How we handle
your data

Last Updated: October 2, 2024

Gratis Intelligence (referred to as “Gratis Intelligence,” “we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use the Gratis Intelligence platform (the “Platform”), and the rights and choices you have in relation to your data. This Policy also details our compliance with U.S. state privacy laws, including but not limited to the California Consumer Privacy Act (CCPA), Virginia Consumer Data Protection Act (VCDPA), and other applicable state laws.

1. Introduction and Scope

This Privacy Policy applies to all users of our Platform, including individuals who use our services to engage with venues, track purchases, and participate in events. By accessing or using the Platform, you agree to the terms outlined in this Privacy Policy.

We encourage you to read this Privacy Policy carefully. If you do not agree with any part of this policy, please discontinue use of our services.

2. Who We Are

Gratis Intelligence is a data and analytics platform that serves bars, restaurants, and consumers. Our Platform allows users to analyze sales data, capture insights, and foster relationships with beverage suppliers and wholesalers. In doing so, we collect and process personal information to provide these services.

3. Information We Collect

We collect several categories of information from and about our users, including:

• Personal Information You Provide Directly: This includes your name, email address, date of birth, phone number, geographic location, and confirmation that you are 21 years of age or older. You provide this information when you sign up for our services, use the Platform, or participate in events or promotions.
• Automatically Collected Information: When you use the Platform, we automatically collect data such as purchase history, location data, and device identifiers. This data includes information on the food and drinks ordered, the cost of items, and the location of purchases.
• Cookies and Tracking Technologies: We use cookies, web beacons, and similar technologies to track your location and activity on the Platform. This includes collecting data even when the Platform is in the background, unless you opt out through your device settings.
• Third-Party Data: We may also receive data from third-party sources, such as credit firms, and combine this with data we collect to provide more comprehensive insights.
• Anonymized Data: Certain information collected may be anonymized and shared with partners for research, analytics, or marketing purposes.

4. How We Use Your Information

We use the information we collect for the following purposes:

• Platform Operation and Functionality: To provide, operate, and maintain our Platform, ensuring that users can engage with venues and receive offers from industry partners.
• Communications: To communicate with you about your use of the Platform, including service messages, promotional offers, updates, and legal notices. While you can change your communication preferences, certain service messages cannot be opted out of, such as security or legal notifications.
• Marketing and Promotions: We may use your personal information for marketing purposes, including purchase-based and interest-based advertising. This involves presenting ads tailored to your preferences. We only share anonymized data with third-party advertisers.
• Research and Development: We use your data for internal analysis, research, and to develop new features for the Platform. This includes combining anonymized data sets for insights and improvement.
• Fraud Detection and Prevention: We use your information to protect the integrity of the Platform and prevent fraudulent activities, including multiple access to free drink offers or violations of promotional terms.
• Legal and Compliance Obligations: We may use your data to comply with legal obligations, respond to law enforcement requests, and address any legal claims or disputes.

5. Who We Share Your Information With

We may share your personal information with:

• Service Providers: Third-party service providers who assist in the operation of our Platform, such as data processors, hosting services, and communication platforms.
• Alcohol Industry Partners: Information may be shared with alcohol suppliers, wholesalers, or bars for promotional purposes. Data shared with these partners is typically anonymized.
• Regulatory Authorities: We may disclose your data to government agencies, law enforcement, or regulators as required by law, in response to legal requests, or to protect the safety and rights of others.
• Business Transfers: In the event of a merger, acquisition, or sale of the business, your personal information may be transferred as part of the transaction, provided that the acquiring party agrees to honor the terms of this Privacy Policy.

6. U.S. State Privacy Law Compliance

Gratis Intelligence adheres to the privacy regulations of several U.S. states, including but not limited to:

• California Consumer Privacy Act (CCPA): California residents have the right to request information about the personal data collected, disclosed, or sold; request deletion of personal data; opt-out of data sales; and receive equal service without discrimination for exercising these rights.
• Virginia Consumer Data Protection Act (VCDPA): Virginia residents can access, correct, delete, or obtain a copy of their personal data, as well as opt out of targeted advertising, data sales, and profiling.
• Colorado Privacy Act (CPA): Colorado residents are entitled to request access, correction, deletion of their data, and opt out of the sale of personal information. We will respond to requests in a timely manner as mandated by CPA regulations.
• Connecticut Data Privacy Act (CTDPA): Residents of Connecticut have the right to know the information collected, request correction or deletion of their personal data, and opt out of sales or targeted advertising.
• Utah Consumer Privacy Act (UCPA): Utah residents can exercise their rights to access, delete, and opt out of the sale of personal information.

7. Your Rights and Choices

Depending on your state of residence, you may have specific privacy rights under U.S. law, including:

• Right to Access: You may request access to the personal information we collect about you.
• Right to Correct: If the data we have about you is inaccurate or incomplete, you have the right to request correction.
• Right to Delete: You may request the deletion of personal information collected about you, subject to certain exceptions for legal or business purposes.
• Right to Opt-Out: You have the right to opt-out of the sale of your personal data. To exercise this right, contact us at privacy@gratisiq.com or use the opt-out link provided on our website.
• Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising your privacy rights.

8. Security of Your Information

We take reasonable steps to ensure that your data is protected using industry-standard encryption, secure data storage, and limited access to personal information. We regularly review and update our security protocols to address new threats.

9. Data Retention

We retain personal information for as long as necessary to provide the services you requested or for other legitimate business purposes, such as legal compliance or dispute resolution. We will securely delete or anonymize data when it is no longer required.

10. International Data Transfers

If you are located outside the United States, please be aware that your information may be transferred to and processed in the U.S. or other countries. We take steps to ensure your information is protected in compliance with applicable data protection laws.

11. Children’s Privacy

We do not knowingly collect personal information from individuals under the age of 21. If we become aware of any such data collection, we will take steps to delete that information.

12. Breach Notification Procedures

In the event of a data breach, we will notify affected individuals in accordance with applicable laws, including those of the California Data Breach Notification Law, as well as any other relevant state laws. Affected users will be notified via email and a notice on the Platform within a reasonable timeframe, describing the nature of the breach, the data involved, and steps taken to mitigate the risk.

13. User-Generated Content and Public Forums

If you participate in any public areas of the Platform (e.g., discussion forums, comments), please note that any information you share in these areas is public and not subject to the protections outlined in this Privacy Policy. Use caution when sharing personal information in these spaces, and be aware that others may collect and use such information.

14. Automated Decision-Making

We do not use automated decision-making processes that have legal or significant effects on individuals. However, if we implement such processes in the future, you will be notified and given the opportunity to opt out of automated decision-making systems that involve your personal data.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. Any significant changes will be communicated via email or through notices on our Platform.

16. Third-Party Links

Our Platform may contain links to other websites, applications, or services that are not owned or controlled by Gratis Intelligence. This Privacy Policy does not apply to those third-party services, and we are not responsible for their content, privacy practices, or data collection methods. We encourage you to review the privacy policies of those third parties before providing any personal data.

17. Contact Us

If you have any questions about this Privacy Policy or wish to exercise your privacy rights, please contact us at:

Email: privacy@gratisiq.com

Mailing Address: 90 West Houston, New York, NY 10012