Privacy Policy

Privacy Policy

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.

• Analytics Information. We may collect certain analytics information automatically as you navigate our Services.  This includes cookies, tracking pixels, tags or similar tools, which may collect information about your browser, device, geolocation, and interactions with the Services, Site, or emails.  For more information, please view the “How Do We Use “Cookies” and Other Tracking Technologies?” section below.
• Contact Information includes name, company information, email address, and phone number. We may collect this information when you provide it directly to us such as filling out a form.
• Commercial Information includes name, company information, payment information, and other information we collect from our clients to provide our Services.
• Social Media Information includes information that you post by sharing on a blog or another social media platform. We collect this information when you provide it directly to us.  Please note that your comments will be visible to the public, so you should never share personal information that you would like to keep private.

How We Use and Share Personal Information

We reserve the right to collect, use, or share personal information for the following purposes:

• Providing the Services. We may use the various types of personal information to provide you with the Services you request.
• Presenting Our Site. We will use personal information to present our Site and its contents in a suitable and effective manner for you and your device.
• Providing Information and Opportunities. We will use your personal information to advertise opportunities, products, or services that we think may be of interest to you or others.
• Customer Service. We will use your personal information to provide you with customer service, troubleshoot issues, and respond to requests, questions, or comments.
• Legal Purposes. We reserve the right to cooperate with local, provincial, state, federal and international officials in any investigation requiring either personal information or reports about lawful of unlawful user activity on this Site.  We also reserve the right to share your personal information to establish, exercise, or defend our legal and property rights, including providing information to others for the purposes of fraud prevention.  We may also share your personal information with any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.If we are ordered by a legal process or government to provide data about one or more individual users, we will notify those users of our compliance with that order, to the extent permitted by law.
• Business Transactions or Mergers. We reserve the right to share your personal information to third parties as part of any potential business or asset sale, merger, acquisition, investment, round of funding, or similar type of transaction.  Additionally, if we are entering into a corporate transaction with a third party, we may receive personal information in connection with the diligence.  If we close a transaction, the third party may transfer personal information, which we would use as described in this Policy.
• Bankruptcy or Insolvency. In the event of bankruptcy, insolvency, or dissolution proceedings, we may share your personal information with third parties as part of the sale or reorganization process.

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:

• Estimate our audience size and usage patterns;
• Store information about your preferences, allowing us to customize our Services according to your individual needs;
• Contact you to provide you with information or services that you request from us;
• Advertise new content, events, and services that relate to your interests;
• Provide you with more personalized content that is most relevant to your interest areas; and
• Recognize when you return to our Services.

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?

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:

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:

• Respond to your requests for services or products
• Provide you with customer support and respond to your communications
• Send you transactional or administrative communications, as well as certain service-related announcements
• Personalize your experience on our Site
• Send you information relating to other programs, services, or products that we believe may be of interest to you
• Run Site analytics to evaluate performance
• Fulfill our responsibilities as an employer
• Other purposes identified in this Policy

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:

• Right to Know (Abbreviated Request): If you make a Right to Know (Abbreviated Request), you will receive the following information about you:
  • Categories of Personal Information collected;
  • Categories of sources from which Personal Information is collected;
  • Business purpose for collecting or selling; and
  • Categories of third parties with who sold.
• Right to Know (Specific Pieces of Information Request): If you make a Right to Know (Specific Pieces of Information Request), you will receive the following information about you:
  • Specific pieces of Personal Information collected about you.

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 PrivacyDept@apfco.com.

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 PrivacyDept@apfco.com 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.