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PRIVACY POLICY

This Privacy Policy was last revised on October 4, 2011.

Front Flip, LLC. ("Front Flip," "we," or "us"), knows that you care how information about you is used and shared. We are keenly aware of the trust you place in us and we are committed to maintaining the privacy and confidentiality of the personal information we collect. As part of this commitment, we let you know what information we collect when you use our websites products and services (the "Service"), why we collect it and how we use it to improve your experience.

KEY PRINCIPLES

We adhere to a few key principles when it comes to your privacy:

  • We will tell you how and why we use certain data
  • We offer users meaningful choices to protect their privacy
  • We use information to provide our users with valuable products and service
  • We are a responsible steward of the information we hold

We will not use or share your information with anyone except as described in this Privacy Policy. Capitalized terms that are not defined in this policy are defined in our Terms of Use. We expect that Users will use Front Flip for harmless and fun social purposes. Please note, though, that by its nature, your information is subject to abuse, misuse, and over-monitoring by others. Please manage your own mobile and profile privacy preferences on the Service, on an ongoing basis, accordingly.

USING THE FRONT FLIP MOBILE SERVICE

In order to use the mobile features of the Front Flip Service, you must consent to: (a) the use of your phone's location to provide the Service to you and (b) pay carrier data, messaging, and other fees resulting from Front Flip usage. Data plans are required to use the mobile features of the Front Flip Service. Standard data and messaging charges, fees, and taxes from your carrier apply.

INFORMATION WE COLLECT

1. User-provided information: You can either provide us information about yourself, such as your first name, last name, e-mail address, profile photos and password if you register for a Member account with the Service, or you can sign in through Facebook, which gives us access to information made available by Facebook. In order to use the Service we also ask you to share your gender, age and zip code. We need this information, because as part of Front Flip's Service we may send you gifts from (local) merchants and retailers that we think you may like.

When using the Service, you may also provide certain other personal information and content, such as locations you visit. When you scan a Flip Code at a participating business location, the Service will register that scan.

2. Recommendations. As part of Front Flip's platform you have the opportunity to write a recommendation about a business. These recommendations will be publicly displayed to other Users and on third-party sites and services in accordance with your privacy and opt-in settings.

3. Location Tracking. To provide the mobile features of the Service, we derive location information from your wireless carrier, certain third-party service providers, or directly from the mobile device that you used to register with Front Flip. This location tracking of your mobile device occurs only when the Front Flip mobile application is actively open and running.

4. Location Information: To provide the Service, we collect, use and store your personal data and the geographic location of your mobile device (we call this location fix of your mobile device "location information").

5. Flip Code Scanning Location. As a user of our Service you have the chance to scan Flip Codes at participating Front Flip businesses. Front Flip will store location and time of every scan.

6. Anonymous Information We Collect. In general, you can visit Front Flip on the World Wide Web without telling us who you are or revealing any personal information about yourself. Like most standard website servers, we use log files. Log files track Internet protocol (IP) addresses, browser type, Internet service Provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks. . This information is used to diagnose problems with our server, measure the number of visits and number of pages viewed, and register methods by which our site was found and methods used for viewing our site. We will use this information to analyze trends, administer the site, prevent fraud, track website navigation in the aggregate, gather broad demographic information for aggregate use, evaluate how you use our Web site and how we improve the content of the site.

HOW WE USE YOUR INFORMATION

We use the personal information you submit to operate, maintain, and provide to you the features and functionality of the Service.

We never share your personal information with advertisers, except for the business where you scanned their specific Flip Code (including the legal entity which manages the respective business on Front Flip's platform). Other businesses, merchants, advertisers or other third parties will only get access to anonymous data. If advertisers select demographic targeting for their ads, Front Flip automatically matches those ads to the appropriate audience. You may receive ads from these advertisers that we forward to you, but the advertisers only receive anonymous information and data reports.

Any personal information or content that you voluntarily disclose for posting through the Service (i.e., Recommendations) becomes available to the public. Front Flip is not responsible for the personal information that you choose to disclose publicly through the Service. If you remove information that you posted through the Service, copies may remain viewable in cached and archived pages of the Service on third party sites, or if other Users have copied or saved that information.

By providing Front Flip your email address, you consent to our using the email address to send you Service-related notices, including any notices required by law, in lieu of communication by postal mail. We may also use your email address to send you other messages, such as newsletters, changes to features of the Service, or special offers.

Front Flip may use certain information about you and/or your User Content without identifying you as an individual to third parties. We do this for purposes such as analyzing how the Service is used, diagnosing service or technical problems, maintaining security, and personalizing content. Third parties providing services to us may have access to your personal information but are required to maintain its confidentiality and use it only on our behalf.

We may also share your information with our service providers for the purpose of operating the Service and facilitating the services you request. This includes service providers we utilize for payment processing, mailing, email, technology support and other such services.

Front Flip reserves the right, but has no obligation, to monitor the User Content you post on the site. We reserve the right to remove any such information or material for any reason or no reason, including without limitation if in our sole opinion such information or material violates, or may violate, any applicable law or our Terms of Use Agreement, or to protect or defend our rights or property or those of any third party. Front Flip also reserves the right to remove information upon the request of any third party.

Front Flip may make use of an Internet tool called "cookies" in order to provide you with tailored information and for identification purposes. A cookie is a small piece of data that a Web site can send to your browser, which may then be stored on your hard drive so we can recognize you when you return. We may in the future contain electronic images known as Web beacons (sometimes called clear gifts or Web bugs) or other advanced technologies that are useful in the provision of services to you. We may use such devices to verify compliance with our terms and conditions of use or with rules for any promotions on the site.

HOW WE SHARE YOUR INFORMATION

1. Personally Identifiable Information: whenever you scan a Flip Code at a participating Front Flip business, that business (including the legal entity which manages the respective business on Front Flip's platform) will be able to see time of the transaction, your first name, initial of your last name, what you scanned for and any photo associated with your account. The Service will store your scan history for that business.

Businesses where you scan a FlipCode will be able to send you gifts (up to one per month maximum) unless you choose to opt out (under settings in the mobile application) to receive gifts from this location. These businesses can select to send you a gift based on your visit history, gender, age and your zip code.

We may selectively send you gifts from businesses where you have not been yet that we think you may like. These businesses can use age, gender, zip code and personally-identifiable location information (e.g. sort of restaurants you visit), for targeting. We will only share such information within these businesses on an anonymous basis until you have scanned a FlipCode at their business.

Front Flip does not share your personally identifiable information or personally-identifiable location information with other, third-party companies for their commercial or marketing use without your express consent or unless you have opted-in to be part of a specific program or feature. We cannot control third parties' use of your information. If you do not want your information to be collected by or shared with such a third party, you can choose not to participate in such programs or features.

As we develop our business, we may buy or sell assets or business offerings. Customer, email, and visitor information is generally one of the transferred business assets in these types of transactions and may be disclosed in negotiations relating to a proposed transaction. We may also transfer such information in the course of corporate divestitures, mergers, or dissolution. In the cases discussed in this paragraph, the transferred information may become subject to a different privacy policy.

Except as otherwise described in this Privacy Policy, Front Flip will not disclose personal information to any third party unless required to do so by law or subpoena or if we believe that such action is necessary to (a) conform to the law, comply with legal process served on us or our affiliates, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) to enforce our Terms of Use, take precautions against liability, to investigate and defend ourselves against any third-party claims or allegations, to assist government enforcement agencies, or to protect the security or integrity of our site; and (c) to exercise or protect the rights, property, or personal safety of Front Flip, our Users or others.

2. Non-Personally Identifiable Information: We may share non-personally identifiable information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third parties to help them understand the usage patterns for certain Front Flip services.

HOW WE PROTECT YOUR INFORMATION

Front Flip uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. We cannot, however, ensure or warrant the security of any information you transmit to Front Flip and you do so at your own risk. Once we receive your transmission of information, Front Flip makes commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from Front Flip, at all times.

Keeping your personal financial information private is very important to us. As a matter of policy and business practice, we do not sell information provided by our users. Any user statistics that we may provide to prospective partners regarding financial matters are provided in the aggregate only and do not include any personally identifiable information about any individual user. We will transfer your credit card number or other personal information to the appropriate credit card company or third party payment processor in order to process any online payments.

COMPROMISE OF PERSONAL INFORMATION

In the event that personal information is compromised as a result of a breach of security, Front Flip will promptly notify those persons whose personal information has been compromised, in accordance with the notification procedures set forth in this Privacy Policy, or as otherwise required by applicable law.

YOUR SETTINGS

You may, of course, decline to submit personally identifiable information through the Service, in which case Front Flip may not be able to provide certain services to you. You may update or correct your account information and settings at any time by logging in to your account.

You can choose to receive a notification when you receive a gift. By default the settings is ON, but you may choose to switch this off.

Businesses from which you have scanned the Flip Code will register in your settings as places that can send you a gift. By default the settings is ON, but you may choose to switch this off.

CHILDREN'S PRIVACY

Protecting the privacy of young children is especially important. For that reason, Front Flip does not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to register as Members. If you are under 13, please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 13 is allowed to provide any personal information to or on Front Flip. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact at Front Flip.com.

LINKS TO OTHER WEB SITES

We are not responsible for the practices employed by websites linked to or from our website, nor the information or content contained therein. Please remember that when you use a link to go from our website to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including those that have a link on our website, is subject to that website's own rules and policies. Please read over those rules and policies before proceeding.

NOTIFICATION PROCEDURES

It is our policy to provide notifications, whether such notifications are required by law or are for marketing or other business related purposes, to you via email notice or through conspicuous posting of such notice on our website and/or other social media, as determined by Front Flip in its sole discretion. We reserve the right to determine the form and means of providing notifications to you, provided that you may opt out of certain means of notification as described in this Privacy Policy.

CHANGES TO OUR PRIVACY POLICY

If we change our privacy policies and procedures, we will post those changes on our website to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it. Changes to this Privacy Policy are effective when they are posted on this page.

CONTACT INFORMATION

If you have any questions about this Privacy Policy or the Service, please contact us at privacy@Front Flip.com, or send mail to:
Front Flip, LLC
5250 W. 116th Place, Suite 200
Leawood
KS, 66211

EU DATA DIRECTIVE PRIVACY NOTICE

Front Flip is committed to compliance with its privacy obligations in the United States and throughout the world. This EU Data Directive Privacy Notice sets forth the privacy principles Front Flip follows with respect to personal information transferred from within the European Union to the United States. This notice applies to the personal information of European Union Citizens maintained by Front Flip in the Front Flip database.

PRIVACY PRINCIPLES

NOTICE

Front Flip notifies data subjects about the purposes for which we collect and use information about them. See "Information We Collect" and "How Do We Use Your Information?" above. Individuals may contact Front Flip's privacy director with the contact information provided below with any inquiries or complaints or to request information about the types of third parties (other than third party processors) to which it discloses the information and the choices and means it offers for limiting use and disclosure of personal information.

CHOICE

Front Flip gives you the opportunity to choose whether your information will be disclosed to a third party (other than service providers) or used for a purpose incompatible with the purpose for which it was originally collected or subsequently authorized by the individual. See below for details on how to update or remove your information.

ACCESS

You may access your personally identifiable information that we have on file. If you would like to access your information or if you believe that any personal information we have about is incorrect, or has been or might be inappropriately used, please contact privacy@Front Flip.com. We will provide you with access to such information in a reasonable amount of time.

SECURITY

Front Flip will take reasonable steps to protect your Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. We have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. We cannot guarantee the security of Information on or transmitted via the Internet. We use Secure Socket Layer encryption for transmitting and storing your information and for payment transactions, and we store your information in limited access servers.

DATA INTEGRITY

Front Flip only processes personal information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, Front Flip will take reasonable steps to ensure that personal information is accurate, complete, current and reliable for its intended use

ONWARD TRANSFER

Front Flip transfers personal information only to those third parties who: (a) have agreed, in writing, to provide at least the same level of privacy protection to the personal information as is required under the EU Data Directive or the related Safe Harbor Principles; and/or (b) adhere to the Safe Harbor Principles. Exceptions to this limitation on onward transfer include where a data subject has granted Front Flip expresses permission to transfer his or her data to the third party, or, where such transfer is necessary for the purpose of meeting an applicable legal requirement.

LIMITATIONS

Our adherence to these principles may be limited to the extent required to respond to a legal or ethical obligation and to the extent expressly permitted by an applicable law, rule or regulation.

CONTACT FRONT FLIP

If you have any questions about this Privacy Policy, please contact Front Flip at: 

Front Flip LLC.
Attn: Privacy Director
5250 W. 116th Place, Suite 200
Leawood, KS 66211
privacy@frontflip.com 
1.855.730.1830

ENFORCEMENT

Front Flip uses a self-assessment approach to assure compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the privacy principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information in accordance with the privacy principles.

If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using (an independent resource mechanism) as a third party resolution provider or if you are unsatisfied with our response to your inquiry and you are located in the EU, you may report complaints to the EU Data Protection Authority ("DPA"). By voluntarily certifying that it will comply with the Safe Harbor Principles, Front Flip has made itself subject to the dispute resolution, enforcement, and sanctioning powers of the DPA and has agreed to cooperate and comply with the applicable DPA in regard to Front Flip's processing of personal information.