Privacy Policy
Updated November 25, 2024
Cauldron Technologies, LLC ("Company", "we", or “us”) is committed to protecting your privacy through our compliance with this policy.
This Privacy Policy applies to information that we collect on the Website at www.cauldronhq.com (“Website”), through our Services (defined below), and through our customer loyalty program application at www.app.cauldronhq.com or accessed through links or user interfaces provided by Merchants (defined below) on their websites (the “Application”), as well as in email, text, and other communications between you and us.
This Privacy Policy describes the information that we collect (directly or indirectly), why we collect it, what we do with the information we collect, and how you can manage your Personal Information (defined below).
Please read this Privacy Policy carefully. If you do not agree with our policies and practices, we may not be able to provide our Services to you.
By using our Website and Services, you expressly give your consent for the collection and use of your Personal Information (defined below) in compliance with this Privacy Policy.
By using the Application, you expressly agree to let Cauldron share your de-identified individual information with third parties outside of Cauldron. That is, you agree that we may share your information below:
Your age and birthday,
Your Shopping information, and
How you interact with the Cauldron Application.
We will de-identify your Individual Information, which means that we strip the data of information that could directly identify you (for example, your name, email address and physical address) and connect the Individual Information you provide by using a random code instead of your name.
Any Individual Information you allow us to share will be associated with that code, not with your name. “Individual Information” means the data are related to a single person and not aggregated or combined with data from other End Users.
Index
DEFINITIONS
HOW WE COLLECT PERSONAL INFORMATION
WHAT THIS NOTICE DOES NOT COVER
TYPES OF PERSONAL INFORMATION WE COLLECT
INFORMATION WE COLLECT THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES
COOKIES NOTICE
HOW WE PROCESS, SHARE AND DISCLOSE PERSONAL INFORMATION
PROCESSING PERSONAL INFORMATION OUTSIDE THE U.S.
PAYMENT INFORMATION
CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
ACCESSING AND CORRECTING YOUR INFORMATION
YOUR STATE PRIVACY RIGHTS
RETAINING YOUR PERSONAL INFORMATION
DATA SECURITY FOR PERSONAL INFORMATION
PERSONAL INFORMATION OF CHILDREN UPDATES TO THIS PRIVACY POLICY
CONTACT US
DEFINITIONS
“Consumer” means any individual who visits or transacts business with the Application and a Merchant Store.
“Merchant” means the commercial enterprise who purchases Cauldron’s tools to establish and operate a customer loyalty program through the Application.
“Merchant Store” means the Merchant's commercial Website or online presence hosted by Shopify Inc., including their online store and point of sale, which may include more than one Merchant Store.
“Personal Information” means information or data that directly or indirectly identifies, describes, relates to, or is reasonably capable of being associated with, or can reasonably link, to a particular individual, consumer or household.
“Service(s)” means:
Cauldron’s provision of online tools to establish a customer loyalty program and related Services to Merchants who purchase such tools and Services;
The information and loyalty programs provided through Websites and the Application owned and controlled by us and any related mobile apps; and
Our marketing and business development activities, including any social media properties we create, and emails that we send (“Marketing Activities”).
“you” or “your” means a visitor to our Website, an employee or contractor of one of our actual or prospective Merchants, Merchants’ customers, and any other individual whose Personal Information Cauldron collects, uses, shares or otherwise processes as more fully set forth in this Privacy Policy.
HOW WE COLLECT PERSONAL INFORMATION
We may collect your Personal Information through different means, described below:
Visitors to our Websites. When you access our Website at https://www.cauldronhq.com through automated data tracking technology.
Consumers. When you download, register with, or use our Application; when you decide to interact with us, either by providing us your information through the registration page, login page or demo page on the Website; by email; regular mail; or telephone; or when you authorize third parties to provide us Personal Information.
Customers of Our Merchants. We may obtain your Personal Information from Merchants or Shopify Inc. when we provide Services to Merchants. We process this Personal Information on our Merchants’ or Shopify’s behalf and recommend you review your Merchant’s privacy policy and contact them with any complaints, questions or requests.
Merchants. Most information we collect about Merchants is business information, not Personal Information. We use any Personal Information collected to support and better understand our Merchants and provide and improve our Services.
Employees / Contractors / Applicants. If you apply for a job with Cauldron, we use your Personal Information to consider hiring you. If we hire you, we will use your Personal Information in connection with your employment. A separate privacy notice may apply to employees.
WHAT THIS NOTICE DOES NOT COVER
Merchant Data. We may obtain Personal Information relating to (a) the business contacts of our Merchant customers, including name, company address, telephone number, email address, job title; and (b) the Merchant’s data about its own customers including Personal Information (“Merchant Data”). Please direct any complaints, questions or requests related to your Personal Information directly to those Merchants. In the event you are not satisfied with how they respond, you may contact us directly. But we cannot guarantee we will be able to address your issue unless some Personal Information included in this category may overlap with other categories of Personal Information that we collect directly from Consumers.
Third-Party Websites. This Privacy Policy does not apply to any third-party sites that may link to or be accessible from the Websites or the Application.
Non-Personal Information; Anonymized Information. In some situations, we may rely on exemptions or other permitted conduct under applicable laws, including collecting, using, disclosing or storing Personal Information. Information about your business is not typically Personal Information. Anonymized information is also not considered Personal Information for the purposes of this notice. We may anonymize any Personal Information in our custody, in which case it will cease to be Personal Information.
TYPES OF PERSONAL INFORMATION WE COLLECT
We collect information which may be considered Personal Information when maintained in an identifiable format. The applicable Personal Information is also summarized in Annex 1 below. Below are some examples of the Personal Information we may collect through our Services, Website or the Application:
Identifiers of Visitors to the Website. If you are a visitor to our Website we may collect (a) certain electronic information as described in the section titled, “Cookies Notice,” below; and (b) if we provide and if you request a demo, we may collect your name, email address, and company name. When a visitor participates in interactive features on the Website, if any, the user may provide information to us, including without limitation through submission of “contact us” forms, customer support tickets or other forms.
Identifiers of Consumers who Use our Application. If you are a Consumer using our Application, we may collect your real name; alias; city, state and country or location; unique personal identifier, online identifier, Internet Protocol address, email address, account name, birthday, age range, loyalty benefits from shopping, shopping inferences, and other similar identifiers. Merchant Data that we obtain from Merchants may contain additional information including shipping and billing addresses.
Commercial information of Consumers. We collect from our Customers information such as goods and Services purchased and loyalty benefits obtained, or other purchasing or consuming histories or tendencies.
Internet or other similar network activity. We collect information about an individual’s interaction with our Website and the Application.
Geolocation data. We do not use geolocation data. But we may receive information about an individual’s approximate physical location, such as city, state, and country, when they provide such information to us or as determined based on the individual’s IP address. Also, Merchant Data that we obtain from Merchants may contain additional information including shipping and billing addresses.
Communications. When you communicate with us (via email, phone, through the Services or Website, or otherwise), we may maintain a record of your communication.
Business contact information. We may collect or receive contact information about personnel of actual and prospective customers, vendors, contractors, business partners and other similar third parties, which may include full name, email address, phone number, company, job title, and other similar identifying information.
Payment information. We do not collect any payment information of Consumers.
Actual and prospective employees of Cauldron. When an individual applies for employment with Cauldron, or becomes an employee of Cauldron, we collect information relating to that individual’s contact details, suitability for employment, background, employment history, salary and payment details, and other similar information.
Information collected from third parties or public sources. We may receive information from third-party sources, such as business partners, marketing service providers, third-party data aggregators, or publicly available sources, in order to make our own information more accurate and useful. Such information may include an individual’s full name, email address, phone number, company, job title and other contact information.
We may link together different types of information or link information to Personal Information. If linked information directly or indirectly identifies an individual person, we treat the linked information as Personal Information. Where we need to collect Personal Information by law, or under the terms of the contract between us and you do not provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with Services or the Application). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case.
INFORMATION WE COLLECT THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES
Automated technical usage data. When a user accesses the Services or the Website, we automatically generate and retain records of how the user interacts with the Services and Website. Our vendor, Google Analytics, collects information which may include your IP address, device identifiers, device information (such as operating system type or browser type), cookies, referring and exit pages and URLs, interaction information (such as clickstream data), domain names, pages viewed, crash data, and other similar technical data, which they provide to Cauldron in anonymized form. We may use technologies such as cookies and/or scripts to collect this information. Please see the “Cookies Notice” section below for further information.
Location information. We do not use geolocation data. But we may receive information about an individual’s approximate physical location, such as city, state, and country, when they provide such information to us or as determined based on the individual’s IP address.
Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Cauldron, for example, to count users who have visited those pages and for other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).
COOKIES NOTICE
We use cookies and related technologies (“Cookies”) to provide our Services and Application, gather information when visitors navigate through the Website to enhance and personalize the experience, to understand usage patterns, and to improve the Services, and the Website.
Cookies are small text files containing a unique string of characters that are stored in your web browser’s memory when you visit a Website. When you return to a Website that has placed a cookie in your browser, the cookie allows a Website provider to recognize that you have visited the site before.
Cookies on our Website fall into the following categories:
Necessary Cookies. These cookies are necessary to provide you with the Services and the Website to use some of their features, such as access to secure areas. Because these cookies are strictly necessary to deliver the Services, you cannot refuse them without impacting how the Services and the Website function. These cookies do not collect identifying information about you, and they do not monitor or remember any of your internet browsing on Website other than the Website.
Functional Cookies. These cookies allow us to provide you with a better experience when you use the Services and the Website through customized settings. These cookies do not collect identifying information about you, and they do not monitor or remember any of your interaction with the Website or Application.
Targeting Cookies. These record your visit to our Sites, the pages you have visited and the links you have followed to recognize you as a previous visitor and to track your activity on the Sites and other Sites you visit. These Cookies qualify as persistent cookies, because they remain on your device for us to use during a next visit to our Sites. You can delete these cookies via your browser settings. See CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION below for further details on how you can control third-party targeting cookies.
Google Analytics. Our Website and Application may use Google Analytics. Google Analytics uses cookies to help us to analyze how users use the Website. It counts the number of visitors and tells us things about their behavior in the aggregate. Google Analytics does not associate your IP address with any other data held by Google. you may see how Google uses data when you use our Website and Application at https://policies.google.com/technologies/partner-Website.
HOW WE PROCESS, SHARE AND DISCLOSE PERSONAL INFORMATION
Much of the Personal Information we process is necessary to provide our Services and meet our contractual obligations. In this Privacy Policy, to “process” Personal Information means to perform any operation on Personal Information, whether or not by automated means, such as collection, recording, organizing, storing, adapting, use, disclosure, combining, erasing or destroying. In most other situations, we rely on our legitimate interest (which, in some countries, would be “implied consent” or a legal exception to the consent requirement, such as where the processing is to prevent fraud). The specific purposes for which we process Personal Information include:
To communicate with you;
to provide our Services and Application to you;
to administer, manage, test and improve our Services;
to better understand the Services, such as through reporting and analytics;
to deliver information to third parties including other Merchants and their customers;
to market and advertise our Services;
to fulfill any other purpose that would be reasonably apparent to the average person at the time of collection; and
For any other purpose with your consent.
While not stated as a purpose below, we may also use any Personal Information:
For security purposes, including to detect, prevent and investigate potential fraud; and
Where required or permitted by law.
We may also request express consent to process your Personal Information in some circumstances, such as when you sign up as a Consumer to use our Application, or when you visit our Website, and we use cookies. We may also de-personalize information, such as through anonymization or aggregation. We may use and disclose such information for any purpose, as it will no longer identify you or any other person.
We do not sell your Personal Information to third parties (as "sell" is defined in California law). A "sale" would not include a situation where someone is buying all or part of our business (as is explained further below).
We share your Personal Information with our employees, contractors, consultants and other parties such as affiliates and third-party companies that assist us in providing our Services, including marketers, customer support and hosting services. Below is a non-exhaustive list of the third parties that may have access to Personal Information under our control.
The following table outlines recipients to whom we may disclose your Personal Information, as well as the purpose of such disclosure. When we disclose your Personal Information, we cease to control it, and the recipient’s policies and procedures will apply. Where required by law, we will obtain your consent before disclosure.
The following table outlines recipients to whom we may disclose your Personal Information, as well as the purpose of such disclosure. When we disclose your Personal Information, we cease to control it, and the recipient’s policies and procedures will apply. Where required by law, we will obtain your consent before disclosure.
PROCESSING PERSONAL INFORMATION OUTSIDE THE U.S.
We may disclose Personal Information to third parties both in and outside of your country, and as result, your Personal Information may be collected, used, disclosed or stored in another country, including Canada and in the United States of America. Laws relating to privacy vary between countries, and your Personal Information may be processed in a country with less stringent laws than the laws in your country. Personal information may be accessible to governments, courts, or law enforcement, national security authorities or and regulatory agencies of these countries in accordance with applicable laws.
PAYMENT INFORMATION
We use a third-party payment provider to process payments from Merchants. We do not collect Personal Information related to credit cards or other payment information. The payment provider will collect, use and disclose that information in accordance with its own privacy policy.
CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:
How to Control Cookies. You can review Your Internet browser settings, typically under the sections “Preferences,” “Help” or “Internet Options,” to exercise choices You have for certain Cookies. If You choose to block all cookies, You may not have access to our Website, our Services will not function as intended, and You will not be able to log in. If You have blocked all cookies and wish to make full use of the features and Services we offer, we recommend enabling at least first-party cookies. Rather than blocking all cookies, You can choose to block only third-party cookies. This will allow the Services to function as intended.
To learn more about the use of Cookies by Google for analytics, please see https://policies.google.com/technologies/cookies. To exercise choice regarding those Cookies, please see the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout. The opt-outs described above are device- and browser-specific and may not work on all devices.
Promotional Offers from Cauldron. If you do not wish to have your email address used by Cauldron to promote our own products or services, you can opt-out by sending us an email stating your request to privacy@cauldronhq.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.
ACCESSING AND CORRECTING YOUR INFORMATION
You can review and change your Personal Information by logging into the Application and visiting your account profile page. You may also send us an email at privacy@cauldronhq.com to request access to, correct, or delete any Personal Information that you have provided to us. We cannot delete your Personal Information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
YOUR STATE PRIVACY RIGHTS
You may have additional rights under state consumer privacy laws of your state of residence regarding our use of your Personal Information.
California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:
Confirm whether we process their Personal Information,
Access and delete certain Personal Information,
Correct inaccuracies in Personal Information, taking into account the processing purpose (excluding Iowa and Utah),
Data portability, and
Opt-out of personal data processing for targeted advertising (excluding Iowa).
We will not discriminate against you for exercising any of your rights as described above.
Keep in mind that Merchants control much of the Personal Information processed by Cauldron, so you may need to direct your request to the Merchant with whom you have a relationship.
As a security measure, our Privacy Officer may request specific information from you in order to verify your identity prior to granting any requests. If we cannot respond to your request promptly or have to refuse the request, we will advise you of the reasons, subject to any legal restrictions. If you disagree with our determination, you may complain to us, and we will reconsider. If you are not satisfied with our ultimate determination, you may contact your local data protection authority or privacy commissioner. In addition, the Personal Information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.
Where permitted by law, we may refuse or charge a fee for repeat, abusive or inappropriate requests.
RETAINING YOUR PERSONAL INFORMATION
We only store Personal Information as long as necessary to fulfill the purposes for which the Personal Information was collected, to conduct our business operations and maintain an appropriate historical record of our relationship with you, or in order to comply with applicable laws, whichever is longer, after which time the Personal Information is destroyed or erased. We may, instead of destroying or erasing your Personal Information, make it anonymous such that it cannot be associated with, or tracked back to, you.
DATA SECURITY FOR PERSONAL INFORMATION
We take steps to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of your Personal Information. These safeguards are intended to prevent your Personal Information from loss and unauthorized access, copying, use, modification or disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to our Services or Application, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Also, the Internet is not a secure environment, and no computer system is perfectly secure. As such, we cannot guarantee the security of Personal Information provided to us through electronic means; there is always a risk that your Personal Information may be accessed or used without authorization.
PERSONAL INFORMATION OF CHILDREN
We will not collect, use, disclose and store Personal Information of children under the age of 13 without the consent of a parent or guardian. If you believe that a child under 13 may have provided us with Personal Information without the consent of a parent or guardian, we request that you contact us at privacy@cauldronhq.com immediately.
California Minors: If you are a California resident who is under the age of 18 and you are unable to remove publicly available content that you have submitted to us, you may request removal by contacting us at the Contact Us information below. When requesting removal, you must be specific about the information you want removed and provide us with specific information, such as the URL for each page where the information was entered, so that we can find it. We are not required to remove any content or information that: (1) federal or state law requires us or a third party to maintain; (2) was not posted by you; (3) is anonymized so that you cannot be identified; (4) you don’t follow our instructions for removing or requesting removal; or (5) you received compensation or other consideration for providing the content or information. Removal of your content or information from the Service does not ensure complete or comprehensive removal of that content or information from our systems or the systems of our service providers. We are not required to delete the content or information posted by you; our obligations under California law are satisfied so long as we anonymize the content or information or render it invisible to other users and the public.
UPDATES TO THIS PRIVACY POLICY
This Policy may change from time to time. Your continued use of this Website or our Services after we make changes to this Privacy Policy is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.
CONTACT US
To ask questions or comment about this privacy policy and our privacy practices, contact us at privacy@cauldronhq.com.
If you have a question, comment or complaint about a Merchant, please contact the Merchant directly. If the Merchant is not responsive, you may direct your question, comment or complaint to us, but we cannot guarantee we will be able to address it.