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PRIVACY POLICY

Privacy Policy
Privacy Policy for Paytronix Systems, Inc.

Last Revised: May 24, 2018



Paytronix is committed to protecting and respecting your privacy. This microsite
https://cpkrewards.myguestaccount.com/guest is hosted by Paytronix on behalf of
our client California Pizza Kitchen otherwise referred to as The Brand
throughout this document. Please refer to California Pizza Kitchen privacy
policy for its use of your data. This Policy explains how Paytronix collects,
stores, uses and protects personal information about people who visit its
myguestaccount microsites.

We may change this Policy from time to time, so please check this page
occasionally to ensure that you're happy with any changes. By using this
microsite, you're agreeing to be bound by this Policy.

Who are we?

Paytronix Systems, Inc., provides gift and loyalty programs for restaurants and
convenience stores. We process transactions, provide a marketing platform, and
analyze the data for those programs on behalf of these retail chains.

For details regarding the privacy policy as it relates to data we process on
behalf of a gift or loyalty program please contact The Brand for which the
program exists.

How do we collect information from you?

When you join a loyalty or gift program hosted by Paytronix or an existing
program is migrated to Paytronix by The Brand that operates the program, we
begin collecting, storing, and making your data available to The Brand through
our merchant interface. Programs may include an online registration form, an
interactive SMS flow, interactions through email, interactions through a mobile
phone app, activity at the point-of-sale, or the transfer of your data from The
Brand another way. For example, some brands use paper registration forms to
collect program member data.

While you are a member of a loyalty or gift program, we collect information the
following ways:

 * Microsites: Paytronix provides microsites and other ways for brands to
   deliver and collect member information to members. These sites may include a
   registration page, profile editing page, refer a friend, transaction history,
   e-gift purchases, physical gift card purchases, and more.
 * Your browser or device: Certain information is collected by most browsers or
   automatically through your device, such as your Media Access Control (MAC)
   address, computer type (Windows or Macintosh), screen resolution, operating
   system name and version, device manufacturer and model, language, Internet
   browser type and version, and browser click-through and usage data.
 * Cookies: Cookies are pieces of information stored directly on the computer
   that you are using. Our websites, personalized promotions, and emails use
   cookies, pixel tags, and other technologies to automatically collect
   information about your interactions, such as browser type, pages viewed,
   links clicked, and other actions you take in connection with our websites,
   online ads, and email. We use the information for a variety of purposes,
   including to facilitate navigation, to display information more effectively,
   to personalize your experience, to understand how our websites are used, to
   market our products and services, to measure the success of our marketing
   campaigns, and for security purposes.
   
   Cookies are necessary for the proper use of the microsite, so that we can
   maintain access privileges and security of the site. If you do not accept
   cookies, you will not be able to use the microsite interface.
 * Using pixel tags and other similar technologies: We may use pixel tags to,
   among other things, track the actions of users of our sites and services
   (including email recipients), measure the success of our marketing campaigns
   and compile statistics about usage of our sites and services and response
   rates.
 * Analytics: We use third-party service providers, including Google, which use
   cookies and similar technologies to collect and analyze information about use
   of our website. This service may also collect information regarding the use
   of other websites, apps and online resources. You can learn about Google's
   practices at http://www.google.com/policies/privacy/partners/, and opt out by
   using the Google Analytics Opt-Out Browser Add-on, available at
   https://tools.google.com/dlpage/gaoptout.
 * IP Address: Your Internet Protocol ("IP") address is a number that is
   automatically assigned to the computer that you are using by your Internet
   Service Provider (ISP). An IP address may be identified and logged
   automatically in our server log files whenever you access our websites, along
   with the time of the visit and the pages that were visited. Your IP address
   may also indicate your approximate physical location. Collecting IP addresses
   is standard practice and is done automatically by many websites, applications
   and other technologies. We use IP addresses for purposes such as calculating
   usage levels and diagnosing networking, server and software problems and for
   tracking and detecting fraudulent behavior.
 * In Store Technologies: We track purchase behavior at the point-of-sale for
   the purpose of operating loyalty and gift programs.
 * Mobile Applications: When you download one of our mobile applications, we may
   track and collect usage data such as date and time the app accesses our
   servers and what information and files have been accessed, viewed and our
   downloaded to the app based on your device number or other identifier. If you
   allow the mobile app to collect location information, we may receive the
   precise location of your mobile device, such as your device's precise GPS
   coordinates. Typically, you give permission to do so through your device's
   mobile operating system. If you grant permission we may collect that
   information while the device is running in the foreground or background. You
   may disable the app's collection of location information through your
   device's mobile operating system.



What type of information is collected from you?

We may collect personal information with information from you, such as your
name, email address, postal address, phone number, gender, birthday, personal
interests, etc., when you engage in activities such as visiting one of our
microsites, The Brands' locations, installing or using our mobile apps, placing
an order online, saving your information with us online, interacting with an
email, contacting us with a question or concern, or participating in a contest,
promotion, or survey. We may maintain a record of your product interests and the
purchases you make online, through a mobile app, by phone and in The Brands'
stores. Through the point of sale, we may track the location of the transaction,
the date and time of the transaction, what was purchased and other details of
the transaction. This data may be necessary for the operation of the loyalty
program so that rewards can be earned and redeemed or gift program so that
currency can be added or redeemed. Personal information, such as phone number,
may be used at the point-of-sale as an identifier to your account information so
that a transaction can be processed for your account.

We may combine personal information about your online and in-store transactions
and other interactions with us, including your purchases. We may also combine
your personal information with information we receive from other sources
provided by The Brand, public databases, publicly available pages on social
media platforms and other third parties. In addition, if you choose to engage in
social sharing, such as by connecting your social media account to your customer
account or by logging into your customer account from your social media account,
the social media site may share information with us about your use of their
services, including profile information, information about your contacts and
content you have viewed or liked. Please refer to the social media site's
privacy settings to control how your information is shared.

If you submit any personal information relating to other people to us or to our
service providers, you represent that you have the authority to do so and to
permit us to use the information in accordance with this Privacy Policy.

How is your information used?



 * Enable you to enroll and participate in a loyalty, gift, or customer
   relationship program.
 * Grant access to your account information.
 * Enable you to identify yourself to earn or redeem loyalty currency or add or
   redeem stored value currency.
 * Process transactions for the purpose of adding or redeeming gift currency or
   earning and redeeming loyalty currency.
 * Enhance the app experience. With device location information we help you
   locate stores and check in to stores to identify yourself for the purpose of
   earning and redeeming loyalty currency.
 * Communication. The Brand may use the data to communicate with you through
   targeted marketing and account-related messages that arrive via your mobile
   device, mobile app, email inbox, or via SMS depending on your opt in status.
 * Prevent, detect, mitigate, and investigate fraud, security breaches and
   activities that are or potentially may be prohibited or illegal.
 * As we believe to be required or appropriate to protect the rights, property,
   safety, and security of Paytronix and its employees, customers, and others.
 * As we believe to be required or appropriate under applicable law.



We will hold your personal information in our systems for as long as is
necessary for the relevant activity, or as long as is defined in any relevant
contract you hold with The Brand.

For handling of EU data, please see The Brand's privacy policy. We will commit
to providing "opt out" options as well as the ability for those who reside in
the EU to delete their information from our database.

Who has access to your information?

Paytronix and the users from the program's brand owner that have credentials to
access our merchant portal have access to your information.

Paytronix will not sell or rent your information to third parties.

We will not share your information with third parties, unless specifically
instructed to do so by The Brand.

Third-party service providers working on our behalf: We may pass your
information to our third-party service providers, subcontractors and other
associated organizations for purpose of completing tasks and providing services
to The Brand. However, when we use third-party service providers, we disclose
only the personal information that is necessary to deliver the service and we
have a contract in place that requires them to keep your information secure and
not to use it for their own direct marketing purposes. Please be reassured that
we will not release your information to third parties beyond the Paytronix
Network for them to use for their own direct marketing purposes, unless you have
requested us to do so, or we are required to do so by law, for example, by a
court order or for the purposes of prevention of fraud or other crime.

We may transfer your personal information to a third party as part of a sale of
some or all of our business and assets to any third party or as part of any
business restructuring or reorganization, or if we're under a duty to disclose
or share your personal data in order to comply with any legal obligation or to
enforce or apply our terms of use or to protect the rights, property or safety
of our supporters and customers. However, we will take steps with the aim of
ensuring that your privacy rights continue to be protected.


Your choices

You have a choice about whether you wish to receive information from The Brand.
If you do not want to receive communications from The Brand, then you can opt
out.

If you reside in the EU:

Direct communications to you are governed by The Brand. Paytronix provides the
tools The Brand uses to provide you with access to your data, give you the
ability to opt-out, or to be forgotten.

How you can access and update your information

The accuracy of your information is important to us. We're working on ways to
make it easier for you to review and correct the information that we hold about
you. The microsite provides tools to access and update your information here:
https://cpkrewards.myguestaccount.com/guest/profile. Please contact The Brand
with questions on your data, for the right to access your data, or if you want
to be forgotten.

Security precautions in place to protect the loss, misuse or alteration of your
information

For certain programs, we may collect sensitive data (credit cards, debit cards)
over the Internet. We protect this data by encrypting in transit and at rest. We
enable you to delete this information from the microsite or by contacting The
Brand for whom we host the microsite.

We provide industry-standard physical, electronic, and procedural safeguards to
protect information we process and maintain. For example, we take reasonable
measures to limit access to this information to authorized employees and
contractors who need to know that information in order to operate, develop or
improve our service. Please be aware that, although we endeavor to provide
reasonable security for information we process and maintain, no security system
can prevent all potential security breaches. As a result, we cannot guarantee or
warrant the security of any information you transmit on or through the service
and you do so at your own risk

Profiling

We may analyze your personal information to create a profile of your interests
and preferences so that The Brand can contact you with information relevant to
you. We may make use of additional information about you when it is available
from external sources to help us do this effectively.

Links to other websites

The microsite may contain links to other websites run by other organizations.
This privacy policy applies only to the microsite, so we encourage you to read
the privacy statements on the other websites you visit. We cannot be responsible
for the privacy policies and practices of The Brand and other sites, even if you
access them using links from our website.

In addition, if you have accessed the microsite from a third-party site, we
cannot be responsible for the privacy policies and practices of the owners and
operators of that third-party site and recommend that you check the policy of
that third-party site.

How does Paytronix protect kids' privacy?

Paytronix is concerned about the privacy and safety of children when they use
the Internet. We will never knowingly request personally identifiable
information online from anyone under the age of 16 in the EU or under 13 outside
the EU, without prior verifiable parental consent. If you are under these ages
please contact the program administrator and have your personal information
removed.

How do I contact you?


Please contact The Brand with questions or comments regarding your data. If you
have attempted to reach The Brand, and have not received a response, please
contact Paytronix and include The Brand information in your communication:

 * By mail to:

Paytronix
Att: Privacy Policy Guests
80 Bridge Street
Newton, MA 02458

Review of this Policy

We keep this Policy under regular review and we may change this privacy
statement from time to time. If we do, we will post the revised version here and
change the last updated date (the date it applies from) at the top of the
statement. You should check here regularly for the most up-to-date version of
the statement. This Policy was last updated on May 24, 2018.


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