HelloWorld, Inc. Privacy Policy

Last Revised: June 18, 2018

HelloWorld, Inc. is a company that helps other businesses operate sweepstakes, contests, promotions, loyalty, and other promotional marketing programs ("Promotions"). In addition, HelloWorld occasionally runs its own Promotions. Such Promotions gather personal data from individuals who choose to enter a particular Promotion and data regarding the Promotion itself. HelloWorld takes its privacy obligations seriously, both to its clients and to people who enter its Promotions. This policy outlines our treatment of personal data we collect on behalf of our clients and for our own use.

Client Promotions

As a full service promotions, loyalty, and sweepstakes agency, HelloWorld operates Promotions on behalf of its clients. HelloWorld acts as a data processor on behalf of such clients. Each of our clients is the data controller for the data they collect within the applicable Promotion and is the sole owner of that data. Our client for a Promotion is often referred to as the promotion sponsor. As part of our services, HelloWorld collects personal data for clients by use of HelloWorld's proprietary online technology, HelloWorld mailboxes, and points of entry offline. HelloWorld collects such personal data solely for the use of the applicable client and the operation of the Promotions. Uses within a Promotion may include notification of potential winners, fulfillment of prizes, and marketing analysis. HelloWorld strictly limits access to personal data within its organization. Data is not shared outside of the company except that HelloWorld provides data to our clients, to third parties if directed by our clients, and in response to appropriate governmental or legal requests. Personal data collected from a client Promotion is never shared with any client other than the client on whose behalf the information was collected. Personal data collected by HelloWorld on behalf of a client belongs solely to the client and will be used solely in accordance with that client's privacy policy. You have the right to access your personal data in our Promotions by contacting the client of ours that collected your data. That client can inform you of how they use, disclose, and limit your personal data, as well as your choice to opt out of its collection, amend it for accuracy, or have it deleted. HelloWorld is not responsible for data collected on behalf of clients when it is in a client's possession.

HelloWorld Promotions

HelloWorld may run Promotions on its own behalf. Such Promotions are to generate interest from other businesses in HelloWorld's products and services. HelloWorld uses personal data collected in such Promotions as sales leads and may contact the individual registrants by email, mail or phone. HelloWorld will never sell such information or share it with another business. When individuals opt in to receive information from HelloWorld, they agree to receive email and other notices from HelloWorld, including marketing messages, surveys, special offers and notices about other Promotions. Such notices may come from HelloWorld itself or from HelloWorld on behalf of companies with whom HelloWorld has a business relationship. If you want to opt out of being contacted by HelloWorld after you have participated in a Promotion operated by us directly, or you wish to correct the information you have provided to HelloWorld, you may do so in one of two ways: (1) mail the details of your request to: Privacy Policy c/o HelloWorld, Inc., 3000 Town Center, Suite 2100, Southfield, MI 48075; (2) email to privacy@helloworld.com. Please make sure to include the name of the Promotion (if one exists) in the subject line and in the body of the email from which you wish to opt-out. Failure to provide this information may delay the processing of your request.

HelloWorld's Online Promotion Technology

HelloWorld's proprietary Promotion technology has the ability to collect data other than personal data for any of the Promotions it operates. HelloWorld may collect information about your computer or device configuration such as your browser type, site visit information, or the operating system. HelloWorld may collect information about the site you last visited prior to the Promotion or about your activity during your visit to the Promotion site. HelloWorld may also offer social sign-on services that allow you to register for a promotion using a third-party social networking site such as Facebook, Google, or Twitter. By using these services, you allow HelloWorld to access the available information from your third-party social network profile such as your name, age, gender, location, email address, and list of friends. This information may be used by HelloWorld to administer the technical and operational aspects of the site. Your IP address may also be used to gather broad demographic information for aggregate use.

Mobile Messaging

As a full service promotions and sweepstakes agency, HelloWorld also operates mobile programs on behalf of its clients and itself. As part of those mobile services, HelloWorld collects personal data by use of HelloWorld's mobile technology. HelloWorld will not collect personal data from you without your consent. We will use reasonable efforts to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data under our control, including physical, electronic and procedural safeguards. However, due to the nature of mobile communications, we cannot guarantee the security of any data transmitted through mobile messaging. HelloWorld will only use the information you provide, including your mobile number, to send you content pursuant to the Promotion in which you have requested to participate; though we will share the information we collected from you with the client on whose behalf we collected it. We will not use your information for any other purpose. HelloWorld is not responsible for information collected on behalf of its clients when such information is in its client's possession. However, we reserve the right at all times to disclose any information as necessary to satisfy any law, regulation, or governmental request; to avoid liability; or to protect our rights or property. When you provide us information in connection with a mobile program, you agree to provide accurate, complete and true information. You agree not to use a false or misleading name or a name that you are not authorized to use. If we, in our sole discretion, believe that any such information is untrue, inaccurate or incomplete, we may prohibit you from further participation in the applicable program and pursue any appropriate legal remedies.

Information You Share With Us

We collect information you provide when you input it into a Promotion site or otherwise provide it to HelloWorld for a Promotion.

  • Content you provide through our websites: The Promotion-related services include the websites and other media operated by us on behalf of clients. See the description under the Types of Promotions section regarding the personal data we collect. We collect content that you submit to these websites, which may also include social media or social networking websites operated by us. For example, you provide content to us when you provide feedback or when you participate in any interactive features, surveys, contests, promotions, sweepstakes, activities or events.

  • Information You Provide Through Our Support Channels: Our services also include customer support, where you may choose to submit information regarding a problem you are experiencing with a Promotion. You may be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue.

Additional Information We Receive About You When You Enter a Promotion

We collect information about you when you participate in a Promotion, including browsing our websites and taking certain actions within the Promotion, such as registration.

  • Your Participation in a Promotion: We collect certain information about your site visit and interaction with a Promotion. This information includes the personal data you provide upon registration; the links you click on; the type, size and filenames of attachments you upload in connection with a Promotion; and how you interact with a Promotion

  • Device and Connection Information: We collect information about your computer, phone, tablet, or other devices you use to access a Promotion. This device information includes your connection type and settings when you access a Promotion site. We also collect information through your device about your operating system, browser type, IP address, URLs of referring and exit pages, device identifiers, and crash data. We use your IP address and to approximate your location to provide you with a better Promotion experience. How much device information we collect depends on the type and settings of the device you use to participate in a Promotion.

  • Location Information: We may receive information about your location. For example, you may enter address information upon registration into a Promotion. We may also determine location by using other data from your device, such as information about wireless networks or cell towers near your mobile device, or your IP address. We may use and store information about your location to provide features of our Promotion and to improve and customize our services.

  • Links: We may keep track of how you interact with links across a Promotion, including email notifications, third-party services, and client applications, by redirecting clicks or through other means. We do this to improve our Promotion services, to provide more relevant experiences, and to be able to share aggregate statistics and analytics to our clients, such as how many times a particular link was clicked on.

  • Cookies and Other Tracking Technologies: HelloWorld uses browser cookies in order to improve the user experience by enabling our Promotions to “remember” you or your preferences, either for the duration of your single visit to a website (using "session cookies") or during additional visits ("persistent cookies"). A cookie is a small text file that is stored on your computer or device by a website. Only the visited website will be able to read the contents of a particular cookie. Every cookie is unique to your web browser and contains anonymous information such as a unique identifier, the site name, and some digits and numbers. Cookies serve different purposes, such as letting the user navigate between pages efficiently, storing user preferences or settings, and overall improving an experience with our Promotions and sites. Cookies make the interaction with a Promotion easier. Some of our sites will also use cookies or web analytic tracking methods to enable targeted advertising or marketing messages based, for example, on your location and/or browsing habits. Cookies may be set by the website domain you are visiting ("first party cookies") or they may be set by other website domains that run content on the page you are viewing ("third party cookies"). The content of third party cookies can sometimes include Facebook "like" buttons or Twitter "tweet" buttons. Although most web browsers automatically accept cookies, some browsers’ settings can be modified to decline cookies or alert you when a website is attempting to place a cookie on your computer. However, some Promotions may not function properly if you disable cookies. If you do not want to see advertising that has been targeted to your interests or activities, it is possible to block some or all cookies, or even to delete cookies that have already been set, but you might lose some or all of that website's functionality.

    To manage cookies on your browser please see the articles below:

    Internet Explorer: http://support.microsoft.com/kb/278835 

    Mozilla Firefox: http://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer

    Google Chrome: http://support.google.com/chrome/bin/answer.py?hl=en&answer=95647

    Opera: http://www.opera.com/browser/tutorials/security/privacy/

    Safari: http://support.apple.com/kb/PH5042

    HelloWorld does not support Do Not Track browser settings and does not currently participate in any Do Not Track frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your personal information.

  • Log Data: We receive information when you view content on or otherwise interact with our Promotions, which we refer to as “Log Data,” even if you have not registered. For example, when you visit our websites, interact with our email notifications, or visit a third-party site from a Promotion site, we may receive information about your visit. This Log Data includes information such as your IP address, browser type, operating system, the referring web page, pages visited, location, your mobile carrier, device information (including device and application IDs), search terms, and cookie information. We use Log Data to operate our services and ensure their secure, reliable, and robust performance. For example, we use Log Data to protect the security of accounts and to determine what content is popular on our Promotion sites. We also use this data to improve the content we show you, including ads.

Information We Share and Disclose

  • Service Providers: HelloWorld works with third-party service providers to provide website and application development, maintenance, backup, storage, virtual infrastructure, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so based on  instructions from us, including compliance with requirements and procedures designed to protect your information.

  • Law, Harm, and the Public Interest: Notwithstanding anything to the contrary in this Privacy Policy, we may preserve or disclose your information if we believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request; to protect the safety of any person; to address fraud, security or technical issues; or to protect our or our client’s rights or property.

  • Affiliates and Change of Ownership: In the event that we are involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be sold or transferred as part of that transaction. This Privacy Policy will apply to your information as transferred to the new entity. We may also disclose information about you to our corporate affiliates in order to help provide, understand, and improve Promotions, our other services, and our affiliates’ services, including the delivery of ads.

  • Non-Personal Information: We may share or disclose non-personal, aggregated, or device-level information such as the total number of times people engaged with a Promotion, the number of users who clicked on a particular link, the number or types of entries in a contest, the characteristics of a device or its user, or aggregated or device-level reports to our clients about Promotions. This information does not include your name, email address, phone number, or other personal data.

Information We Receive from Other Sources

  • HelloWorld Clients: We may receive information about you from clients of HelloWorld related to a program or Promotion with that client, in accordance with their terms and policies.

  • HelloWorld-Affiliated Companies: We may receive information about you from companies that are affiliated with HelloWorld, in accordance with their terms and policies.

How We Use Information We Collect

  • To Operate Promotions and Personalize Your Experience: We use information about you to operate the Promotions, including to process transactions with you, authenticate you when you log in, provide customer support, and operate and maintain the Promotions. Our Promotions may also include features that personalize your experience. We may use your email domain to ensure your eligibility or your affiliation with a particular organization or industry to personalize the content and experience you receive. Where you use multiple Promotion platforms (website, mobile website, mobile app), we combine information about you and your activities to provide an integrated experience, such as to allow you to engage from the various platforms we make available.

  • For Development and Improvement of our Promotions and Services: We continually to make our Promotions more engaging, secure, rewarding, and useful to you and our clients. We use collective learnings about how users engage with our Promotions and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns and areas for improvement.

  • To Communicate With You About The Services: We use your contact information to send transactional communications to you by email, text message, mobile app messaging, and other means to access a Promotion. We remind you of Promotion deadlines, respond to your comments, questions and requests, provide customer support, and may send you notices, updates, and administrative messages. We also provide personalized communications based on your activity and interactions with a Promotion. For example, certain actions you take in a Promotion may automatically trigger communications related to the Promotion engagement, such as loyalty points in your account. Transactional communications are part of the Promotion and in most cases, you cannot opt out of them and continue to participate. If an opt out is available, you will find that option within the communication itself. Importantly, if you do enter into a Promotion and opt out of transactional communications, we will have no way to reach you if you are a potential winner or otherwise eligible for something of value. If you opt out of such communications, you will no longer be eligible as an entrant.

  • To Market, Promote, and Drive Engagement With The Services: If you opted in to receive such communications from HelloWorld, we will use your contact information and information about how you engage with Promotions to send communications that may be of specific interest to you, including by email and by displaying HelloWorld ads on other companies' websites and applications, as well as on platforms like Facebook and Google. These communications are aimed at driving engagement with our Promotions, and may include information about new programs and sites we think may be of interest to you. We may also communicate with you about new product and service offers, promotions and contests. You can control whether you receive these communications as described below under "Opt-out of communications."

  • Customer Support: We use your information to resolve technical issues you encounter, to respond to your requests for assistance, to analyze crash information, and to repair and improve the Promotions.

  • For Safety and Security: We use information about you and your Promotion participation to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of the Promotion rules or the policies of HelloWorld or our clients.

  • To Protect our Legitimate Business Interests and Legal Rights: Where required by law or where we believe it is necessary to protect the legal rights and interests of HelloWorld, our clients, or others, we may use information about you in connection with legal claims, compliance, regulatory, and audit matters.

  • With Your Consent: We use information about you where you have provided consent for HelloWorld and our client to do so for a specific purpose not listed above. For example, with your consent and on behalf of our clients, we may post contest entries or other user generated content to social media platforms

  • Legal Bases for Processing (for EEA Users): If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the Promotions you enter, how they operate, and how you use them. This means we collect and use your information only where:

    • We need it to operate the Promotion, provide customer support and personalized features, and to protect the safety and security of our platforms and Promotion services;

    • It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for our internal development of improved services, to market and promote the Promotions, and to protect our legal rights and interests;

    • You give us consent to do so for a specific purpose; or

    • We need to process your data to comply with a legal obligation or where the processing is necessary to the establishment, exercise or defense of legal claims.

If you consented to use of information about you for a specific purpose, you have the right to change your mind at any time but this will not affect processing that has already taken place. Where HelloWorld is using your information because our client or HelloWorld have a legitimate interest to do so, you have the right to object to that use although this may mean no longer participating in a Promotion. If we are unable to manage your participation in a Promotion without the personal data provided (such as registration information), you will no longer be able to participate in the applicable Promotion.

How We Store and Secure Information We Collect

  • Information Storage and Security: We use data hosting equipment and service providers in the United States to host the information we collect, and we use technical measures to secure your data.

  • How Long We Keep Information: How long we keep personal data and other information we collect about Promotion participants depends on the type of information, as described below. After such time, we will either delete or anonymize the information or, if this is not possible, we will securely store your information and isolate it from further use until deletion is possible.

    • Promotion information: We retain the information your provide to participate in a Promotion for a reasonable period after the Promotion and all related services and requirements are completed. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our terms and rules, to support business operations and to continue to develop and improve our Promotions and services. Where we retain information for service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to develop general insights about use of our Promotions, not to analyze personal characteristics about any individual.

    • Marketing information: If you elect to receive marketing emails from HelloWorld, we retain information about your marketing preferences unless you specifically ask us to delete such information. We retain information derived from cookies and other tracking technologies for a reasonable period from the date such information was created.

Managing Your Personal Information with HelloWorld

HelloWorld acts as a data processor on behalf of its clients. Each of our clients is the data controller for the data they collect in the applicable Promotion and is the sole owner of that data. Individuals have the right to access the personal data processed about them, subject to applicable law. Individuals may request to access their personal data processed by us by emailing us at privacy@helloworld.com. However, if HelloWorld collects your personal data on behalf of a client in connection with that client’s Promotion, your request should be directed to the client data controller. In most cases, we will in the first instance direct your request to our client, the data controller. You have certain choices available to you when it comes to your information. Subject to applicable law, you may have some or all of the following rights available to you in respect of your personal data:

  • to obtain a copy of your personal data together with information about how and on what basis that personal data is processed;

  • to rectify inaccurate personal data (including the right to have incomplete personal data completed);

  • to erase your personal data (in limited circumstances, such as where it is no longer necessary in relation to the purposes for which it was collected or processed);

  • to restrict processing of your personal data under certain circumstances

  • to port your data in machine-readable format to a third party (or to you) when we justify our processing on the basis of your consent or the performance of a contract with you;

  • to withdraw your consent to our processing of your personal data (where that processing is based on your consent); and

  • to obtain, or see a copy of the appropriate safeguards under which your personal data is transferred to a third country or international organization.

In relation to these rights, you may contact us at privacy@helloworld.com.

Notice: If you contact us regarding personal data collected in connection with a client Promotion for which we are a data processor, we will attempt to refer your request to the relevant client, which is the sponsor of the Promotion and the data controller. We are not responsible for responding to your request on behalf of the data controller and your request will be directed to the client only. We will process such requests only upon instructions from the data controller that is sponsoring the Promotion.

If HelloWorld is required to respond directly to your request, we may require proof of identity. We also reserve the right to charge a fee where permitted by law, especially if your request appears unfounded, excessive, or abusive. We will use reasonable efforts to respond to your request within all applicable timeframes.

Your California Privacy Rights (As provided by California Civil Code Section 1798.83)

A California resident who has provided personal information to a business with whom they have established a business relationship for personal, family, or household purposes ("California customer") is entitled to request information about whether the business has disclosed personal information to any third parties for the third parties' direct marketing purposes. In general, if the business has made such a disclosure of personal information, upon receipt of a request by a California customer, the business is required to provide a list of all third parties to whom personal information was disclosed in the preceding calendar year, as well as a list of the categories of personal information that were disclosed. However, under the law, a business is not required to provide the above-described lists if the business adopts and discloses to the public (in its privacy policy) a policy of not disclosing customer's personal information to third parties for their direct marketing purposes unless the customer first affirmatively agrees to the disclosure. The business may comply with the law by notifying the customer of their right to prevent disclosure of personal information and providing a cost free means to exercise that right.

Privacy Shield

HelloWorld complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. HelloWorld has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, visit https://www.privacyshield.gov/. In compliance with the Privacy Shield Principles, HelloWorld commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact HelloWorld’s data security team at privacy@helloworld.com. In any matters relating to the EU-U.S. Privacy Shield Framework, HelloWorld is subject to the investigatory and enforcement powers of the Federal Trade Commission. Under certain conditions, more fully described on the Privacy Shield website at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted. If we fail to address your data privacy concerns via the contact information above, we have contracted JAMS (https://www.jamsadr.com/eu-us-privacy-shield), a dispute resolution provider based in the US, as our independent dispute recourse provider. This recourse provider is available to address privacy complaints and provide appropriate recourse free of charge to the individual filing a privacy related complaint against HelloWorld. HelloWorld will comply with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

Special Note about Children

Unless otherwise specifically indicated, HelloWorld Promotions are generally not available to persons under the age of 13. HelloWorld does, however, on occasion operate Promotions on behalf of clients that will collect personal data from children under the age of 13. In each such instance, HelloWorld and its clients will fully comply with all aspects of the Children's Online Privacy Protection Act ("COPPA") or other applicable law in the operation of the Promotion, in the collection of the data, and in the subsequent use and deletion of the data collected. In the EU, Promotions will generally not be available to children under the age of 16 unless permitted by applicable law and upon written instructions by a client.

Additional Information or Assistance

If you wish to contact HelloWorld to correct, amend, or delete information (if HelloWorld is holding on to your information as explained above), to communicate about privacy related issues, or for any reason at all, you may do so in one of two ways: (1) mail to: Privacy Policy c/o HelloWorld, Inc., 3000 Town Center, Suite 2100, Southfield, MI 48075; (2) email to: privacy@helloworld.com

Privacy Policy Changes

HelloWorld may make material changes to this privacy policy from time to time. Therefore, you should periodically visit this page to view the current privacy policy. In the event of a material change to this privacy policy, HelloWorld will send an email advising of the change to all persons whose email addresses we have collected and retained pursuant to the terms set forth above, or by posting notice of the changes on this site.