LAST UPDATED: November 13, 2024
PLEASE READ THIS PRIVACY POLICY CAREFULLY
This Privacy Policy describes how CLYNK and its affiliates and subsidiaries (collectively, “CLYNK,” “we,” “us,” and “our”) collects, processes, and shares your personal information, and the choices that are available to you with respect to your personal information. This Privacy Policy applies to the personal information we collect whenever you interact with us, whether those interactions are online – for example, when you use any of our websites, including www.clynk.com and ct.clynk.com (referred to individually and collectively as the “Website”), use our mobile application (the “App”), or use our kiosks or other CLYNK hardware or software, in each case, only to the extent the Website, App, or hardware or software link or point to this Privacy Policy (all of the foregoing referred to collectively herein as the “Platform”), or when you communicate with us via email, click on our digital advertisements, or scan our QR codes. This Privacy Policy also applies to the personal information we collect offline, for example, when you communicate with our customer service teams by phone or postal mail, and that we obtain from third-party sources. In this Privacy Policy, we refer to the services we provide both online and offline as “Services”. If you do not agree with this Privacy Policy, please do not use our Platform or Services.
We may revise this Privacy Policy periodically, and in such a case we will revise the date at the top of this Privacy Policy accordingly. Changes to this Privacy Policy are effective at the time they are published, and therefore we encourage you to review this Privacy Policy from time to time. Additionally, this Privacy Policy may be supplemented or amended from time to time by other notices posted elsewhere, including on specific pages of our Website, in our App, at our kiosks and facilities, or in our published materials.
1. Personal Information We Collect
The personal information we collect depends on how you interact with us, and may include some or all of the following categories of information:
- Name and Contact Information: We will collect your name and contact information, including your postal address, telephone number, and email address if you provide it to us, including when you create an account on our Platform.
- Device Information: When you visit our Platform, interact with our digital advertisements or scan our QR codes, or open our emails, we may learn information about your browser or device (e.g., name or type, version, settings, etc.), IP address, unique online identifiers (e.g., MAC address, mobile device identifiers, etc.), internet service provider, the name and version of your operating system, referring and exit pages, and the date and time of your visit.
- Usage Data: We may collect information about your interactions with our Platform, digital advertisements, QR codes, and emails, including the pages you visit, links or buttons you click, the search terms you enter, and similar information.
- Location Data: We may infer your non-precise geographic location from your device’s IP address or similar device information collected when you visit our Platform, interact with our digital advertisements, scan our QR codes, or open our emails. We may also collect precise geolocation information; for more information about our collection of precise geolocation information, please see the How We Collect Your Personal Information > Mobile Location Information section below.
- Financial Account Information and Payment Details: We collect your financial account information and other payment details when you provide them as part of our Services.
- Transactional and Commercial Data: We keep track of your transactional history with us, including the types and quantity of bottles and cans you return to us and the amount of associated redemption payments, and the organizations to which you choose to direct your deposit proceeds (if any). We may also collect other commercial information about products or services that you have used, purchased, or considered.
- Records of Communications: If you call or email our customer service representatives (or other agents or representatives of CLYNK) or reach out to us via a social media platform, we may keep records of those conversations including any information you have provided to us in connection with such conversations.
- Submitted Content: We collect any content you submit to us, including via the Website, the App, our social media pages, email, or postal mail, such as photos, videos, testimonials, and feedback.
- Demographic Information: We may collect demographic details about you such as your age, gender, race or ethnicity, marital status, level of education, employment information, political affiliation, and other similar demographic details.
- Account Credentials: If you register an account on our Platform, we collect your account credentials, including your account log-in name and password.
- Video Recordings: We use video cameras (i.e., CCTV) in and around our redemption facilities for security purposes and to prevent fraud, theft, and vandalism.
- Inferences: We may draw inferences about any of the information above that may relate to your preferences, characteristics, or other matters.
CLYNK may also de-identify or aggregate the above information, at which time it is no longer “personal information.” We will not reidentify or attempt to reidentify such information unless permitted by applicable law.
2. How We Collect Your Personal Information
We may collect the information described above from various sources, including directly from you, from third parties we partner with, and through cookies or other automated means.
- Directly from You: We collect information directly from you when you provide it to us, including when you create a CLYNK account; redeem your bottles and cans; contact us with questions or comments via email, phone, postal mail, or on our social media pages; fill out and submit any webforms on our Platform, or otherwise upload Submitted Content to our Platform (or submit it via email, postal mail, or social media); enter our contests, sweepstakes, or other promotions; or respond to a survey or other request for feedback.
- Automatically from Your Device or Browser: Certain information (e.g., Device Information and Usage Data) may be automatically collected from your device or browser when you interact with our Platform, open our emails, click on our digital advertisements, or scan our QR codes.
- CLYNK Kiosks. We may collect your personal information from the technology we use in our facilities, including. For example, our point-of-sale terminals process your credit card information when you complete your purchase, and we operate in-store cameras for security and operational purposes. These cameras may capture images of you as part of checkout, to help deter theft, or improve store design to better serve our customers.
- From Third-Party Service Providers and Business Partners: Third parties, including data analytics companies, advertising and marketing companies, commercial data providers, shipping and delivery companies, email service providers, and companies that assist with the operation and functionality of our Platform and our business more generally, may share information they have collected from or about you with us. We may also obtain personal information about you from third-party commercial data providers.
- Using Cookies and Similar Technologies: CLYNK uses cookies (small files stored on your device or browser), pixel tags (tiny graphic images embedded in a website or email), and other similar technologies to automatically collect information when you visit our Platform or interact with our emails or digital advertisements, including, for example, Device Information, Usage Data, and Location Data. Through the use of cookies and similar technologies, we may link information about your interactions with our Platform, emails, digital advertisements, and QR codes over time, like which pages you visit, which links or buttons you click, and how long you stay on each page.
We also partner with third-party advertising, marketing, and data analytics companies (including certain social media advertising partners) that use cookies or similar technologies to collect information about your interactions with our Platform, emails, and digital advertisements, and your interactions with other websites and digital platforms, and that may use and share the information gathered to deliver ads more tailored to your interests (sometimes referred to as “targeted advertising”). We receive information from these third parties to understand our advertising effectiveness and to understand the operation, functionality, and use of the Platform. The collection and use of your information by each of these third parties is governed by such third party’s privacy policy. For example, the collection and use of your information by our data analytics provider, Google Analytics, is governed by Google’s privacy policy, which can be found here.
- Mobile Location Information: If you use a mobile device, your device may share location information (when you enable location services) with our Platform. For example, precise geolocation information (e.g., a GPS signal) can be used to help you find nearby CLYNK facilities, and our use of your device’s blue tooth signal (or other similar technologies) will permit CLYNK to recognize the location of your mobile device near our facilities. To manage your device’s location settings, go to the Your Privacy Choices section of this Privacy Policy.
- Cameras: As noted above, we use cameras in and around our facilities for fraud detection, theft prevention, and security.
- Information from Other Sources: We may collect information about you from other sources, including from publicly available sources and from third-party commercial data providers, to enhance our existing customer database and improve the accuracy of our records.
3. How We Use Your Personal Information
How we use the personal information we collect depends on how you interact with us, and may include the following purposes:
- Perform Redemption Services: We use your personal information to perform our redemption services, including, for example, to process your bottles and cans, add redemption funds to your CLYNK account, and donate your redemption funds to the organization of your choice.
- CLYNK Accounts: We use your personal information to operate CLYNK accounts, including by making certain services available and offering rewards or special promotions to our account users.
- Communications: We use your personal information to communicate with you, including to respond to your customer service inquiries and other requests for information, and to ask for feedback through surveys, testimonials, or other messages.
- Advertising and Marketing: We use your personal information to advertise and market our Services online, via email and direct mail, and through other communication channels, including through partnerships with social media platforms and internet search engines.
Targeted Advertising. As noted above, CLYNK participates in targeted advertising, meaning we use third-party advertising companies to display online ads tailored to your individual interests based in part on the personal information collected via cookies and similar technologies when you browse and shop online. Those companies may also use your personal information to provide us with advertising-related services such as ad delivery, reporting, attribution, analytics, and market research.
Feedback and Reviews. If you choose to provide feedback, testimonials, or other materials to us, we may use such content and materials for advertising and marketing purposes and to help us improve our Services, and to develop new products and services.
- Understanding Our Customers and Improving Our Platform and Services: We use your personal information to analyze your activity with us (including your interactions with our Platform, emails, digital advertisements, or other forms of communication). For example, we may keep track of the pages of our Website that you visit, or the manner in which you use the App or our kiosks, in order to determine whether to make changes to our Platform or Services, or develop new Services. We may also use your information and the information of other customers (including information about the bottles and cans redeemed) to help us analyze trends, purchasing patterns and preferences, and demographics. We may create and publish industry or market reports or other products (e.g., reports that analyze consumer consumption trends) using this information, but such reports will include only de-identified or aggregated information.
- Personalization and Recommendations: We may use your personal information to personalize your experience when using our Platform and make recommendations about products and promotions that we believe you may be interested in.
- Promotions: We may use your personal information to run contests, sweepstakes, or other promotions.
- Security: We use your personal information to protect CLYNK, our business partners, and our customers from fraud, security threats, and other illegal or harmful activity.
- Legal Obligations: We use your personal information to comply with legal and regulatory requirements and to respond to requests from courts or other governmental or regulatory authorities.
4. How We Share Personal Information with Third Parties
We may share information with third parties for certain purposes. For example, we may share information with:
- Service Providers: We partner with third-party service providers (which may include CLYNK affiliate companies) to assist with many aspects of our business, including payment processing, analyzing our Platform users’ interests and activities and consumer trends, advertising and marketing services, providing certain functionalities on our Platform, helping us communicate with our customers, and operating our business more generally, and we may share your personal information with these service providers in connection with the provision of their services.
- Business Partners: We may disclose your personal information to businesses that we have partnered with to jointly offer a product, service, or promotion (e.g., a grocery or department store where our kiosks and facilities are located). For example, if you agree to link your CLYNK account with a loyalty or rewards program of a CLYNK business partner, then we may disclose certain identifying personal information to that business partner. We may also share your personal information with business partners, such as market research and information companies, that are interested in understanding consumers’ purchasing patterns and preferences and that may create datasets, perform market research, or create business intelligence or information products that analyze and monitor consumer trends, or with business partners that wish to market their own or other businesses’ products and services to you. The use and sharing of your information by our business partners is not governed by this Privacy Policy but by their own respective privacy policies.
- Successors: We may transfer your information in connection with the potential or actual sale, lease, license, assignment, acquisition, merger, reorganization or change of control of CLYNK, in whole or in part, or as part of a bankruptcy proceeding.
- Other Third Parties: We will disclose information about you to third parties, including to government bodies or law enforcement agencies, when we believe it to be necessary for compliance with the law or to protect CLYNK, our customers, our employees, or the public more generally. For example we may disclose specific personal information if we reasonably believe it is necessary to: (i) investigate any suspected fraud or misuse of the Platform; (ii) protect or defend the rights, property, or interests of CLYNK, our employees, our customers, or the rights, property, or interests of our business partners or service providers; or (iii) protect the personal safety of our employees, customers, or the public.
- At Your Request: We will disclose information about you to other third parties at your direction or with your consent.
5. Your Privacy Choices
- User requests: You can contact us at any time via email at privacy@clynk.com to request we do any of the following: (i) delete all or some of your personal information; (ii) change, update, or correct your personal information; (iii) restrict how we use all or some of your personal information; (iv) access your personal information and, where applicable and feasible, request to receive that personal information in a commonly used electronic format (or ask for this information to be provided in that format to a third party); or (v) disclose what personal information we collect, use, or disclose. You may also request that we stop sharing your personal information with third parties for certain purposes. We will consider and respond to any such requests promptly, and otherwise in accordance with applicable laws.
- Emails: You can unsubscribe from our marketing emails by clicking the unsubscribe link in the footer of such emails.
- Direct Mail: You can request that we remove you from our direct mail mailing list by emailing us at privacy@clynk.com.
- Cookies:
Browser and Industry Opt-Outs. You may opt out of certain third-party cookies by following your browser’s instructions or by using the opt-out tools provided by the following industry groups:
- Digital Advertising Alliance (DAA): http://www.aboutads.info/choices/
- Network Advertising Initiative (NAI): http://optout.networkadvertising.org
Please note that online cookie opt-outs are device and browser-specific. You may still see targeted advertising from us when using a different device or browser, unless you also opt out using that device or browser.
Furthermore, if you opt out of our cookies, you may experience some inconvenience in your use of the Website.
7. Children
We do not knowingly or purposefully request or collect personal information from any person under the age of 13. If you believe that your child under the age of 13 has submitted personal information to CLYNK, please contact us at privacy@clynk.com.
8. Security
Although we use reasonable safeguards to protect your personal information, we cannot guarantee the security of information provided over the Internet or stored in our databases. Your transmissions are, therefore, at your own risk. You can help protect your information by selecting strong, unique passwords for your account on CLYNK Website and any associated email addresses.
9. Retention
We will retain your personal information for the length of time needed to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.
10. Links to Other Websites; Social Media Platforms
Our Website and App may, from time to time, contain links to websites and applications owned and operated by third parties (“Third-Party Platforms”). We encourage you to review the privacy policies of such Third-Party Platforms so that you understand how those websites and applications collect, use, and share your information. We are not responsible for the privacy policies or other content on Third-Party Platforms.
If you engage or communicate with CLYNK on a social media platform (e.g., Instagram, Facebook, Pinterest, TikTok, etc.), we may contact you via direct message or use other social media tools to interact with you. In these instances, your communications and interactions with us are governed by this Privacy Policy as well as the privacy policy of the social media platform you use.
11. Contact Us
We welcome your comments and questions. Please contact us by email at privacy@clynk.com, by phone at 1-888-991-1535, or by mail at the following address:
Count & Crush, Inc. dba CLYNK
100 Waterman Drive, Suite 301,
South Portland, Maine 04106