Last updated January 4th 2020
By using any portion of our Services, you agree to the Terms of Service and conditions of this Policy. Please read them carefully.
Information We Collect
When you use our Services, we may collect data from you that generally falls into one of two categories:
“Personal Information” - Personally identifiable information you provide to us when you register for or use any Chulos service, website, or app. This information may include, not limited to, your name, email address, username and account access tokens. If you grant Google and Facebook permission, we may collect your list of contacts including but not limited to your contacts name, and email address and information about your use of coupons and other savings opportunities.
If you download and use our browser extension, we may collect browsing, product and e-commerce information, including but not limited to product pages viewed, pricing information, location data, purchase history on various merchant websites and services, the price you paid for items, whether a purchase was made, and the coupons that you used (including information regarding whether or not a coupon or coupon code is valid or effective). We may also collect information on coupons and other discounts that you found using our Services, even if you do not use such coupons, so that we may share this coupon and discount information with other users.
“Online/Mobile Activity Data” - Data such as your IP address, your browser type and language, and your display/screen settings; data about how you use our website and how you interact with our website and mobile advertisements; data about your mobile device; advertising identifiers; precise location data; social media preferences and other social media data; and other data that may be aggregated and/or de-identified (information that doesn’t identify individual consumers/customers).
How We Collect Information
When You Use or Visit Our Sites
Chulos may collect information about you when you browse our Sites or use our online Services. We may collect Personal Information when you voluntarily provide it to us through our website or in our mobile applications.
When You Grant Gmail Access
Chulos may collect Personal Information when you provide us access credentials or tokens for your email and other merchant accounts.
Chulos systems capture your contacts, in encrypted form. Chulos then applies proprietary logic to identify emails that: (1) appear to be receipts from retailers, online sellers, or merchants engaged in ecommerce (“Merchant(s)”) we monitor; or (2) relate to other potential savings opportunities. The bodies of these select emails are then retrieved, decrypted and reviewed to notify you of potential savings opportunities. Occasionally, we may also decrypt the email header data so that we can make sure our proprietary logic is working properly.
When You Use our Browser Extension
We may automatically record certain information from your device by using various types of technology, including “clear gifs" or “web beacons.” This automatically collected information may include your IP address or other device address or ID, web browser and/or device type, web pages or sites that you visit, order information, the content you view or interact with on our Services, and the dates and times that you visit, access, or use our Services. This information is gathered from all users, and may be connected with other information about you. We may obtain information from third parties and sources outside of Chulos, such as our partners, affiliates, and advertisers. This information may include, but is not limited to, order references.
When You Use Our Social Media Pages
How We Use Information
We may use Personal Information and Online/Mobile Activity Data we have collected for a variety of reasons. For example, we may use this type of data:
We may use email data we have collected (if inbox access is provided) for a variety of additional reasons. For example, we may use this type of data:
We may use browser data we have collected (if browser extension is downloaded) for a variety of additional reasons. For example, we may use this type of data:
Managing Your Online and Mobile Preferences
You provide Personal Information to us on a voluntary basis and are not required to provide it in order to browse our websites.
Online Tracking & Advertising on our Sites or Apps
As you access our online Services over time, cookies and similar technologies such as web beacons allow us to collect information such as browser type, pages visited, preferences, and your relationship with us. Chulos may customize content and advertisements for our products and services on the websites or mobile apps we own. In order to make the content and advertising as informative and useful as possible, we may use information about your relationship with us (such as your network). Currently, for online advertising purposes, our website does not respond to browser “do not track” signals, but these signals may be used for fraud prevention. However, if you choose, you can set your website browser to inform you when cookies are sent or you may choose not to accept cookies. Your decision not to accept cookies could limit access to some of the services and offers that are available on our website. For example, your device may not be recognized when you visit our website. You also may not receive advertising or other offers from us that may be of interest to you.
Some mobile devices come with a non-permanent advertising identifier or ID which gives companies the ability to serve targeted ads to a specific mobile device. In many cases, you can turn off mobile device ad tracking or you can reset the advertising identifier at any time within your mobile device privacy settings. You may also choose to turn off location tracking on your mobile device. By turning off ad tracking or location tracking on your mobile device, you may still see the same number of ads as before, but they may be less relevant because they will not be based on your interests.
If you live in California and use Chulos, you have some additional rights when it comes to your data.
Right to Delete: You can ask us to delete the personal information we have about you.
California law gives you the right to opt out of the sale of your personal information. But Chulos does not and will not sell (or rent, or disclose for value) any of your personal information in the first place. So you’re good.
To exercise any of these rights, you (or your authorized agent) can contact us by email at email@example.com. We will confirm receipt of your request, and will provide a response to you within 45 days of your request, though in some exceptional cases it might take longer (if that happens, we’ll let you know). We will need your name and email address to verify your request, and may also ask for additional information if necessary to verify the identity of the person making the request . Please note that these rights are limited, like for example, where fulfilling your request would adversely affect other individuals or where we have a conflicting legal obligation. That said, we will not discriminate against you for exercising any of these rights.
To learn about the categories of personal information that Chulos uses, please see the section of this policy called “How We Use Information” and “Information We Collect”. The personal information that we have collected in the past 12 months falls into the following categories as set out under California law:
The contact information you provide – California law refers to these as identifiers.
We don’t track your location, but your IP address gives us a general idea of the city, state, and country - what California law calls geolocation.
Shopping and Chulos usage data – California law calls this internet activity
Purchases on retail sites when using Chulos – this is commercial information under California law.
To learn about the limited ways in which we disclose data for our business purposes -- that is, to a service provider -- and the categories of those service providers, please see the section of this policy called “How We Use Information”.
European Union residents
Controller: Chulos is a private company, established in the United States of America. Our contact email address is firstname.lastname@example.org. For the purposes of the General Data Protection Regulation, we are the data controller.
When you consent to our use of your data for a specific purpose.
When we need that data to enact a transaction or to provide you with services and products that you request. This includes personalizing features and protecting the security of Chulos and its users.
When Chulos has a legitimate interest in using that data in the normal ways you’d expect, like ensuring Chulos’s products run properly, improving and creating new products, historical analytics research, promoting Chulos, and protecting our legal rights.
When we need to process your data to comply with a legal or regulatory obligation.
Your rights: EU residents have the following rights with regard to their personal data. To exercise any of these rights, please contact us at email@example.com. Please note that these rights are limited, like for example, where fulfilling your request would adversely affect other individuals or our legal obligations.
Right to Access: You have the right to request information about your personal data that we hold, how we use it, and who we share it with.
Right to Portability: Where you have provided your personal data to us on the basis of your consent, you have the right to ask us for a copy of this data in a structured, machine-readable format and to ask us to send this data to another data controller.
Right to Rectification: You have the right to ask us to correct your personal data where it is inaccurate or incomplete.
Right to Erasure: In certain circumstances, you have the right to ask us to delete the personal data we hold about you.
Right to Withdraw Consent: In situations where we are processing your personal data based on your consent, you may withdraw this consent at any time.
Right to Object to Processing: In situations where we are processing your personal data based on our legitimate interest, you can object that the interest is no longer legitimate. Chulos will stop processing that data, unless we can demonstrate an overriding legitimate ground. You can also request to opt out of direct marketing.
Right to Restrict Processing: You have the right to ask us to stop any active processing of your personal data while we seek to verify data you claim is inaccurate, while we verify our legitimate interests, or while we cannot erase that data due to legal obligations.
Chulos will try to respond to these requests within 30 days, but some might take longer. You will typically not be charged any fee for effecting these rights, but Chulos reserves the right to charge a reasonable fee (or refuse to comply) if the request is unfounded, repetitive, or excessive.
Complaints: In the event that you wish to make a complaint about how we process your personal data, please contact us at firstname.lastname@example.org and we will do our best to resolve it. You can also choose to file a complaint with the relevant data protection authority.
If we send you an email advertisement, it will include instructions on how to opt out of receiving such emails in the future. If you are a customer and you elect to opt out of receiving email advertisements, we may still send you emails about your Chulos account. To opt out of receiving email advertisements, you may submit your request to email@example.com. If your name was previously selected for any of our upcoming email offers, it is possible for you to receive information from Chulos up to 10 business days after your request has been submitted. If you receive an email that claims to be from us but you are not sure, or if you think it is suspicious, do not click on any of the links in the email. Instead forward it to us at firstname.lastname@example.org then delete it.
Updating Your Information
Keeping your account information up-to-date is very important. You may access, review, update, correct or delete certain account information or close your account by logging into your account online. If you cannot change the incorrect information online, please contact us at email@example.com. We may retain cached or archived copied information about you for a certain period of time and as required by applicable law.
Protecting Children’s Online Privacy
Chulos encourages protection of children’s information on the internet. Our service is not intended for, nor targeted toward, children under the age of thirteen (13). We do not knowingly collect personal information as defined by the Children’s Online Privacy Protection Act (COPPA) from children under age thirteen (13). If you are a child under the age of thirteen (13), you are not permitted to use our Services and should not send any information about yourself to us through the Services. If you are a parent or guardian and believe a child has provided us information, please contact us at firstname.lastname@example.org. Please refer to the FTC’s website.
Our websites may include links to third-party websites. These third parties are not subject to this Policy, or to the Chulos Terms of Services when you visit a third-party website, you should review its privacy notice.
At Chulos, we make your safety and security a top priority and are committed to protecting your personal information. If we collect identifying information from you, we will protect that information with controls based upon internationally recognized security standards, regulations, and industry-based best practices.
Chulos maintains customer authentication procedures to protect your personal information and account from identity theft. These procedures are for your protection. If you suspect a website is pretending to be a Chulos website (also known as “spoofing”) do not enter personal information but instead contact us at email@example.com.
Changes to this Policy
This Policy describes Chulos’s current online privacy practices. Chulos may change its online privacy practices in the future and we may revise this Policy to reflect material changes.