Privacy Policy
WeSalute Privacy Policy
WeSalute (founded as Veterans Advantage) respects your right to privacy and adheres to the highest standards in protecting your personal information. We strive to secure a level of trust and confidence that matches the code of honor and integrity with which our customers have served.
This Privacy Policy discloses the privacy practices for Veterans Advantage PBC dba WeSalute (“WeSalute”, “Veterans Advantage,” “we,” “us,” or “our”) through our WeSalute service, websites (located at wesalute.com and veteransadvantage.com), the WeSalute mobile application and WeSalute widgets/services/integrations present on our clients’ websites and applications (collectively, our “Services”).
Verification Services
WeSalute provides verification services to allow companies and their brands to have confidence that special offers and other marketplace content made for communities of service are reserved for those that deserve them, and for groups to access those offers. Depending on whether you are active military, a veteran or an eligible family member, or a member of another group, we provide a number of different ways to verify your identity and status.
Military
- If you are active military, military student or are employed by the Commissioned Corps of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration, we ask that you confirm your branch of service and through a verification to your .mil (or noaa.gov or usphs.gov, if applicable) email address. As an alternative, we may ask that you take a picture of your government-issued ID and a selfie (a picture of yourself on your mobile phone) to confirm your identity.
- If you are a veteran or former service member, we may ask that you provide your name, gender, date of birth, military status, branch of service and Social Security number. We will then be able to confirm your status automatically with the Department of Veterans Affairs. We ask for your permission before connecting to the Department of Veterans Affairs’ systems. If you prefer to use a different way to verify your military/veteran status or if we are unable to confirm your status with the Department of Veterans Affairs, we will ask that you sign an affidavit of military service and complete a screening with facts that are generally known only within the military community before review by our customer support teams. In addition, we may ask for you to upload redacted proof of service to us for verification.
- If you are an eligible family member, we may ask not only for your personal information, but the personal information of the service member you’re related to. We may ask for additional documentation associated with the service member and additional documentation of your relationship.
- If you are unable or do not want to complete either of the above methods of verification, we will ask that you provide additional documentation, which may include a redacted copy of your DD 214, Veteran ID card, military retiree account statement, military paystub, or an SCRA Status Report.
When you use our verification services, with your consent, we create a WeSalute account for you. Please note that any sensitive information you provide in connection with our verification services, we either do not retain (i.e., Social Security numbers) or destroy within 30 days of when the verification is completed (e.g., documentation associated with military status). Please note that we may ask you to confirm your status more than once.
As detailed under “Device Information” below we may also collect information from your device to determine if your activity is authentic.
WeSalute and WeSalute+ Programs
The Types of Information We Collect
When you interact with the WeSalute website and programs (collectively, the “WeSalute Services”), we may collect information about you. The categories of information we collect as well as descriptions of how WeSalute receives, uses and shares that information are described in the chart below:
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
How We Use Your Personal Information
We use the personal information we collect for purposes described in this Privacy Policy or as otherwise disclosed to you. For example, we use personal information for the following purposes:
- Providing Our Services. To provide our services, including our WeSalute programs, and any products you may purchase.
- Verification. As described in the Verification Services section above, we may use your information to verify eligibility for promotional offers from our marketplace partners.
- Business Operations. To operate our business, such as: creating and managing your membership in WeSalute programs and for billing, improving our internal operations, securing our systems, detecting fraudulent or illegal activity, and monitoring and analyzing trends, usage and activities in connection with our Services.
- Product Improvement, Development, and Research. To improve our products, develop new products or features, and conduct research.
- Personalization. To understand you and your preferences to enhance your experience and enjoyment using our services and to personalize your online experience and the advertisements you see when you use the Services and on other sites as detailed below.
- Customer Support. To answer your questions and respond to your requests and to send you information and notices about your membership, such as updates, order confirmations, delivery notices, security alerts, and support and administrative messages.
- Marketing and Advertising. To communicate with you about new WeSalute and our marketing partners’ products and services, offers, promotions, contests, upcoming events, and other information about our products and services and those of our Marketplace Partners, and to display advertising to you.
- Legal, Security, and Safety Reasons. For legal, security and safety reasons, such as to protect our rights and the rights of our customers and members, enforce our policies, communicate product recalls or safety notices, detect, investigate, or prevent fraud and other illegal activities, or address legal and regulatory compliance obligations.
- For any other purpose described to you at the time information is collected.
How We Share Your Personal Information
We may share your personal information as follows:
- WeSalute entities. Your personal information may be shared within our company and with our affiliated entities as reasonably necessary to accomplish any of the above-noted purposes.
- Marketplace Partners. We may share your personal information with our Marketplace partners who may offer you products and services that may be of interest to you. We may share your personal information with Marketplace partners with your consent to facilitate the marketplace experience.
- Vendors and Service Providers. Your information may be shared with parties who support our business, such as payment processing, financing, order fulfillment, delivery services, professional advisors, advertising and marketing, web-hosting, analytics providers, customer-relationship-management software providers and other similar information technology providers.
- Merger, Sale, or Business Transfer. Your previously collected personal information may be shared or disclosed in connection with the sale, assignment or other transfer of our company or one of our businesses and of their assets. This includes merger, sale, or transfer in the case of bankruptcy or receivership.
- Fraud Protection, Prevention, and Legal Compliance. We may disclose your information: (1) at times when we believe it is necessary to comply with applicable regulation, law, judicial or legal proceeding, or governmental agency request; (2) to third-parties as to aid them in their attempts to root out fraud or suspected fraud or illegal activity; (3) to combat and prevent fraud, suspected fraud, illegal activities, and threats to others’ physical safety; and (4) to uphold and enforce an agreement we have with customers.
- With your consent. Other disclosures with your consent.
How We Secure Your Personal Information
We take what we believe are reasonable steps to protect your personal information as you transmit your information from your computer to our Services and to protect such information from loss, misuse and unauthorized access, disclosure, alteration or destruction.
We use a third-party vendor to process credit card transactions. Our online payment pages along with our processing partner reside on secure web servers that encrypt the data between the customer and the processing vendor. By using this payment processing service, we do not collect any credit or debit card numbers or store such information.
Biometric Information
As part of our verification services, we may collect “biometric identifiers” or “biometric information” as defined under the Illinois Biometric Information Privacy Act and the Business Code of Texas on the Capture or Use of Biometric Identifiers. “Biometric identifier” means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. Biometric identifiers do not include writing samples, written signatures, photographs, human biological samples used for valid scientific testing or screening, demographic data, tattoo descriptions, or physical descriptions such as height, weight, hair color, or eye color. “Biometric information” means any information, regardless of how it is captured, converted, stored, or shared, based on an individual’s biometric identifier used to identify an individual.
We collect face scan information (face geometry information and information based on your face geometry) during the identity verification process. This information is only retained for the period required for the verification and authentication process, but in any event, this data will not be retained for more than 3 years after your last interaction with us for the residents of the State of Illinois and more than 1 year after your last interaction with us for the residents of the State of Texas.
By providing your consent for the verification process, you consent to providing us with biometric information and identifiers and for WeSalute to use and store that information for the purpose of verifying and authenticating your identity and disclosure of your biometric information to our service providers in order to provide the service. We use reasonable standards of care to store, transmit, and protect from disclosure your facial scan information, in a manner that is the same as or more protective than the manner in which we store, transmit, and protect other confidential and/or sensitive information. We will not sell, lease, trade or otherwise profit from the biometric information – it is used solely to provide the verification service.
Information for European Residents
- Our Legal Basis for Processing: In most instances, we process your personal information in order to perform our contractual obligations. For example, we rely on this legal ground when we use your personal information to administer our WeSalute and WeSalute+ programs on your behalf. We may also process your personal information in connection with our legitimate interests; for example, in order to market our services to you and to understand and improve our Website, to process your information in connection with job inquiries, and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. In certain circumstances, we rely on your consent to process your information. For example, we rely on your consent when you submit your information in connection with our verification services. In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements or for reasons of public interest.
- Transferring Your Personal Information Internationally: WeSalute is based in the United States and is directed at current and past members of the American military and their families. If you are a resident of the European Union or the United Kingdom (“UK”), your information may be transferred to the United States. By submitting your information to WeSalute, you consent to the transfer of your information to the United States. When we transfer your personal information outside the European Union or the UK we will put in place appropriate safeguards, in accordance with our legal obligations.
Your Rights
- Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
- Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
- Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.
You can make a request to exercise any of these rights by filling out this form or emailing us at [email protected].
We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance.
- Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Social Media Features
Our Site may include social media features, such as the Facebook “Like” button and Twitter “Follow” button. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing it.
Information Collected from Children
WeSalute’s programs and services are intended for individuals over the age of 16. If you are a child 16 or younger, you are not authorized to register for an account or make a purchase from our Services without consent from your parent or legal guardian.
If we become aware that personal information from a child 16 years of age or younger has been collected without such a child's parent or guardian's consent, we will use all reasonable efforts to delete such information from our database. If any parent, guardian or other responsible adult becomes aware that we have collected personal information from a child 16 years of age or younger, please contact us at [email protected].
Links to Other Web Sites
You should be aware that when you are on our Services you could be directed to other sites beyond our control. For example, if you “click” on a link to one of our marketing partners sites, the “click” may take you off our Services and onto the marketing partner’s website. These other websites may send their own cookies to you, independently collect data or solicit personal information and may or may not have their own published privacy policies. If you visit a website that is linked to our Services, you should consult that site’s privacy policy before providing any personal information. Please note that we are not responsible for the privacy practices of such third parties.
Changes to This Privacy Policy
We will occasionally update this Privacy Policy as our business and services change. If we make changes to this Privacy Policy or make any material changes to how we use your personal information, we will revise this Privacy Policy to reflect such changes and revise this Privacy Policy’s effective date.
We stand behind the promises we make, however, and will never materially change our policies and practices to make them less protective of your personal information collected in the past without your consent.
We encourage you to periodically review this Privacy Policy to be informed of how we are using and protecting your personal information.
Cookie Policy
How We Use Cookies and Other Tracking Technologies
Our Services may use a standard technology called a “cookie” and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Services. These technologies automatically identify your device whenever you interact with our Services.
Categories of Cookies
We use cookies for the following types of purposes:
Essential (Strictly Necessary) cookies. These are cookies that are required for the operation of our Services.
Analytics cookies. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Services. They help us to know which pages are the most and least popular and see how visitors move around and interact with our Services. If you do not allow these cookies we will not know when you have visited our Services and will not be able to monitor its performance.
Personalization cookies. These are used to recognize you when you return to our Services. This enables us to personalize our content for you and remember your preferences.
Marketing (Advertising) cookies. These cookies may be set through our Services by our marketing partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and device. If you do not allow these cookies, you will experience less targeted advertising.
You can find more information about the individual cookies we use and the purposes for which we use them in the tables below. The following cookies are labeled and classified using postgres regular expression:
|
|||
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|||
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|||
|
|
|
|
|
|
|
|
|
|||
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Controlling and Deleting Cookies
If you would like to change how a browser uses cookies, including blocking or deleting cookies from our Services you can do so through the Cookie Consent Management tool by Osano provided on our website or by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It’s also easy to delete cookies that are already saved on your device by a browser.
The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser’s “Help” function or alternatively, you can visit http://www.aboutcookies.org, which explains, step-by-step, how to control and delete cookies in most browsers.
Similar Technologies
We use technologies that resemble cookies to help track user activities and preferences. For example, we may use web beacons (tiny graphics with a unique identifier embedded on web pages or emails) to track your activities and communicate with cookies. You cannot opt out of web beacons used on webpages, but you can limit their use by opting out of the cookies they interact with. You can opt out of web beacons used in emails by setting your email client to render emails in text mode only.
Mobile Apps
Our apps (e.g., for iOS and Android) do not use cookies, but may use tracking technologies to, for example, authenticate you as a registered user, allow you to use the app’s features, and help us understand how our apps are being used. You cannot opt out of these mobile tracking technologies, but you may delete your apps and use the web versions of our services instead.
Third-Party Ad Serving & Audience and Traffic Measurement Services
Our Services may use third-party network advertisers to serve advertisements you may see based on your visit. Network advertisers are third parties that display advertisements based on your visits to our Services and other websites you have visited. Third-party ad serving enables advertisements to be served to you for products or websites you might be interested in. In addition, we may share this information with Ace to allow them and their network advertisers to serve ads based on your interests to you.
Our Services are in compliance with the Ad Choices Self-Regulatory Program for Online Behavioral Advertising. The goal of Ad Choices is to provide you with information about how online advertising works and the choices you have.
You may visit the http://www.aboutads.info/choices page to learn more about online behavioral advertising and to see your opt-out choices from companies that are participants in the Self-Regulatory Program for Online Behavioral Advertising.
Please note that if you choose to opt out, you will still see ads, but these ads will not be customized based on your interests generated from your visits over time and across different websites. In addition, the preferences you select on the http://www.aboutads.info/choices page may not apply to mobile devices. Due to the differences between using apps and websites on mobile devices, opt-outs will need to be set for both browsers and apps.
Your California Privacy Rights
This California Consumer Privacy Act Disclosure (this “CCPA Disclosure”) describes how WeSalute collects, uses and discloses personal information relating to California residents (consumers) covered by the California Consumer Privacy Act of 2018 (“CCPA”) and other California laws. If you are a California resident, you have certain rights with respect to your personal information.
Introduction
Under the CCPA, “Personal Information” is information that identifies, relates to, or could reasonably be linked directly or indirectly with a particular California resident. The specific Personal Information that we collect, use, and disclose relating to a California resident covered by the CCPA will vary based on our relationship or interaction with that individual.
Your information may be “sold” as defined under the CCPA, which defines “sale” as the disclosure of Personal Information to a third-party for monetary or other valuable consideration. California’s definition of sale is broad and encompasses many types of data transfers. However, we do not "sell" any consumer data in the traditional sense for direct monetary compensation.
For more information about how we collect, disclose, and secure information, please refer to our general Privacy Policy above. Terms that are used, but not defined, in this CCPA Disclosure are defined in the CCPA.
Notice Regarding the Categories of Personal Information Collected.
You have the right to receive notice of the categories of personal information we collect, the purposes for which we use personal information, and the categories of entities to whom we disclose or “sell” personal information. The categories we use below to describe personal information are those enumerated in the CCPA.
We disclose information for a business purpose to service providers and contractors, which are companies or individuals that we engage to conduct activities on our behalf. Service providers and contractors are restricted from using personal information for any purpose not related to our engagement.
We may also share your information with our marketing partners to whom we may “sell” your information as defined by CCPA.
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Personal information may be disclosed in additional, more limited circumstances, as described in How We Share Your Personal Information above (for example, to law enforcement or in connection with a sale of our business).
Right to Know and Right to Request Deletion. You have the right to request access to personal information collected about you and information regarding the source of that personal information, the purposes for which we collect it, and the third parties and service providers with whom we disclose it. You also have a right to request that we delete personal information under certain circumstances, subject to a number of exceptions. You may make such requests by visiting the “Privacy” tab on “My Account” or filling out this Request Submission Form. You can also submit your request by calling 1-866-838-2774 or emailing [email protected] .
To provide or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law. We will verify your request by matching information we request or you provide with your request to information we have collected previously or by using our verification service.
Do Not Sell My Personal Information/Right to Opt Out. You have a right to opt out from future “sales” of personal information. You can exercise your Do Not Sell My Personal Information rights by contacting us using the methods above; or making your request via our “Do Not Sell My Personal Information” webpage. You can prevent digital tracking information from being sold by visiting the Cookie Preferences page from the Do Not Sell My Personal Information page. Any opt-out choices you make will only apply to the specific email address that you provide when making the request, and to the browser that you are using when you submit an opt-out for digital tracking technologies.
Note that although we will not “sell” your personal information after you opt out from the sale of personal information, we will continue to disclose some personal information with our suppliers (acting as our service providers) for our business purposes. Selecting the “Do Not Sell My Personal Information” link and or opting out of cookies and digital tracking technologies will not stop the use of previously sold personal information or stop all interest-based advertising.
Right to Not Experience Discrimination. You have a right to not be discriminated against for exercising these rights set out in the CCPA.
Use of an Authorized Agent. You may designate an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us or confirm that you provided the authorized agent permission to submit the request.
California Shine The Light. Under California Civil Code Section 1798.83, California residents have the right to obtain (a) a list of all third parties to whom we may have disclosed your Personal Information within the past year for direct marketing purposes; and (b) a description of the categories of Personal Information disclosed. Please contact us at [email protected] to receive this information.
California's "Do Not Track" Requirement. We do not react to "Do Not Track" or "DNT" browser signals at this time.