Privacy Policy

We collect information from and about you across all touchpoints of the Platform.  Because the Platform is an integrated ecosystem, information collected through any one part may be combined with information from any other part to create a unified record of your interactions with Fuze Technology.

2.1  Information You Provide.

When you register, transact, communicate with us, enter a promotion, or otherwise engage with any part of the Platform, you may provide the following categories of information:

(a)  Contact and identity information, including name, phone number, and email address;

(b)  Account credentials and authentication information;

(c)  Payment and billing information, which is processed by our third-party payment service providers — we do not store full payment card numbers or equivalent sensitive payment credentials;

(d)  Communications, correspondence, survey responses, and user-generated content; and

(e)  Any other information you choose to provide through any Platform interaction.

2.2  Information Collected Automatically.

When you interact with any part of the Platform — across any of our digital, physical, or transactional touchpoints — we and our technology partners automatically collect the following categories of information:

(a)  Transaction and Usage Data.  Records of all transactions, interactions, and events occurring through the Platform, including date, time, duration, frequency, transaction identifiers, device or terminal used, location of the transaction, amounts, promotional codes or incentives applied, and any other operational metadata associated with a Platform interaction.  This includes all transactions made through any current or future FUZE product or service.

(b)  Location Information.  We collect location data at multiple levels of precision:  (i) general location derived from IP address or network signals, indicating your approximate city or region; (ii) transaction-point location associated with any device, kiosk, terminal, or installation through which you interact with the Platform; (iii) precise device location, where you have granted location permission through your device settings; and (iv) proximity signals, where you have consented, derived from geofencing, beacons, or other proximity technologies that indicate your presence near a location of interest.

(c)  Behavioral, Interest, and Inference Data. We observe, record, and derive information about your behavior, preferences, habits, and likely interests based on how you interact with the Platform over time.  This includes engagement patterns, content interactions, responses to promotions and offers, product usage patterns, and attributes inferred from the combination of your transaction, location, and usage data.  We may derive segments, scores, or modeled attributes based on this data.

(d)  Device and Technical Information.  Information about the devices and technologies you use to access the Platform, including IP address, advertising identifiers (such as mobile ad IDs), device type and model, operating system, browser type, network provider, and related technical parameters.

(e)  Communications and Engagement Data.  Information about your interactions with our communications, including whether you opened a message, engaged with content, or responded to an offer or advertisement.

2.3  Information From Third Parties.

We may receive information about you from third-party sources — including data providers, analytics companies, advertising technology partners, platform partners, and other service providers — and combine it with information we already hold about you.  We use this combined data for all purposes described in this Policy.

2.4  Cookies and Tracking Technologies.

We and our technology partners use cookies, pixel tags, software development kits (SDKs), and similar tracking technologies across our digital properties to collect device and activity information for the purposes described in this Policy.  Upon accessing our digital properties, you will be presented with choices regarding non-essential tracking technologies where required by applicable law.  You may also manage preferences through your browser and device settings.

2.5  Information We Do Not Collect.

We do not collect full payment card numbers or equivalent sensitive payment credentials, government-issued identification numbers, or health or medical information.

3.   HOW WE USE YOUR INFORMATION

We use the information we collect — individually, in combination, and in aggregate — for a broad range of purposes consistent with our operations as a technology and media company.  The purposes set forth below are illustrative and not exhaustive.  We will use information for additional purposes that are compatible with those described herein, to the extent permitted by applicable law.

3.1  Providing and Operating the Platform.

We use information to enable, process, and fulfill transactions and interactions across all parts of the Platform; to create, verify, and manage accounts; to send transactional and service-related communications; to provide customer support; and to maintain the security, reliability, and integrity of the Platform.

3.2  Personalization, Marketing, and Advertising.

Marketing and advertising are core functions of the FUZE Platform. We use information to:

(a)  Deliver personalized content, offers, and promotions across the Platform and through our communications channels, based on your profile, behavior, transaction history, and inferred interests;

(b)  Serve and optimize advertising to you within and beyond the Platform, including through third-party digital media channels and programmatic advertising technology;

(c)  Trigger contextual marketing and promotional communications based on your location, proximity to points of interest, or your behavior at the time of a Platform interaction;

(d)  Retarget you with relevant messaging across digital channels, including through the use of your contact information and device identifiers on third-party advertising and marketing platforms;

(e)  Build and activate audience segments based on behavioral, transactional, locational, and interest data derived from your use of the Platform;

(f)  Develop lookalike or modeled audiences for marketing activation;

(g)  Measure, attribute, and report on the performance of marketing and advertising campaigns; and

(h)  Operate advertising, media, and data intelligence services as commercial functions of the Platform.

3.3  Data Intelligence and Analytics.

We use information to analyze patterns of use, behavior, and engagement across the Platform; to develop, train, and improve algorithms, models, and machine learning systems; to generate aggregated, de-identified, or pseudonymized insights about audience behavior and market trends; and to support business intelligence, product development, and strategic planning.

3.4  Data Collaboration and Platform Integrations.

As a technology and media company, we leverage a range of data collaboration techniques and platform integrations.  This includes, without limitation:

(a)  Uploading and synchronizing Platform data with third-party software platforms, data management systems, customer data platforms, marketing automation systems, and advertising technology infrastructure;

(b)  Participating in privacy-compliant data collaboration programs — including clean room environments, data co-ops, and identity resolution frameworks — in which information is processed in controlled environments to generate marketing and analytical outputs;

(c)  Enabling data matching, enrichment, and identity resolution through industry-standard techniques and technology providers;

(d)  Integrating Platform data with partner or vendor systems for joint analysis, campaign execution, or product development purposes; and

(e)  Leveraging Platform data through any other collaboration methodology that achieves a lawful business purpose consistent with this Policy.

3.5  Product Development and Innovation.

We use information to research and develop new products, services, features, and business lines; to conduct user research, surveys, and testing programs; and to integrate data from new FUZE products into the Platform data ecosystem as those products launch.

3.6  Communications.

We use information to send promotional and marketing communications by email, SMS (where separately consented), push notification, in-app message, and other channels; to administer contests, loyalty programs, incentives, and special offers; and to personalize communications based on your profile, behavior, and inferred interests.

3.7  Safety, Security, and Legal Compliance.

We use information to prevent, detect, and address fraud, abuse, and violations of our Terms of Service; to enforce our agreements and exercise our legal rights; and to comply with applicable laws, regulations, and legal process in all markets where we operate.

3.8  Legal Bases for Processing.

We process your information on the following legal bases:  (a) performance of our contract with you, to the extent processing is necessary to provide Platform services and manage your account; (b) our legitimate interests as a technology and media company, including in developing and monetizing our data intelligence capabilities, subject to your applicable rights; (c) your consent, for processing that requires it under applicable law, including precise location collection, certain advertising uses, and SMS marketing — consent may be withdrawn at any time without affecting the lawfulness of prior processing; and (d) compliance with legal obligations.

4.   HOW WE SHARE AND DISCLOSE INFORMATION

We may share de-identified, aggregated, or pseudonymized information without restriction, as such information does not constitute personal information.  We share identifiable personal information in the following circumstances.

4.1  Within the FUZE Platform.

Fuze Technology Inc. operates the Platform as a single, integrated business.  Information collected through any part of the Platform is accessible to and usable across all current and future FUZE business functions — including technology, media, advertising, and data intelligence — for all purposes described in this Policy.

4.2  Service Providers and Technology Partners.

We share information with companies that perform services for or on our behalf, including cloud computing, data storage and processing, payment processing, messaging, analytics, advertising technology, identity resolution, marketing automation, and customer data platform operations.  Service providers are authorized to use information only as directed by Fuze Technology Inc.

4.3  Advertising, Marketing, and Data Partners.

We share information — including contact information, device identifiers, behavioral data, audience segment data, and inferred interest data — with advertising platforms, media companies, marketing technology providers, data intelligence firms, and other commercial partners for the purposes of executing advertising campaigns, audience targeting, audience extension, data enrichment, measurement, attribution, and related commercial activities.  Such sharing may include, without limitation:

(a)  Uploading contact information or device identifiers to third-party advertising and marketing platforms for targeted advertising and campaign measurement;

(b)  Making audience segments or modeled attributes available to media and marketing partners for campaign planning and activation;

(c) Participating in data matching and identity resolution programs operated by third-party technology providers;

(d) Contributing Platform data to collaborative analytical environments; and

(e)  Sharing aggregated or de-identified audience insights with commercial partners.

Where such sharing constitutes "selling" or "sharing" personal information for cross-context behavioral advertising under applicable law, the opt-out rights described in Section 9 of this Policy apply.

4.4  Business Partners and Venue Operators.

We may share information with partners, venue operators, retailers, and other third parties with which we have a commercial relationship, for purposes including joint marketing, co-branded programs, audience analytics, and operational coordination.

4.5  Legal and Safety Disclosures.

We may disclose information where required by law or legal process; to protect the rights, property, or safety of Fuze Technology Inc., our users, or the public; to detect and prevent fraud; or to enforce our agreements.

4.6  Corporate Transactions.

In connection with a merger, acquisition, financing, reorganization, asset sale, or similar transaction, information may be transferred as a business asset.  We will provide notice of any such transfer as required by applicable law.

4.7  With Your Consent.

We may share your information with additional parties where you have provided consent.  Consent may be withdrawn at any time, though withdrawal does not affect prior disclosures made in reliance on that consent.

5.   CONSENT

5.1  How We Obtain Consent.

Where consent is required under applicable law for a particular use or disclosure, we collect it through a clear and affirmative mechanism — such as a checkbox, toggle, or other consent interface — presented at the relevant point of interaction.  Consent to advertising, marketing, and data collaboration uses is entirely voluntary and separate from any consent required to receive the core service.  Declining these consents does not affect your ability to use the Platform's primary features.

5.2  SMS and Telemarketing.

We send promotional SMS messages only where we have obtained your prior express written consent in compliance with the Telephone Consumer Protection Act (TCPA) in the United States, the Canadian Anti-Spam Legislation (CASL) in Canada, and equivalent requirements in other markets.  SMS consent is obtained through a standalone opt-in, separate from all other consent mechanisms.  You may opt out of promotional SMS at any time by replying STOP to any promotional message.

5.3  Location-Based Features.

Precise location and proximity-based features require consent through your device's operating system permissions.  You may grant or revoke location permission at any time through your device settings without affecting your ability to use other parts of the Platform.

5.4  Withdrawing Consent.

You may withdraw consent for any consent-based use at any time by contacting us or using the controls described in Section 9.  Withdrawal of consent does not affect the lawfulness of any processing that occurred prior to withdrawal.

6.   LOCATION DATA AND PROXIMITY FEATURES

Location information — including transaction-point data, IP-based approximate location, device GPS, and proximity signals — is a core data type within the Platform.  We use location data to provide location-relevant features and experiences, to deliver contextual marketing and promotions, to analyze venue and point-of-interest performance, to support our advertising and media functions, and for any other purpose described in this Policy.

Precise GPS coordinates are used for real-time feature delivery and are not stored persistently beyond the active session.  Venue-level and city or region location data associated with transactions is retained as part of the transaction record in accordance with Section 8.

7.   INTEGRATED PLATFORM ECOSYSTEM

The Platform is designed to grow.  New products, services, and business lines launched under the FUZE brand after the Effective Date of this Policy are automatically incorporated into this Policy from the date they launch, unless we provide a separate supplemental notice.  Transaction data, usage data, behavioral signals, and other information collected through any new FUZE product will be integrated into our unified data environment and used for all purposes described in this Policy — including advertising, marketing, data intelligence, and data collaboration — without requiring a separate policy update.

This design reflects our intent to operate the Platform as a unified ecosystem.  Your acceptance of this Policy covers all current and future FUZE products and services to the fullest extent permitted by applicable law.

8.   DATA RETENTION

We retain personal information only for so long as necessary to fulfill the purposes described in this Policy, to comply with our legal obligations, and to resolve disputes and enforce our agreements.  Retention periods by category are as follows:

(a)  Account and identity data:  for the duration of your account plus seven (7) years;

(b)  Transaction and usage data across all Platform products:  for the duration of your account plus seven (7) years;

(c)  Behavioral, interest, and audience data:  up to twenty-four (24) months from your last Platform interaction, after which such data is deleted or de-identified;

(d)  Precise GPS location data:  not stored persistently; deleted upon session end;

(e)  Venue-level and city-level location data:  retained as part of the transaction record per subsection (b) above;

(f)  Marketing consent records:  for the duration of your account plus three (3) years;

(g)  SMS marketing consent records:  four (4) years from the date of opt-in;

(h)  Cookie and digital tracking data:  up to thirteen (13) months from collection; and

(i)  Legal hold and compliance records:  as required by applicable law or litigation hold.

We apply data minimization principles and periodically review our retention practices to ensure information is not held longer than necessary.

9.   YOUR CONTROLS AND CHOICES

The following controls are available to all users regardless of location, in addition to any jurisdiction-specific rights described in Section 10.

9.1  Marketing Communications.

You may opt out of marketing communications at any time by:  (a) using the unsubscribe link in any marketing email; (b) replying STOP to any promotional text message; (c) adjusting push notification settings in your device's operating system; or (d) adjusting in-app notification preferences within the Platform application.

9.2  Opt Out of Sale or Sharing for Targeted Advertising.

To opt out of the sale or sharing of your personal information for cross-context behavioral or targeted advertising purposes:  (a) use the "Do Not Sell or Share My Personal Information / Opt Out of Targeted Advertising" link available in the footer of our websites and within the Platform application's privacy settings; (b) submit a request through the privacy request form on our website; or (c) where applicable, we honor the Global Privacy Control (GPC) browser signal as a valid opt-out from sale and sharing for users in applicable jurisdictions.

9.3  Location Controls.

You may withdraw precise location permission at any time through your device operating system settings.  To opt out of proximity or geofencing-based communications, submit a request through the privacy request form on our website.

9.4  Industry Opt-Out Tools.

Additional opt-out tools are available through the following industry resources:  the Digital Advertising Alliance at aboutads.info/choices (and the AppChoices mobile app at youradchoices.com/appchoices); the Network Advertising Initiative at networkadvertising.org/choices; the European Interactive Digital Advertising Alliance at youronlinechoices.eu; and the Australian Ad Choices program at youronlinechoices.com.au.

9.5  Access, Correction, and Deletion.

You may request access to, correction of, or deletion of your personal information at any time by submitting a request through the privacy request form on our website.  Jurisdiction-specific rights and procedures are described in Section 10.

10.   JURISDICTION-SPECIFIC RIGHTS

Depending on where you live, you may have additional rights under local law.  The following provisions apply to residents of the identified jurisdictions.

10.1  United States.

(a)  California — CCPA / CPRA. California residents have rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), including:  the right to know and access personal information we have collected; the right to correct inaccurate personal information; the right to delete personal information, subject to legal exceptions; the right to opt out of the sale or sharing of personal information for cross-context behavioral advertising; the right to limit our use of sensitive personal information; and the right not to be discriminated against for exercising these rights.  We honor the Global Privacy Control (GPC) browser signal as a valid opt-out from sale and sharing for California residents.  We sell and share the following categories of personal information for cross-context behavioral advertising:  identifiers, device information, internet or electronic network activity, geolocation data, and inferences derived from such data.  We will acknowledge requests within ten (10) business days and respond within forty-five (45) days, extendable by an additional forty-five (45) days with notice.  Authorized agents may submit requests with appropriate proof of authorization.

(b)  Other U.S. States.  Residents of Colorado, Connecticut, Virginia, Texas, Oregon, Montana, Nebraska, New Hampshire, New Jersey, Delaware, Iowa, Minnesota, Maryland, Indiana, Kentucky, Rhode Island, Tennessee, and any other U.S. state with a comprehensive consumer privacy law in effect have rights under their respective state laws, including rights to access, correct, delete, and opt out of targeted advertising and profiling.  We will respond to requests within the timeframes required by applicable state law and honor all available appeal rights.

10.2  Canada.

Our processing of personal information about Canadian residents is governed by the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation, including Quebec's Act respecting the protection of personal information in the private sector (Law 25).  We collect, use, and disclose personal information with knowledge and appropriate consent, and only for purposes a reasonable person would consider appropriate in the circumstances.  You have the right to access and request correction of your personal information, to withdraw consent for non-essential uses, and to file a complaint with the Office of the Privacy Commissioner of Canada at priv.gc.ca.  Quebec residents have additional rights including rights related to automated decision-making and de-indexing.  In the event of a breach posing a real risk of significant harm, we will notify affected individuals and applicable authorities as required by law.

10.3  Mexico.

Our processing of personal data about Mexican residents is governed by the Federal Law on Protection of Personal Data Held by Private Parties (LFPDPPP) and its regulations.  This Policy constitutes our Aviso de Privacidad for Mexican residents.  Primary purposes of processing are those necessary to provide the core service.  Secondary purposes — including marketing, personalization, advertising, and data intelligence — may be declined without affecting the core service.  You have the ARCO rights of Access (Acceso), Rectification (Rectificacion), Cancellation (Cancelacion), and Objection (Oposicion).  To exercise these rights, submit a request through our website's privacy request form, referencing "ARCO Request — Mexico."  We will respond within twenty (20) business days.

10.4  Australia.

Our handling of personal information about Australian residents is governed by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).  We are an APP entity.  You have the right to access the personal information we hold about you (APP 12), to request correction of inaccurate or incomplete information (APP 13), and to opt out of direct marketing at any time (APP 7).  We are likely to disclose personal information to overseas recipients, including in the United States and other jurisdictions where our service providers and partners operate.  By using the Platform, you consent to this cross-border disclosure.  You may submit a complaint to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.  Submit privacy requests through our website's privacy request form, referencing "Australian Privacy."  We will respond within thirty (30) days.

10.5  United Kingdom.

Our processing of personal data about UK residents is governed by the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.  The UK data controller is Fuze Technology UK Limited.  UK residents have rights of:  access; rectification; erasure; restriction of processing; data portability; objection (including to direct marketing and profiling); rights in relation to automated decision-making; and the right to withdraw consent at any time without affecting the lawfulness of prior processing.  You may lodge a complaint with the Information Commissioner's Office at ico.org.uk.  International transfers from the UK use UK-approved Standard Contractual Clauses or another lawful transfer mechanism recognized under UK law.

10.6  European Union and EEA.

Our processing of personal data about EU and EEA residents is governed by Regulation (EU) 2016/679 (GDPR).  The EU-facing controller is Fuze Technology UK Limited.  EU and EEA residents have all rights described for UK residents in Section 10.5, exercisable under EU GDPR.  You may lodge a complaint with your national supervisory authority.  International transfers from the EU and EEA are made using European Commission Standard Contractual Clauses (SCCs) or another lawful transfer mechanism recognized under EU law.  Processing for advertising and audience profiling purposes is conducted on the basis of consent under Article 6(1)(a) of the GDPR.

11.   INTERNATIONAL DATA TRANSFERS

Fuze Technology Inc. operates globally.  Your information may be transferred to, stored in, and processed in the United States and in any other country where we or our service providers and partners maintain operations.  Data protection standards in those jurisdictions may differ from those applicable in your home jurisdiction.  By using the Platform, you acknowledge this transfer.  Where required by applicable law, we implement appropriate safeguards — such as Standard Contractual Clauses for EU and UK transfers — to protect personal information during international transfer.

12.   DATA SECURITY

We implement administrative, technical, and physical security measures proportionate to the sensitivity of the information we process, including access controls, authentication requirements, encryption in transit, and security monitoring.  Access to personal information is limited to personnel and systems that require it to fulfill the purposes described in this Policy.  In the event of a personal data breach, we will notify affected individuals and applicable regulatory authorities as required by law.

13.   MINORS

We do not knowingly collect, use for advertising purposes, sell, or share the personal information of individuals we know to be under the age of thirteen (13), or under the age of sixteen (16) for advertising and profiling purposes in jurisdictions where that higher threshold applies.  If we become aware that we have inadvertently collected personal information from an individual below the applicable minimum age, we will delete such information promptly.  We do not sell or share the personal information of individuals below the applicable minimum age for any advertising purpose under any circumstances.

14.   THIRD-PARTY LINKS AND SERVICES

The Platform may link to or integrate with third-party websites, applications, and services that are not operated by Fuze Technology Inc.  This Policy does not apply to those third-party services, and we are not responsible for their privacy practices.  We encourage you to review the privacy notices of any third-party services you access through the Platform.

15.   SUBMITTING A PRIVACY REQUEST

To exercise any right described in this Policy — including rights of access, correction, deletion, opt-out, or data portability — please submit a request through the privacy request form available on our website.

Your request should include sufficient information to identify you, such as the name and phone number or email address associated with your account, and should specify the jurisdiction whose law you are relying on.  Please do not include payment card numbers, government identification numbers, or other sensitive credentials in your request.

We will verify your identity before processing any request and will respond within the timeframe required by applicable law — generally thirty (30) to forty-five (45) days from the date of receipt, with extensions available upon notice where permitted by law.

16.   MODIFICATIONS TO THIS POLICY

Fuze Technology Inc. reserves the right to modify, amend, or replace this Policy at any time and for any reason, in its sole discretion.  When we make changes, we will post the revised Policy on our website and update the Effective Date at the top of this document.  The most current version of this Policy is always available on our website, and posting constitutes sufficient notice of any modification.

Where required by applicable law, we will provide additional notice of material changes through one or more of the following methods, as determined by Fuze in its discretion:  a notice posted on our website; a notification within the Platform or App; a communication to the contact information associated with your account; or any other means we deem appropriate under the circumstances.  The timing, format, and method of any such additional notice will be determined by Fuze in compliance with the minimum requirements of applicable law in the relevant jurisdiction.

Your continued use of any part of the Platform after the effective date of a revised Policy constitutes your acceptance of the Policy as modified.  If you do not agree to the revised Policy, you should discontinue your use of the Platform.  Where applicable law requires affirmative consent to material changes rather than continued-use acceptance, we will obtain such consent as required.

You are responsible for reviewing this Policy periodically to remain informed of any changes.  Your continued use of the Platform following any modification confirms your acknowledgment of and agreement to the modified Policy.

Fuze Technology Inc.
This Policy governs all current and future FUZE products and services.