Last Updated: January 13, 2021
• Any Sites or Services that post separate privacy policies or privacy notices.
• Personal Information we collect on behalf of our Clients (as described below).
• Information that is de-identified, aggregated, or anonymous (“Anonymized Data”).
We are a leading sales agency and innovative business solutions provider in the military resale channel, growing business for our brand clients and retailer customers (our “Clients”), while supporting our service members, their families, and mission readiness. With roots in the military resale industry dating back decades, we deploy a dedicated team to every commissary and exchange in the United States and abroad, offering the full spectrum of headquarter sales services, business processing support, analytics and insights, and retail services. As such, we primarily provide business-to-business services and do not generally provide services directly to consumers.
We may collect the following categories of Personal Information through the Site and Services:
• Your contact information, such as your first and last name, phone number, email address, and postal address, and that of others you provide to us (e.g., other contacts in your business);
• Biographical or demographic information, such as your date of birth, age, gender, employer and job title/position;
• Commercial information, such as Services you have purchased or considered purchasing from us;
• Activity information about your use of our Sites and Services, such as your preferences and how often you use the Site or Services;
• Usage, technical and device information when you visit our Sites or open emails we send, including browser or device information, unique device identifier, URL that referred you to our Site or Services, and IP address. We may collect your location information derived from this information or from beacon technologies (as described below), where permitted by law to do so;
• Information you submit through any “Contact Us” feature, or otherwise provided to us in your communications with us.
We may obtain Personal Information from the following categories of sources:
We collect Personal Information you provide to us when you request or purchase Services or information from us, sign up for our mailing or email marketing lists (where applicable), participate in a survey, contact us, or otherwise interact with our Site and Services.
We and our service providers may collect information using analytics tools when you use our Sites and Services, that store or collect information about your interactions with our Sites and Services.
We may use various methods and technologies to store or collect information (referred to herein as “Tracking Technologies”), including when you visit or use our Sites. These Tracking Technologies may include the following:
• Cookies. A cookie is a file placed on a device to uniquely identify your browser or to store information on your device. Our Sites may use HTTP cookies, HTML5 cookies, Flash cookies, and other types of cookie technology.
• Web Beacons/Pixels. A web beacon is a small tag (which may be invisible to you) that may be placed on our Site’s pages or emails we send.
• ETags. An eTag or entity tag is a feature of a browser cache. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL.
We may use your Personal Information to:
• Provide you with requested Services;
• Operate, understand, optimize, develop, or improve our Sites, Services and operations, including tailoring the Sites and Services to your preferences;
• Establish and verify the identity of visitors to our Sites or users of our Services;
• Open, maintain and administer accounts you open through our Sites or Services;
• Send you email marketing messages, where you have signed up to receive them;
• Respond to your questions, inquiries, comments, complaints, or other communications you send to us;
• Communicate with you about our Sites and Services, including important updates to Sites and Services;
• Provide you with information about new opportunities, and related communications;
• Ensure our compliance with relevant legal and regulatory obligations;
• Maintain the security and integrity of our systems, Sites and Services; and
• Detect, investigate and prevent activities that may violate our policies or be illegal.
We do not share your Personal Information that we collected directly from you with third parties for their direct marketing purposes unless we have first given you the choice to consent or withhold consent to such sharing. We may share your Personal Information in the following circumstances, or as otherwise described in any privacy notices provided to you at the time your Personal Information was collected:
• When you request that we share your Personal Information with other companies so they can send you information, offers and/or promotions about their products and services, or when you interact with third parties through our Sites or Services, such as social media sites. Please note we are not responsible for the privacy practices of these third parties, and we encourage you to review their privacy policies and practices before requesting information from or otherwise interacting with them;
• When we use third-party service providers to perform services on our behalf, such as hosting and analytics providers, consulting services, auditors, and other providers; however, these companies are prohibited from using your Personal Information for purposes other than those requested by us or required by law;
• With our affiliate companies, meaning companies that are subsidiaries, joint ventures, or are otherwise controlled by or under common control with us; and
Individuals in certainjurisdictions may have certain rights under applicable privacy laws. Rightsspecific to residents of California, Nevada, the United Kingdom, and theEuropean Economic Area are described below. Subject to applicable law, you mayhave the right to request access to, modification or correction of, or deletionof your Personal Information, and information on how it has been used ordisclosed. For example, if you are a resident of Canada, you may be able torequest access to and/or correction of your Personal Information. To exerciseyour rights, you may contact us at firstname.lastname@example.org. We willrespond as soon as practicable, and in accordance with applicable law. We maytake steps to verify your identity prior to responding to your request, and, wherepermissible by law, we may charge for such submissions.
If you would like to stopreceiving newsletters or other marketing or promotional messages, notificationsor updates from us, you may do so by following the unsubscribe instructionsthat appear in those communications, or by contacting us email@example.com to opt-out of marketing emails. Please beadvised that you may not be able to opt-out of receiving certain service ortransactional messages from us, including legal notices.
We do not exchange Nevada residents’ PersonalInformation for money with anyone so they may further license or sell thePersonal Information to additional parties.
If you are a California resident, subject to applicable law, you have the following rights with respect to your Personal Information:
• Right to Know. You have the right to request, up to two times each year, the categories and/or specific pieces of Personal Information about you that we collect, use, disclose and sell, as applicable, and subject to applicable legal exceptions.
• Right to Delete. You have the right to request that we delete Personal Information that we collect from you, subject to applicable legal exceptions.
• Right to Non-discrimination. You have the right not to receive discriminatory treatment by us for the exercise of your rights under the CCPA.
You can submit a Right to Know or Right to Delete request through our PRIVACY PORTAL (click the link to access) or by calling us, toll free, at 1-888-651-2032.
These rights are subject to our being able to reasonably verify your identity. We will verify your identity by matching information you provide with your request with information in our systems; and, for requests submitted through our Privacy Portal, by additionally requiring you to respond to an automated email to verify your email address. In general, we will ask you to provide the following information in connection with your request: first and last name, email address, state and country of residence, and the nature of your relationship with Advantage. We may also request additional documentation or information solely for the purpose of verifying your identity.
You may also authorize someone else to exercise these rights on your behalf. When a third party submits a request on your behalf, they must indicate in our Privacy Portal or on the phone that they are an authorized agent, and supply us with evidence of such authorization; we will not fulfill any request submitted by a third party related to your Personal Information until we have received confirmation that you authorized such third party to submit a request on your behalf.
Please note that your exercise of these rights is subject to certain exemptions and exclusions, and your requests may be granted in whole, in part, or not at all, depending on the scope and nature of the request and applicable law. Where required by applicable law, we will notify you if we reject any part of your request and the reason(s) we are unable to honor it.
• We collected the following categories of Personal Information in the last 12 months: identifiers/contact information; biographical/demographic information (such as age and gender); commercial information; Internet or other electronic network activity information; professional or employment-related information; geolocation data (in some cases); and inferences drawn from the above.
• The sources of Personal Information we collected are outlined in the How We Collect Your Information section above.
• The business or commercial purposes of collecting Personal Information are outlined in the Why We Collect Your Information section above.
• We disclosed the following categories of Personal Information for a business purpose in the last 12 months: identifiers/contact information; commercial information; and Internet or other electronic network activity information. We disclose these categories only as described in the How We Share Your Information section above.
• We do not “sell” Personal Information of known minors under 16 years of age.
This section applies only to the extent you are a resident of the United Kingdom (“UK”) or European Economic Area (“EEA”). We are the data controller of your Personal Information that we collect through our Site and Services, except where we collect your Personal Information as a data processor on behalf of a Client. In that case, the collection and processing of your Personal Information is governed by the relevant Client’s privacy notice.
We process your Personal Information under the following legal bases:
The following rights are provided to residents of the UK and EEA under the General Data Protection Regulation (“GDPR”) or equivalent local laws:
If you are a resident of the UK or EEA and wish to exercise any of these rights, you may do so by using our PRIVACY PORTAL (click the link to access).
We recognize the importance of children’s safety and privacy. Our Sites are general audience websites and applications and are not designed or intended to attract or be used by children under the age of 16. We do not knowingly collect or request Personal Information from children under the age of 16. If you are under the age of 16, you are not permitted to use this Site and should not send us any information about yourself. In the event we become aware we have collected Personal Information from a child under the age of 16, we will take steps to dispose of that information in accordance with the Children’s Online Privacy Protection Act and other applicable laws and regulations. If you are a parent or guardian and you believe your child under the age of 16 provided us with Personal Information without your consent, you may contact us at firstname.lastname@example.org.