AND INFORMATION PRACTICES STATEMENT
Revised June, 2006
Introduction. We at OutDigit, Lda. ("OutDigit"), recognize the importance of protecting the privacy of Personal Information collected online or offline by us about individuals participating in the Program ("Members" or "you"). This policy also explains when and how we treat Personal Information provided to us by other OutDigit business units and affiliates ("Affiliates").
Information We Collect
Direct Mail/Outbound Telemarketing
What is Individual Specific Information?
What We Won't Do with Customer Information
We Will Do With Customer Information
Compliance with Law
Application. This policy applies
to residents of the United States and to the Program activities
conducted in the United States only. We do not accept the jurisdiction
of any other laws over our activities in the United States.
Purpose. Our purpose in establishing this
policy is to balance our legitimate business interests in collecting and
using Information with our Members' reasonable expectations of privacy.
Our intent is to bring you offers and discounts that we believe are relevant
to your interests. We believe that our Members benefit from promotional
activity based on Member Information employed to market goods and services
offered by and through other OutDigit business units and affiliates ("OutDigit
Brands") third party merchants participating in the Network ("Network
Partners"), and other carefully selected marketing partners ("Marketing Partners").
For more information on our affiliates, check our corporate
Web site, www.outdigit.com.
Security. OutDigit collects Information
only in a manner deemed reasonably necessary to serve our legitimate
business purposes and comply with our legal obligations.
We safeguard our Members’ personally identifiable information
by using industry standard practices. Although “guaranteed
security” does not exist either on or off the Internet, we
make commercially reasonable efforts to make our collection of such
Information consistent with all applicable laws and regulations.
Currently, this OutDigit Web site utilizes a variety of different security
measures designed to protect personally identifiable information
from unauthorized access by users both inside and outside OutDigit,
including the use of 128-bit encryption based on a Class 3 Digital
Certificate issued by Verisign Inc. This allows for utilization
of Secure Sockets Layer, which is a method for encrypting data.
This protects confidential information - such as credit card numbers,
online forms, and financial data—from loss, misuse, interception
We take all commercially reasonable efforts to create and maintain
"fire walls" and other appropriate safeguards to ensure
that to the extent OutDigit and OutDigit controls the Information, the
Information is used only as authorized by OutDigit and OutDigit and consistent
with this Policy, and that the Information is not improperly altered
or destroyed. Our privacy protection practices help us to maintain
accurate, timely, complete and relevant information for our business
purposes. Our communication system, software and database practices
have been designed to aid us in supporting authenticity, integrity
and confidentiality. Although we use commercially reasonable efforts
to maintain data security when data is transmitted through third
party communication service providers, we do not warrant the security
of data during such transmission.
Web sites of all OutDigit Brands and Program Partners,Marketing Partners
and any other third party Web sites that are accessed through links, banners
and other means of electronic connection on this OutDigit Web site have separate
privacy and data collection practices, and security measures. We have
no control over these web sites and no responsibility or liability for
the practices, policies and security measures implemented by such parties
on their Web sites. These web sites have content, advertising, banners,
links, sponsors, partners and connections over which we have no control
and no responsibility. We encourage you to contact these third parties
and security measures before disclosing personal information on linked
policy, advertising or sponsors of any linked web site.
Please click on this link Feedback/Opt
out to give us your feedback about this Policy or opt out of further
communications from us.
The Internet. On this OutDigit Web site we do
not collect personally identifiable information from Members, unless they
provide it to us voluntarily and knowingly. If you provide us with your
e-mail address, we may use it to send OutDigit and other offers
to you. In addition, you can sign up to receive email offers from OutDigit
Brands and Program Partners and Marketing Partners. OutDigit,
OutDigit Brands, Program Partners and/or Marketing Partners may contact
you via e-mail from time to time if you have asked or agreed to be put
on their respective mailing lists. You will always be provided with a
way to opt-out of future e-mailings.
Like many other Internet sites, we automatically collect certain
non-personal information regarding our Members, such as software
client information (for example, IP addresses, browser versions
and operating systems) and aggregate information (for example, number
of pages accessed) in order to analyze Web traffic and usage trends,
and to enable us to tailor content and services to provide a better
fit to our Members’ needs. Information of this nature does
not pertain to your specific identity and is not associated with
your personal information.
This OutDigit Web site has hyperlinks that connect the Member to other
Web sites, some of which are not affiliated with or controlled by
OutDigit. Once you leave this Web site, each new Web site you visit
and use of such linked Web sites through links provided on this
policies of those sites, not this Web site. This Web site’s
including other OutDigit Brand web sites.
Cookies. We may place a "cookie"
on your web browser. A cookie is a very small text file that is
sent to a Member’s browser from a web server and stored on
the Member’s computer hard drive. It assigns the computer
a unique identifier. The cookie stores information on your hard
drive so we can communicate with you more efficiently, respond to
you based on prior sessions at which you provided information about
you or your preferences to us and understand what you prefer to
or credit card information. Cookies do not tell us your individual
identity unless you have chosen to provide it to us.
Your browser should be set to allow you to be notified when a cookie
is to be placed on your browser, decline the cookie or delete cookies
that have been placed on your browser. Some functions of our web
sites may not work or may work slowly if a cookie is refused.
Our web site uses third party service providers to serve and host our advertisements.
These third parties may place cookies on your computer if you click on the advertising.
The third party cookies are used to track whether the site was accessed from the advertisement.
The cookies generated from the advertisements do not contain personally identifiable information.
We do not control these cookies and they may not follow the rules we have set for our own cookies.
Our web site also uses invisible pixels, sometimes called web beacons, to count how many people
visit certain web pages. Information collected from invisible pixels is used and reported in the
aggregate without the use of a Member's personally identifiable information.
This information may be used to improve marketing programs and content and to target our
Internet advertisements on our site and other web sites. For more information about our third party
ad server, or to learn your choices about not having this non-personal information used
to serve ads to you, please click
The Information We Collect. As
part of the enrollment process for the Program, we must collect
and store names and addresses, and other basic Information that
we solicit from you in order to make the Program benefits available
to you. In addition, we will collect and store optional information
that you choose to provide to us directly, or indirectly through third parties,
including telephone numbers, e-mail address and credit card information
for purposes of sending you
information about OutDigit offers. We send to the OutDigit Loyalty
Database and Enterprise Data Warehouses certain personally identifiable
information, including the name, address, telephone number, email
address and transaction detail ( what credit card purchases were
made from OutDigit Brands and Program Partners ). In addition, we may append
personally identifiable information that we obtain from third parties
to the Information that we collect from you. We do not collect
Social Security or driver's license numbers from Members.
Feedback/Opt out. We always offer
Members the opportunity to "opt-out" of communications.
A Member may elect to opt out of communication by following the
directions generally included in every email communication or by
visiting this OutDigit Web site or by contacting the OutDigit Member
Services department. Members can elect to opt out from any of the
following: (1) Mail - email and direct mail; (2) Phone -telephone
and fax solicitation; or (3) Contact - all communications including
email, direct mail, fax and telephone. We maintain telephone "do
not call" lists as mandated by law. We incorporate into the
OutDigit Loyalty Database and Enterprise Data Warehouse "do
not call" and "do not mail" lists maintained by other
organizations. We process requests to be placed on do not mail,
do not phone and do not contact lists within 60 days after receipt,
or such shorter time as may be required by law.
Any Member may opt out of communication by contacting OutDigit using
the following methods:
By email -
By phone -
By mail - Opt Out/ Privacy
OutDigit Member Services
We also invite your feedback and comments on this Policy. Please
contact us at the email address above or by writing to the above address.
Email. Members will have the option of submitting
their email address to us. Your e-mail address may be used by us to send
OutDigit offers to you . In addition, Members may sign up to receive
e-mail offers from OutDigit Brands, Program Partners and/or Marketing Partners.
Members will always have the ability to opt-out of future email communications.
It is our intent to only send email communications to Members who have
elected to provide us with their e-mail address, who have consented to
receive email from the OutDigit Brands, Program Partners and/or Marketing
Partners, or who have permitted third parties to share the Member's e-mail
address with entities such as OutDigit for purposes of receiving
promotional e-mails. These communications will relate to promotions from
OutDigit, OutDigit Brands, Program Partners and/or Marketing Partners,
as applicable. At any time a Member may opt-out of receiving email communications
by following the directions posted in every email communication, by visiting
this OutDigit website and following the opt-out instructions or by contacting
the OutDigit Member Services Department.
We may use a third party email service provider to send emails.
Any such service provider is prohibited by contract from using our
Member’s email address for any purpose other than to send
Program related e-mail.
SWEEPSTAKES / CONTESTS:
Occasionally OutDigit may run sweepstakes and contests. We
use Information provided by Members in connection with enrollment
for the Program or ask Members who participate or enter to provide
contact information (like an email address). If a Member participates
in a sweepstakes or contest, his/her contact information may be
used to reach him/her about the sweepstakes or contest, and for
other promotional, marketing and business purposes.
All sweepstakes/contests entry forms will provide a way for participants
to opt-out of any communication from the sweepstake’s/contest’s
manager that is not related to awarding prizes for the sweepstake/contest.
DIRECT MAIL / OUTBOUND TELEMARKETING:
Members who supply us with Information, or whose Information we obtain
from third parties may receive periodic mailings or phone calls from us
with information on OutDigit and other offers. Members may
also receive mailings/calls from OutDigit Brands, Program Partners and/or
We offer our Members the option to decline these communications.
Members may contact us to opt-out of such communications as follows:
By email -
By phone -
By mail - Opt Out/ Privacy
OutDigit Member Services
From time to time we may perform research (online and offline)
via surveys. All survey responses are voluntary, and the information
collected will only be used for research and reporting purposes,
to help us to better serve Members by learning more about their
needs. We may contact a Member to inquire or survey about the Program
or the improvements needed to the Program. The survey responses
may also be used to determine the effectiveness of our Web site,
various types of communications, advertising campaigns, and/or promotional
If a Member participates in a survey, the information given by the
Member will be used along with that of other study participants
(for example, a finding that 50% of a survey's respondents are men).
We may share anonymous individual and aggregate data for research
and analysis purposes.
Participation in surveys is voluntary. Participants who do not
wish to receive email communications may opt out of the receipt
of such communication by notifying us as provided in the Feedback/Opt-Out
What is Individual Specific Information? Individual-specific
or personally identifiable information is any information or data
about a Member that in itself, or as part of a unique combination
of information, specifically recognizes the Member by a unique identifier
or descriptor. Examples of individual-specific include name, address,
telephone number, email address, employment status, credit card
type and number, and other financial information.
What We Won't Do With Customer Information.
OutDigit will not:
1. Sell or rent Information to parties outside the OutDigit
family of present and former companies, OutDigit franchisees and affiliates,
or allow OutDigit affiliates to sell or rent the Information to parties
outside the OutDigit family of companies, franchisees and affiliates;
2. Use the Member Information we collect and store to make
decisions about granting or extending consumer credit unless the
Member submits a separate credit application and authorizes us to
use or disclose this information;
3. Act as a consumer reporting agency, or furnish information
about any Member's credit worthiness, credit standing, credit capacity,
character, general reputation, personal characteristics or mode
of living to any consumer reporting agency;
4. Maintain in our OutDigit Loyalty Database or Enterprise
Data Warehouse any Information about any Member on billing, collection
or payment disputes with any franchisee, creditor or OutDigit affiliate;
What We Will Do With Customer Information:
1. Use Member Information to inform Members about new
offers, and to offer goods and services we believe may be of interest
to Members, under joint marketing arrangements with OutDigit Brands, former
OutDigit affiliates, and OutDigit franchisees, and on behalf of Program
Partners and/or Marketing Partners;
2. With Member consent, provide Member Information to OutDigit
Brands, Program Partners and/or Marketing Partners, for purposes of directly
offering their goods and services to Members.
3. Include information about Members gathered from other sources
we believe to be reliable to identify our Members more thoroughly and
update Information we store and provide to third parties when the information
changes, such as changes of address or new credit card expiration dates;
4. Provide the name, address, telephone number and transaction
Information, including payment method, about Members to a OutDigit Brand's
or Program Partner's or Marketing Partner's designated affinity credit
card issuer(s) and loyalty club providers for use in the preselection
process for a OutDigit Brand's or Program Partner's or Marketing Partner's
affinity credit card and loyalty club;
5. Create and use aggregate Member data that is not personally
identifiable to understand more about the common traits and interests
of our Members;
6. Use Member Information to enforce a contract with a OutDigit
or provide access or disclosures that we believe in good faith are required
to comply with applicable law (See Compliance with Law in this Policy);
7. Provide information on corporate credit card usage to the corporate
card holder Member directly or through third parties;
8. Transfer Member Information to the party that acquires the business
or assets to which the information relates, or as part of the sale, merger
or consolidation of OutDigit to or with another business, or the consolidation
of OutDigit with another loyalty program.
Service Providers. We may utilize the services of, and disclose
Information to, our subcontractors and affiliates for purposes of
collecting Information on our behalf, and for administrative and
other purposes that we deem necessary to maintain, service, and
improve the Program.
Compliance with Laws.We may be
obligated to disclose Information about you to a law enforcement
agency or by a court order, or under the discovery process in litigation
and prosecutions. We may provide Information to assist a OutDigit
Brand or franchisee to enforce a contact you may have breached.
We may also disclose information voluntarily to cooperate with law
enforcement agencies in matters of national security. We may ask
certain questions to comply with certain laws if you reside outside
the United States or meet certain other criteria established by
law or executive order.
Correction. We make repeated efforts
to verify the accuracy of Information and to correct and update
our database from Information available to us. In the event a Member
believes that such Information held by OutDigit or OutDigit is inaccurate
or outdated, OutDigit or OutDigit, upon notification and sufficient time
for verification, will take all reasonable steps to correct any
inaccuracy or update outdated information of which we are made aware.
Downloading. Please feel free to
download or copy this Policy. You may obtain a copy free of charge
by writing to us at the following address:
OutDigit Member Services
Policy Changes. We may change or terminate
this Policy at any time without prior notice. We will post any Policy
changes to our web site to notify you of these changes and provide
you with the ability to opt out of any new, unanticipated uses of
Information not previously disclosed in the Policy. The Policy in
effect at the time of each visit to this Web site applies to that
visit. Please check our Policy each time you visit our web site
if you are concerned about how your Information will be used.