you access our Services, we use cookies and other tracking technologies to:
We set some cookies ourselves and others are set by third parties. You can manage your Cookies preference as described in the “Managing Your Cookies” section below.
What Types of Cookies Do We Use and Why?
| Types of Cookies | Purpose | Who Serves (for example) |
| Essential | These cookies are required for the operation of our Site and enable you to move around our Site and use its features. Disabling these cookies can negatively impact the performance of our Site. | Arrowhead |
| Functionality | These cookies are used to recognize you when you return to our Site. This enables us to personalize content for you and remember your preferences. These cookies also enable your interactions with our Site such as emailing us and customer support chat. | Vimeo |
| Analytics, Performance, and Research | These cookies, beacons, and pixels allow us to analyze activities on our Site. They can be used to improve the functioning of our Site. For example, these cookies recognize and count the number of visitors and see how they move around our Site. Analytics cookies also help us measure the performance of our advertising campaigns to help us improve them and to optimize the content on our Site for those who engage with our advertising. | |
| Social Networking | These cookies are used to enable you to share pages and content that you find interesting on our Services through third-party social networking and other websites. These cookies may also be used for advertising purposes. | YouTube
|
| Advertising | These cookies and pixels are used to deliver relevant ads, track ad campaign performance, or track email marketing. |
We do not use analytical tools in a manner that discloses to third parties that a specific person viewed specific video materials.
How Long Do Cookies Stay on My Device?
Some cookies operate from the time you visit the Services until the end of that particular browsing session. These cookies, which are called “session cookies,” expire and are automatically deleted when you close your Internet browser.
Some cookies will stay on your device between browsing sessions and will not expire or automatically delete when you close your Internet browser. These cookies are called “persistent cookies” and the length of time they will remain on your device will vary from cookie to cookie. Persistent cookies are used for a number of purposes, such as storing your preferences so that they are available for your next visit and to keep a more accurate account of how often you visit the Services, how your use of the Services may change over time, and the effectiveness of advertising efforts.
Managing Your Cookies
It may be possible to block cookies by changing your Internet browser settings to refuse all or some cookies. If you choose to block all cookies (including essential cookies), you may not be able to access all or parts of the Services.
You can find out more about cookies and how to manage them by visiting https://www.aboutcookies.org.
Does the Site Respond to “Do Not Track” Signals?
At this time, our Site does not respond differently based on a user’s Do Not Track signal.
California Privacy Rights
If you are a California user, you have certain rights with respect to the collection, use, transfer, and processing of you “Personal Information,” as defined by the California Consumer Privacy Act (“CCPA”). We reserve the right to limit these rights where permitted under applicable law, including where your identity cannot be reasonably verified or to the extent your rights adversely affect the rights and freedoms of others. To exercise any of the rights below, please contact us via the contact information below. Only you or a person that you authorize to act on your behalf may make a verifiable consumer request related to your personal information.
Collection of Personal Information
Over the previous 12 months, we may have collected the following categories of Personal Information:
| Category | Examples | Collected | Retention Period |
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. | YES | Duration of the relationship or as required by law |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some Personal Information included in this category may overlap with other categories. |
YES | Duration of the relationship or as required by law |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | NO | N/A |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES | Duration of the relationship or as required by law |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO | N/A |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | YES | 26 months |
| G. Geolocation data. | Physical location or movements. | YES | 26 months |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | YES | Duration of the relationship or as required by law |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | NO | N/A |
| J. Non-public education information | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO | N/A |
| K. Inferences drawn of the consumer. | Inferences drawn from Personal Information identified above to create a profile about a consumer reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | YES | 26 months |
| L. L. Sensitive Personal Information | Personal information that reveals (a) Social Security, driver’s license, state identification card, or passport number; (b) account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credential allowing access to an account; (c) precise geolocation; (d) racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; or (f) genetic data.
Biometric information processed for the purpose of uniquely identifying a consumer, personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation.
Some Sensitive Personal Information included in this category may overlap with other categories. |
NO | N/A |
The examples listed above are illustrative only and do not reflect the specific pieces of information that Arrowhead has collected in the previous 12 months.
Categories of Sources From Which Personal Information Is Collected
We collect the personal information in categories A(identifiers), B (personal), and D (commercial) based on your use of the Services. We collect personal information in categories F (Internet and other electronic network activity), G (Geolocation), and K (inferences) based on your interactions with our Site and mobile apps.
Business or Commercial Purposes for Which Personal Information Is Collected
Your Personal Information is used for the following purposes:
Third Parties With Whom Personal Information Is Disclosed, Shared, or Sold
Arrowhead discloses your Personal Information with analytics and service providers, benefits providers, transaction processors, and law enforcement (if necessary). We may also disclose content posted on our social media platforms (e.g., if a consumer “comments) with other consumers. Such posts may include personal information in categories A and B, but the content depends on the individual posts.
In the preceding 12 months, we have shared for cross-context behavior advertising the following the personal information in categories A (identifiers), B (personal), D (commercial), F (internet), G (geolocation), and K (inferences).
In the preceding twelve (12) months, we have not sold the personal information of any consumer for monetary consideration. However, our use of cookies and other tracking technologies may be considered a sale of personal information under the CCPA. Categories of personal information that we have sold under the CCPA include categories A (identifiers), B (personal), D (commercial), F (internet), G (geolocation), and K (inferences). Categories of third parties to whom personal information is sold under the CCPA include data analytics providers and advertising and marketing providers.
You can opt out of our tracking technologies for analytics and advertising service providers by clicking the Your Privacy Choices link. Please note that your use of our website will still be tracked by Arrowhead and its service providers.
We do not have actual knowledge that we sell or share the personal information of consumers under sixteen (16) years of age.
Individual Rights
Right to Know About Personal Information Collected, Disclosed, or Sold
You have the right to request that Arrowhead disclose the Personal Information it collects, uses, and discloses about you to third parties. There are two types of Right to Know requests that you can make:
This information will be provided to you free of charge, unless Arrowhead determines that your request is manifestly unfounded or excessive. You may request this information twice in a 12-month period.
There are certain exceptions to a consumer’s Right to Know, including exceptions relating to employment information and information processed as a service provider. Arrowhead will state in its response if an exception applies.
Right to Data Portability
You have the right to obtain your personal data in a portable and—to the extent technically feasible—readily usable format that allows you to transmit the data to another entity without hindrance.
Right of Deletion
You have the right to request that Arrowhead and our service providers delete any Personal Information about yourself which Arrowhead has collected from you upon receipt of a verifiable request. This right is subject to certain exceptions, including exceptions relating to employment information and information processed as a service provider. Arrowhead will state in its response if an exception applies.
Right to Correct
If we maintain inaccurate Personal Information about you, you have the right to request that we correct these inaccuracies. After receiving notice of these inaccuracies, we will make reasonable efforts to correct your Personal Information throughout our systems and networks.
Right to Opt-Out of the Sale of Personal Information
You have the right to opt-out of the sale of your personal information by a business subject to certain laws and regulations.
Please note that opt-out choices may be stored via cookies. If you clear cookies, if your browser blocks cookies, or if you view the page from a different browser or device, your opt-out choice may no longer be logged or recognized.
For more information, please visit our Your Privacy Choices page.
Right to Non-Discrimination
You have the right not to receive discriminatory treatment for exercising the privacy rights conferred by California law. Arrowhead will not discriminate against you because you exercised any of your privacy rights, including, but not limited to, by: denying goods or services to you; charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing a different level of quality of goods or services to you; or suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Submitting Requests
If you have a request related to information submitted in connection with a promotion, Arrowhead suggests that you submit that request directly to the business holding the promotion. As Arrowhead is only a service provider for those promotions, we may only be able to direct you to that business if you submit the request directly to us. To submit a request to us, please see our Data Subject Request page. You may also contact us at (800) 950-9914, or via email at [email protected].
Verifying Requests
Arrowhead provides California consumers with an online web form to submit requests. The web form is accessible at https://apfco.com/secured/wprivacy/. As stated in the web form, Arrowhead must verify that the person requesting information or deletion is the California consumer about whom the request relates in order to process the request. To verify a California consumer’s identity, we may request up to three pieces of Personal Information about you when you make a request to compare against our records. We may also request that you sign a declaration under the penalty of perjury from the consumer whose personal information is the subject of the request.
Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in your request to verify your identity and will delete any information you provide after processing the request. Arrowhead reserves the right to take additional steps as necessary to verify the identity of California consumers where we have reason to believe a request is fraudulent.
Authorized Agents
You may choose a person that you authorize to act on your behalf to submit your requests (“Authorized Agent”). If you choose to use an Authorized Agent, Arrowhead requires that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with Arrowhead. Failure to do so may result in Arrowhead denying your request.
Privacy Contact Information
If you have any questions, concerns, or comments about our privacy policy or your California privacy rights, you may contact us at (800) 950-9914, or via email at [email protected] or via the Site at https://apfco.com/secured/wprivacy , or via mail at Attn: Privacy Dept., 1105 SE 8th St. Grand Rapids MN 55744.
We reserve the right to make changes to this policy at any time.
Arrowhead’s industry-leading technology, along with our deep expertise and proven systems and processes, enables us to advance our clients’ objectives efficiently and cost-effectively across service areas, including Promotion & Fulfillment; Rebates, Coupons, Sweepstakes, Games and Contests; Loyalty & Continuity services; B2B Sales Incentives and Contact Center services.
Call: 218-327-1165
Email: [email protected]
Location: 1105 SE 8th Street
Grand Rapids, MN 55744
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