At Micronotes, our most important asset is our relationship with you. Micronotes is committed to maintaining the confidentiality, integrity and security of any personal information about our users. This Privacy & Security Policy explains how we protect personal information provided through your financial institution and how we use that information in connection with our service (“Service”). “Personal information” for purposes of this Policy means information that identifies you, such as your name, address, phone number, fax number or email address.

Micronotes stresses its privacy and security standards to guard against identity theft and provide security for your personal information. We regularly re-evaluate our privacy and security policies and adapt them as necessary to deal with new challenges.

1. Your Privacy is not for sale

Simply put, we do not and will not sell your personal information to anyone, for any reason, at any time. Micronotes uses your personal information only as follows:

• to analyze purchase behavior that in turn will improve the Service;
• to deliver to you offer that you have selected
• to transfer cash into your bank account via ACH
• to deliver to you any administrative notices and communications relevant to your use of the Service
• to third-party contractors that provide services to Micronotes and are bound by these same privacy restrictions;
• to enforce Micronotes’ Terms of Use;
• as otherwise set forth in this Privacy and Security Policy.

2. We limit the collection and use of personal information

The Micronotes Service is available to you on an opt-in basis through your financial institution without registration or the need to provide to us any information. However, in order to benefit from the full functionality of the Service, you can also provide your third-party account credentials (“Account Credentials”) to allow Micronotes to access your account data at those other financial institutions (“Account Information”) for your use.

From time to time we may request other personal information to provide you with other benefits of the Service. In all such instances, you will be given the opportunity to provide or to decline to provide that information, and it will be used only for the stated purpose. Micronotes may make anonymous or aggregate personal information and disclose such data only in a non-personally identifiable manner to merchants who may to interview you and make you an individualized offer. Such information does not identify you individually. Access to your Account Credentials, Account Information and any other personal information you provide is strictly restricted and used in accordance with specific internal procedures and safeguard governing access, in order to operate, develop or improve the Service. These individuals have been selected in accordance with our security policies and practices and are bound by confidentiality obligations. They may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations. We may also use third party vendors or service providers to help us provide the Service to you, such as sending e-mail messages on our behalf or operating a particular feature or functionality of the Service. Our contracts with these third parties outline the appropriate use and handling of your information and prohibit them from using any of your personal information for purposes unrelated to the product or service they're providing. We require such third parties to maintain the confidentiality of the information we provide to them.

3. Merchants making offers will not be given your personal information

Under no circumstances will your personal information be shared with merchants and are making customized offers to you. However, when you redeem your offers, you may need to disclose information to the providers, or grant them permission to collect information about you, then their use of your information is governed by their privacy policies. You should evaluate the practices of external services providers before deciding to use their services. Micronotes is not responsible for their privacy practices. If you click on a link to a third party site, Micronotes encourages you to check the privacy policy of that site. Micronotes may present links in a format that enables us to keep track of whether these links have been followed and whether any action has been taken on a third party Web site. We use this information to improve the quality of the Micronotes Offers and customized content on the Service.

4. Blogs and other Forums on Micronotes.com

If you use a bulletin board, blog or chat room on our Site, you should be aware that any information you submit there can be read, collected or used by other users and could be used to send you unsolicited messages. We are not responsible for the personal information you choose to submit in these forums. These forums may be hosted by Micronotes or by one of our third party service providers on Micronotes' behalf.

5. Contests, Giveaways and Surveys

From time to time, Micronotes may offer you the opportunity to participate in contests, giveaways and other promotions. Any information submitted in connection with such activities will be treated in accordance with this Privacy and Security Policy, except as specifically set forth in the rules for those contests, giveaways or promotions. From time to time, Micronotes may also ask you to participate in surveys designed to help Micronotes improve the Service. Any personal information provided to Micronotes in connection with any survey will be used only in relation to that survey and as elsewhere set forth in this Policy.

6. Disclosure of your information to protect our rights or if required by law

Notwithstanding the foregoing, Micronotes reserves the right (and you authorize Micronotes) to share or disclose your personal information when Micronotes determines, in its sole discretion, that the disclosure of such information is necessary or appropriate:

• To enforce our rights against you or in connection with a breach by you of this Privacy and Security Policy or the Micronotes Terms of Use;
• To prevent prohibited or illegal activities; or
• When required by any applicable law, rule regulation, subpoena or other legal process.

7. Your data may be transferred upon change of control but only in accordance with this Policy

Personal information may be transferred to a third party as a result of a sale, acquisition, merger, reorganization or other change of control. If we sell, merge or transfer any part of our business, part of the sale may include your personal information. If so, you will be asked if you'd like to stop receiving promotional information following any change of control.

8. You can transport or delete your data

Your data is yours. You can remove it anytime you want. When you request us to delete your profile, your data will be permanently expunged from our primary production servers and further access to your account will not be possible. We will also promptly disconnect any connection we had established to your Account Information and delete all account credentials. However, portions of your data, consisting of aggregate data derived from your Account Information, may remain on our production servers indefinitely. Your data may also remain on a backup server or media. Micronotes keeps these backups to ensure our continued ability to provide the Service to you in the event of malfunction or damage to our primary production servers. We also reserve the right to use any aggregated or anonymous data derived from or incorporating your personal information.

9. Email communications from us

We allow users to subscribe to email newsletters and from time to time may transmit emails promoting Micronotes. Micronotes’ subscribers have the ability to opt-out of receiving our promotional emails and to terminate their newsletter subscriptions by following the instructions in the emails. Opting out in this manner will not end transmission of service-related emails, such as email alerts.

10. Your data is secure

We use a combination of firewall barriers, encryption techniques and authentication procedures, among others, to maintain the security of your online session and to protect Micronotes accounts and systems from unauthorized access. Our servers are in a secure facility. Access requires multiple levels of authentication. Security personnel monitor the system 7 days a week, 24 hours a day. Our databases are protected from general employee access both physically and logically. All backup drives and tapes also are encrypted. We enforce physical access controls to our buildings. No employee may put any sensitive content on any insecure machine (i.e., nothing can be taken from the database and put on an insecure laptop).

11. Our service ensures secure communications with encryption

From the time you opt-in, these communications between your computer and Micronotes are encrypted. This enables client and server applications to communicate in a way that is designed to prevent eavesdropping, tampering and message forgery.

12. We post updates on our website whenever there is a change to our Privacy and Security Policy

We update this Privacy & Security Policy periodically. The date last revised appears at the top of the Policy. Changes take effect immediately upon posting.

15. Contact us if you have any questions or concerns

If you have questions, comments, concerns or feedback regarding this Privacy and Security Policy or any other privacy or security concern, send an e-mail to security@micronotes.com.

Micronotes Inc.
One Broadway, 14th floor
Cambridge, MA 02142
Phone: (617) 401-2175