blackhawknetwork.com Open in urlscan Pro
2a04:4e42:200::645  Public Scan

Submitted URL: https://email.mg.workplaceextras.com/c/eJxMUstu2zAQ_Br5UkBYvsWDD7ZcFU5sIG2cpOjF4GMdKaYe0COu-_UF5QTtZZY73BmCg_VLL506kQUuicwIaApaL8qlzD...
Effective URL: https://blackhawknetwork.com/uk-en/privacy-policy
Submission: On April 11 via api from IE — Scanned from DE

Form analysis 6 forms found in the DOM

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          <option value="Incentives - Transactional">Buying bulk giftcards or ecodes</option>
          <option value="Arena">Reward or incentive Solutions</option>
          <option value="Incentive Resellers">Reselling giftcards or ecodes</option>
          <option value="Benefits">Employee benefits</option>
          <option value="Corporate Payments">Managing corporate payment solutions</option>
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PRIVACY POLICY

 


BLACKHAWK NETWORK PRIVACY NOTICE

Last Updated: June 17, 2021

Previous version is available here. 

 


CONTENTS

Blackhawk Network Privacy Notice

Blackhawk Network Short-Form Privacy Notice (for customers of Financial
Companies)

Third-Party Privacy Notices (from our Banking Partners)

 


BLACKHAWK NETWORK PRIVACY NOTICE

 


INTRODUCTION

This Privacy Notice (commonly referred to as a “Privacy Policy”) explains how
Blackhawk Network Holdings, Inc., and its affiliated companies, process the
Personal Information of website visitors, users of our apps, users of our gift
card and branded payments services. It also addresses the policies that apply to
how we process the Personal Information of the customers of the many hundreds of
brands who use Blackhawk Network platforms to provide services to those
customers.

You should read and understand this Notice because it constitutes the core of
our obligations to you when you use this website, when you provide your Personal
Information to us either directly or through automated processes. For your
convenience we have summarized several of the most important points, which are:

 * We collect and process your personal information in order to provide services
   to you, either as a direct customer of Blackhawk, or as a customer of one of
   the businesses for whom we provide services.
 * We also use your personal information for our own legitimate and lawful
   business interests, including (but not limited to): improving our websites
   and services, communicating information about our services through direct
   advertising (such as email) and indirect advertising (such as ads appearing
   on other websites), conducting fraud detection and prevention activities,
   maintaining records and communicating notices that are required by law.
 * We do not sell your information.
 * We may share your information with the service providers needed to deliver
   our services to you, but those service providers are bound by law and
   contract to only use your information for the purposes we specify.
 * We may receive your information when we function as a service provider for
   other companies; we are bound by law and contract to only use your
   information for the purposes they have specified.
 * This Notice applies to websites and mobile applications operated by
   Blackhawk, and covers your personal information whether provided via those
   channels as well as any information you might provide to us when you call,
   email, or send postal mail to our Customer Service.
 * For websites and apps that we operate on behalf of other companies, those
   companies will provide their own privacy notices. If they provide their own
   privacy notice, that company’s notice will govern how your information is
   processed. Please be sure to review the notice provided on the site you are
   using.
 * Data protection laws in your jurisdiction may provide you with rights to
   access or delete your personal information and this policy provides you with
   instructions on how we do this. For example, if you are a resident of the
   European Union or the State of California in the United States, laws in those
   jurisdictions grant you specific rights that are discussed below in the
   section called “Your Rights.”

You are strongly encouraged to read this Privacy Notice in its entirety, not
just the above highlights, so that you will fully understand Blackhawk’s
commitment to responsible data governance and the protection of your personal
information. Please also note that this Notice may have changed since the last
time you read it, so you should make sure that you have familiarized yourself
with any terms that may have changed since the last time you read it.

 


SCOPE OF PRACTICES

WHO

This Privacy Notice (“Notice”) applies to the activities of Blackhawk Network
Holdings, Inc., and its affiliates (“Blackhawk,” “we,” “us,” or “our”). It
applies to our usage of your personal data, whether you are an individual
consumer (“business to consumer”) or you are interacting with us as part of your
job (“business to business”).

WHAT

This Notice describes how we collect and process your personal information
(which includes “personal data” or “personal information” as defined under
applicable data protection laws) and the rights you have regarding such data.

WHERE

This Notice applies to our collection and processing of personal data about
users of our websites, mobile applications, and the services and features
therein (together the “Sites”), as well as the data we collect during the course
of providing our services (the “Services”). It also applies to those channels
through which individuals communicate with us about our Sites and Services,
whether in person, by telephone, by postal mail, e-mail, or other means.

WHEN

On some Sites (including, but not limited to: gGiftCardStore.co.uk), we function
as a Controller of your data. This means we define the purposes for which your
personal information is processed, and we control the means by which your
information is processed. When we act as a Data Controller, we bear the primary
responsibility to you, the Data Subject, for protecting your information and
honoring your rights.

When we act as a Data Processor on behalf of another Data Controller, we
collect, use, and disclose certain personal information only under the
Controller’s instruction, and our processing of your personal information is
subject to their instructions and privacy policies. For any Site operated by us
on behalf of another company, their privacy notice will appear on the site and
that privacy notice will be the applicable policy.

Some of Blackhawk’s Services are offered through third parties, such as banks or
other financial institutions. In those cases, you will see privacy notices
provided by those companies alongside the Blackhawk Network Privacy Notice. The
Blackhawk Network Privacy Notice will apply to your usage of that Site while the
privacy notice provided by the third party will apply to their use of their
customers’ personal information in the delivery of their financial services.
Please read both notices carefully to understand the differences between the
applicability of one policy versus the other.

Please note: Links to third-party websites are provided solely for your
convenience; when you go to those sites, your experience there is subject to the
privacy notices and terms of use of those third-party sites, not ours, unless
you are explicitly told otherwise.


PERSONAL INFORMATION WE COLLECT

We collect personal information directly from you, through third parties, or
automatically through our Sites and related to our Services, subject to
applicable laws as set out below. Where the personal information we collect is
needed to comply with law, or to enter into or perform an agreement with you, we
will inform you at the time of such data collection. If we cannot collect this
data, we may be unable to register you as a client, to complete certain
transactions, or provide products or services to you.

PERSONAL INFORMATION WE COLLECT DIRECTLY FROM YOU

 * Contact information, such as name, email address, mailing address, fax or
   phone number;
 * Payment and financial information, such as credit or other payment card
   information, bank account, or billing address;
 * Shipping address and related details;
 * Your resume, employment and education history, name and contact details,
   background details, and references when you apply to job postings or contact
   us about employment opportunities;
 * Company and employment information when you contact us on behalf of your
   employer or when your employer uses one of our services;
 * Subject to applicable local law restrictions, national tax ID number (for
   clients and potential clients);
 * Unique identifiers such as username, account number, or password;
 * Preference information such as product wish lists, order history, or
   marketing preferences;
 * Information about your business such as company name, size, or business type;
   and
 * Demographic information, such as when you provide your age, gender, interests
   and ZIP or postal code.

COMMENTS, POSTS, CHATS, AND SUBMISSIONS

When you submit online forms, participate in surveys, contests, promotions, or
sweepstakes, join online chat discussions or post on a blog, request customer
support, or submit testimonials, we collect your personal information, such as
contact information, and other information you choose to share. Some of our
Sites offer publicly accessible blogs. Any information you provide in these
areas may be read, collected, and used by others who access them.

TESTIMONIALS

Some of our Sites make available the ability for you to provide reviews or
testimonials. With your consent, we may use your testimonial and your name,
e.g., to display personal testimonials of satisfied customers on certain Sites
and in print advertisements.

LOCATION

On some Sites we collect geolocation-based information for fraud prevention
purposes. With your consent, we may also collect your precise location-based
information for purposes such as to help you locate a store offering our
products and services in your area. You may withdraw your consent to the
processing of location-based information at any time by changing the settings on
your device. If you do, you might not be able to use certain features,
especially when we use location-based information to prevent fraud.

PERSONAL INFORMATION WE COLLECT FROM THIRD PARTIES

Sometimes, we may collect personal information from third-party sources. For
example, subject to applicable law, we may confirm your address with the postal
service, or we may receive personal information about you from our clients who
use our Services to provide you with incentives. Similarly, if our users choose
to send a gift to a friend through our Sites, we will ask for the friend’s name
and contact details.

Certain websites also may offer a referral service where users may refer other
people they know to our Services, subject to restrictions under applicable local
laws. If you choose to use our referral service to tell your friends about our
Services, we will provide you with a referral code and signup instructions that
you can share with your friends. Where permitted by local law, we conduct such
referrals on an opt-out basis. If personal information about you has been
provided to us and you want us to delete it, you may email us at
ourprivacycommitments@bhnetwork.com.

PERSONAL INFORMATION WE COLLECT AUTOMATICALLY

We and our service providers automatically gather information about your use of
the Sites and Services through cookies, web beacons, java script, log files,
pixels, and other technologies, which include: your domain name, browser type,
browser language preference, device type and operating system, page views and
links you click within the Sites, IP address, device ID or other identifier,
location information, date and time stamp, and time spent using the Services,
referring URL, your activity within the Sites, and device geolocation
information (where permitted by your device settings). We also collect
information from analytic services, including Google Analytics, to compile and
analyze information derived from the use of our Services, such as aggregate
usage patterns, user preferences, peak demand times, preferred content and other
information. See the “Cookies and Online Tracking” section below for details.


USE OF YOUR PERSONAL INFORMATION AND LEGAL BASES

We may use the personal information we collect for the following purposes:

 * Provide Our Services: To provide our Services, operate our Sites, respond to
   your enquiries and fulfill your requests and orders, process your payments,
   for bug and error reporting and resolution, to perform upgrades and
   maintenance;
 * Customer Service and Support: To send you important information, such as
   changes to terms, conditions, and policies and/or other administrative
   information;
 * Personalization: To personalize your experience on a Site or using the
   Services, such as by tailoring the content we send or display to you in order
   to personalize help and instructions, and to otherwise personalize your
   experience using the Services;
 * Alerts and Required Notices: To send you messages that you have requested
   such as service-related alerts and any notices required by contract or
   applicable law;
 * Marketing and Promotions: To send you marketing communications you have
   signed up for;
 * Advertising and Referrals: To assist in advertising the Services on
   third-party websites and to track referrals from partner websites;
 * Analytics and Improvement: To better understand how our users access and use
   the Services, and for other research and analytical purposes, such as to
   evaluate and improve the Services;
 * Verify Identity and Detect Fraud: To verify your identity and/or location in
   order to allow access to your accounts, conduct online transactions, and
   secure your personal information, and for risk control, fraud detection and
   prevention, and compliance with laws and regulations;
 * Protect Our Legal Rights and Prevent Misuse: To protect the Services, prevent
   unauthorized access and other misuse, and where we believe necessary to
   investigate, prevent or take action regarding illegal activities, suspected
   fraud, situations involving potential threats to the safety of any person, or
   violations of our Terms of Use or this Privacy Notice.
 * Comply with Legal Obligations: To comply with the law or legal proceedings
   such as when required to disclose information in response to lawful requests
   by public authorities, including responding to national security or law
   enforcement disclosure requirements; and
 * General Business Operations: Where necessary to the administration of our
   general business, accounting, recordkeeping and legal functions.

 

AGGREGATED AND ANONYMIZED INFORMATION

We may also generate aggregated, pseudonymized, and/or anonymized information
about users for marketing, advertising, research or similar purposes.


PURPOSE OF PROCESSING

In the table below, we explain the purposes for which we use and process your
personal information, as well as the legal bases for such use and processing
(such as those permitted under the European Union’s General Data Protection
Regulation (“GDPR”) and other applicable laws).

 

PURPOSES OF USE/PROCESSING

 

 

LEGAL BASES OF PROCESSING (WHERE APPLICABLE)

 

To Provide Our Services

Customer Service and Support

 * Necessary to enter into or perform a contract with you (upon your request, or
   as necessary to make the Services available)
 * Our legitimate business interests*

Personalization

Marketing and Promotions 

Advertising and Referrals

 * Our legitimate business interests*
 * With your consent

Analytics and Improvement

 * Our legitimate business interests*

Verify Identity and Detect Fraud

Protect Our Legal Rights and Prevent Misuse

Comply with Specific Legal Obligations

 * Compliance with applicable laws and regulations
 * Establish, defend or protect our legal interests
 * Our legitimate business interests*

General Business Operations

 * Our legitimate business interests*
 * Establish, defend or protect our legal interests
 * Compliance with law

 

* For personal information from the EU, the processing is in our legitimate
interests to the extent they are not overridden by your interests and
fundamental rights. Our legitimate interests include our interests in verifying
identify, detecting and preventing fraud, protecting and improving our products
and services, in support of our general business operations, and to comply with
our legal obligations. We only send marketing communications to consumers who
provide opt-in consent or who are covered by "soft opt-in" exemptions (where
allowed by law).

 


HOW WE DISCLOSE PERSONAL INFORMATION WE COLLECT

In this section, we describe the types of disclosures we make and the categories
of third parties to whom we may disclose your personal information. All third
parties to whom your personal information is disclosed are subject to
contractual agreements that govern how your information can be used and must be
protected.

SALE OF DATA

We do not sell your personal information to third parties. Because we do not
sell your personal information, we do not provide any further detail regarding
such sales, nor do we provide a process for opting out of such sales.

AFFILIATED BLACKHAWK COMPANIES

We disclose personal information among our affiliated and subsidiary companies
in furtherance of the purposes set out in this Notice; their processing of your
personal information is subject to the requirements and limitations contained in
this Notice.

SERVICE PROVIDERS

We disclose your personal information to certain companies that provide services
to us and on our behalf and subject to our written instructions, such as
shipping, payment, hosting, and other support services; these companies may be
located in the EU, the United States, and other jurisdictions. As noted above,
we may also disclose your information to service providers who assist us in the
detection or investigation of fraudulent or illegal activities, for verification
of identity, and for compliance activities, such as required transaction-related
reporting or to verify your address in order to accurately calculate or process
tax-related matters.

CLIENTS AND PARTNERS

Where we process personal information on behalf of our clients or partners, we
process and share your personal information with that entity subject to its
instructions. In such cases, the client or partner is the Controller of your
personal information and we are a Processor. When we process personal
information on behalf of a Controller, that Controller’s privacy notice will be
presented, and their notice will apply instead of this Notice. In certain
circumstances, we may operate a site jointly with another entity and both will
function as Controllers; in those instances, you will see both the Blackhawk
Privacy Notice and the other entity’s privacy notice, and both will apply with
respect to the activities of each Controller individually.

REFERRAL PARTNERS

We offer referral-based commission systems through third-party partners so that
publisher websites may refer users to our pages to make purchases. These
partners will be identified when you sign up, and we will obtain your consent in
jurisdictions where this is required (in which case no other legal bases will
apply). Your personal information collected in such cases will be owned and
controlled by both Blackhawk and the partner as independent data controllers.
This Notice governs only Blackhawk’s use of such data. The partner’s own privacy
notice governs its use of the data.

PRODUCT SHORT NOTICES

Some products offered in conjunction with banks have unique data sharing
agreements. Where relevant, Blackhawk will make available to you short-form
privacy notices of each product’s sharing policies on that website or on this
page (see “Blackhawk Network Short-Form Privacy Notice” below).

ADDITIONAL DISCLOSURES

We may also disclose your personal information under the following
circumstances:

 * As permitted or required by law, such as to comply with a subpoena or
   court-issued discovery order, a warrant, a government request, or similar
   legal process;
 * When we believe in good faith that disclosure is necessary to respond to
   claims asserted against us; to protect our rights; to protect your safety or
   the safety of others; or, to investigate or prevent fraud.
 * If Blackhawk is involved in a merger, acquisition, or sale of all or a
   portion of its assets, or in the event of a bankruptcy or dissolution of our
   business, your personal information may be transferred to an acquiring
   business or third party, including in contemplation of or related to due
   diligence for such business transactions, subject to any applicable
   restrictions under applicable laws. You will be notified by email and/or by a
   prominent notice on our website of any change in ownership or uses of your
   personal information, as well as any choices you may have regarding your
   personal information.
 * We may disclose your data to any other third party with your prior consent.

 

AGGREGATE AND ANONYMIZED INFORMATION

We may share aggregate and anonymized information about users with certain third
parties, including for marketing, advertising, research or similar purposes.


COOKIES AND ONLINE TRACKING

We and our third-party service providers collect information automatically
through cookies, beacons, pixels, tags, scripts, and HTML5, as well as log
files. We, or our service providers, may combine this information with other
information, including personal information we collect about you, to record your
preferences, gather information about the use of our Services, identify when our
emails are viewed, personalize content and ads and track information about the
performance of our advertisements. We have a detailed Cookie Notice which is
incorporated into the Privacy Notice and provides more information about our
cookie-related practices and a number of service providers we use for our online
targeting activities.

COOKIES

These are small files with a unique identifier that are transferred to your
browser through our websites. These technologies allow us to collect information
such as browser type, time spent on our Sites, pages visited, language
preferences, and your relationship with us. We can use this information to
analyze trends, administer the website, track users’ movements around the
website, measure the effectiveness of our communications, tailor our advertising
to you, and gather demographic information about our user base as a whole. These
technologies may provide us with information about devices and networks you
utilize to access our Services, and other information regarding your
interactions with our Services. For detailed information about the cookies used
in the Services and how you can manage your cookie preferences or reject cookies
altogether, please read and review our Cookie Notice.

PIXELS, WEB BEACONS, CLEAR GIFS

These are tiny graphics with a unique identifier, similar in function to cookies
that we use to track the online movements of users of our web pages and our Ad
Services, and to personalize content, and to identify when our emails are viewed
or forwarded. Our third-party partners may use Local Shared Objects, such as
Flash cookies, to embed features on our sites. To manage Flash cookies, please
click here.

"DO NOT TRACK" PREFERENCES

Our Site does not recognize do-not-track signals; however, we do not use your
personal information to track your online activities across different Sites. We
only track your activity within a Site to the extent you log into your account.
Therefore, our practices remain the same whether or not you enable the "Do Not
Track" feature. For more information about do-not-track signals, please click
here or see in our Cookie Notice. In addition, some of our advertising partners,
may use standard technologies, such as cookies, pixel tags, and web beacons, to
collect information about your Internet activities across websites. We do not
share your personal information with those services; any information we provide
is in an anonymized or de-identified format. You may be able to disable certain
third-party cross-site tracking as described here or in greater detail in our
Cookie Notice.

THIRD-PARTY ANALYTICS

We also use automated devices and applications, such as Google Analytics (more
info here) to evaluate use of our Services. We use these tools to gather
non-personal information about users to help us improve our Services and user
experiences. These analytics providers may use cookies and other technologies to
perform their services on our behalf. See our Cookie Notice for more information
about our use of analytics tools.


MARKETING AND TARGETED ADVERTISING

We partner with third-party ad networks and third-party ad companies to manage
our advertising on other sites. Our third-party partners use technologies such
as cookies to gather information about your activities on this website and other
sites in order to provide you personalized advertising based upon your browsing
activities and interests. Please see the “Cookies and Online Tracking” section
above or our Cookie Notice  for more information.

MARKETING AND NEWSLETTERS

If you subscribe to our newsletters, we will use your name and email address to
send them to you. You may choose to stop receiving our newsletter or marketing
emails at any time by following the unsubscribe instructions included in these
emails or accessing the email preferences in your account.

THIRD PARTY TARGETING AND CUSTOM AUDIENCES

We partner with certain third parties so that we can better target ads and
content to our users, and others with similar interests, on these third parties’
platforms or networks (“Custom Audiences”). One such partnership is with
Facebook through their Custom Audiences program. Under that program we only
share a cryptographically pseudonymized (“hashed”) version of your email
address, which Facebook is prohibited from using for any other purpose and may
not share with any other party. (More info on Facebook Custom Audience here).
Subject to applicable laws, we may disclose certain information (such as your
email address) with third parties and we may work with third-party ad networks
and marketing platforms that enable us and other participants to target ads to
Custom Audiences submitted by us and others. If you would like to opt-out of
being included in our Custom Audiences going forward, email us at
ourprivacycommitments@bhnetwork.com and we will opt you out of our future Custom
Audiences.

For more detailed information about how we partner with third parties for
cookie-based ad targeting, please see our Cookie Notice.


OPTING OUT OF AD NETWORKS

How to opt out. If you wish to not have this cross-site information used for the
purpose of serving you targeted ads, you may opt-out of many ad networks by
visiting the DAA WebChoices Tool (or if located in the European Union, by visit
Your Online Choices). You will continue to receive ads on the sites you visit,
but the ad networks from which you have opted out will no longer target ads to
you based upon your activities on other sites.

Please note, however, that these opt-out mechanisms are cookie based, so if you
delete cookies, block cookies or use another device, your opt-out will no longer
be effective.

For more information about Interest Based Advertising, please visit Your Ad
Choices.


SOCIAL MEDIA WIDGETS

Our Sites include social media features, such as the Facebook "Like" button,
either hosted by a third-party or hosted directly on our website (“Widgets”).
Please refer to the privacy policies of the relevant third-party websites or
services to find out more about the collection, use, and disclosure of your
information through such features. We will comply with any legal obligations
placed on the use of these technologies by certain jurisdictions, which may
affect how these Widgets function.


SECURITY

The security of your personal information is important to us. We have
implemented safeguards designed to protect the personal information submitted to
us. Please note that no data transmission over the Internet can be guaranteed to
be 100% secure. As a result, we cannot guarantee or warrant the security of any
personal information that we process.


RETENTION

It is our policy to retain your information only for as long as is necessary to
fulfill the purpose for which it was collected and processed. We will retain
your information for as long as your account is active or as needed to provide
you services and for as long as may be required to comply with our legal
obligations, resolve disputes, maintain appropriate business records, and
enforce our agreements. Even if you request for your information to be deleted,
laws and regulations may require us to retain a copy of your information in our
files for a longer period of time. Unless a specific applicable law requires a
different retention period, most data will be retained for no longer than seven
(7) years.


IMAGE SUBMISSIONS AND PUBLIC DIRECTORIES

Some of our websites offer you the ability to upload your own image to be used
to create a personalized product. You may have the option to make these images
available in publicly accessible directories. You should be aware that any
information you provide in these areas may be read, collected and used by others
who access them. Depending on the website, you may be able to remove that
information yourself at any time. If not, you may request removal of your
personal information at any time by contacting the Customer Service team for
that website.


YOUR RIGHTS

FOR EU RESIDENTS

The European Union’s General Data Protection Regulation (“GDPR”) gives you
certain rights, including: a right to be notified of our data collection
practices; the purposes and lawful bases under which we process your data; if
our legitimate interests are a basis for processing, what those interests are;
the categories of data processed; the categories of third parties with whom data
is shared; the details of any data transfers outside of the EU and the
safeguards in place; the applicable retention periods or policies; the right to
access, correct, and delete (under certain circumstances) your personal
information; the right to receive a copy of your information in a “portable”
form so that you may transfer it to other services; the right to withdraw
consent for processing; the right to lodge a complaint with a data protection
authority; the right to be advised of the existence of any automated
decision-making, including profiling, and the right to object such decisions;
and, the right to withdraw consent without detriment. This Notice provides
details on how we honor those rights and the process for exercising them.

FOR CALIFORNIA CONSUMERS

California law gives you certain rights, including: a right to be notified of
(and to request more information about) our data collection practices; the
categories of data we process; the categories of third parties with whom data is
shared; the right to request disclosure (up to twice per year) of the personal
information we have about you or have had within the last 12 months: the right
to delete that information (under certain circumstances); the right to know if
your data is being sold; the right to know what personal information is being
sold and to opt-out of such sales (if applicable); the right to receive a copy
of your information in a “portable” form so that you may transfer it to other
services; and, the right to not be discriminated against for exercising these
rights. This Notice provides details on how we honor those rights and the
process for exercising them.

FOR ALL CUSTOMERS

Regardless of your location and jurisdiction, Blackhawk may at its sole
discretion choose to extend these rights to all individuals, and to comply with
reasonable requests in the manner detailed below. We do not charge for these
services. Where you are entitled to exercise a right, we will respond to your
request within the timeframe set out by applicable law (for EU residents this is
typically thirty (30) days, for California residents this is typically
forty-five (45) days). Where we provide answers on a voluntary basis, we will
provide a response within a reasonable timeframe.

ACCESS, CORRECTION, PORTABILITY, AND DELETION

You have the right to access, correct (“rectify”), or delete (“erase”) your
personal information held by us (“be forgotten”), or may ask for a restriction
of processing. You may also have the right to ask for an overview or copy of
your personal information or to request that certain of your personal
information be exported in a format so that you may take your data to another
provider where technically feasible (“data portability”).

On some of our Sites, you may exercise your rights to access, correct, or delete
your personal information by making the change directly on your account page.
You may also make these requests by sending an email to
ourprivacycommitments@bhnetwork.com, by using the toll-free number on the back
of your card, or by sending your request by postal mail to the address below.

Please note that there are some limitations to these rights. For example, we
will not be able to delete your personal information if we are required by law
to keep it or if we hold it in connection with a contract with you. Similarly,
access to your personal information may be refused if making the information
available would reveal personal information about another person or if we are
legally prevented from disclosing such information. If we cannot fulfill your
request, we will inform you about why we cannot comply with your request.

WITHDRAWAL OF CONSENT

Where we process your personal information based on your consent, you have the
right to withdraw your consent at any time without affecting the lawfulness of
the processing that occurred based on your consent before its withdrawal. Please
keep in mind that certain services are directly dependent upon our ability to
process your personal information, so if you withdraw your consent, request for
your information to be deleted, or if you otherwise object to our processing of
certain personal information, those services may no longer be functional.

OBJECT TO PROCESSING

You have the right to object to processing (including profiling) that occurs
based on legitimate interest grounds, where we are relying upon legitimate
interests as the primary basis for processing your personal information. If you
object, we must stop that processing unless we can demonstrate compelling
legitimate grounds for the processing that override your interests, rights and
freedoms, or we need to process the personal information for the establishment,
exercise or defense of legal claims. Where we rely upon legitimate interest as a
basis for processing, we believe that we can demonstrate such compelling
legitimate grounds, but we will consider each case on an individual basis.

OBJECT TO MARKETING

You have the right to object to our use of your personal information (including
profiling) for direct marketing purposes, such as when we use your personal
information to invite you to our promotional events.

RIGHT TO LODGE A COMPLAINT

If you believe that our processing of your personal information infringes your
rights or violates applicable data protection laws, you have a right to lodge a
complaint with the relevant supervisory authority. If you are in the United
Kingdom, you may contact the Information Commissioner’s Office. If you are
located in the European Union, a list of supervisory authorities is available
here. If you are located in another jurisdiction, you will need to research or
contact your local government for further guidance.


EXERCISING YOUR RIGHTS

To exercise your rights as described in this Notice, you may contact us via the
following methods:

 * Via the Toll-Free Number on the back of your gift card or debit card;
 * Via email to our Global Privacy Office at
   ourprivacycommitments@bhnetwork.com;
 * Via postal mail at: Blackhawk Network, Westside, London Road, Hemel
   Hempstead, Hertfordshire, HP3 9TD

 

Blackhawk Network,
Westside,
London Road,
Hemel Hempstead,
Hertfordshire, HP3 9TD

We will respond to your request in accordance with applicable law, and if we are
unable to comply with your request, we will provide information regarding why.

WHEN SUBMITTING A PRIVACY REQUEST

Depending on the nature of your request, we may request further proof of your
identity in accordance with applicable law. When sending a request, you can
expedite this process by providing the following information with your initial
inquiry:

 * Full name;
 * Email address associated with the relevant transaction(s);
 * Postal address associated with your account or transaction;
 * Product or service (for example, which Blackhawk website you used); and,
 * Only the last four (4) digits of the card associated with the transaction (if
   applicable).
   WARNING: For security reasons NEVER send the full card number, other
   information contained on the card (such as CVV or expiration date), and NEVER
   send any sensitive personal or financial information associated with you or
   the card.

If the nature of your request in unclear we may ask you for further
clarification. In the event that we require additional time to process your
request (if allowed by applicable law), we will advise you of that. If you are
unable to or refuse to provide satisfactory verification information, we may
deny your request in accordance with applicable law. If you do not follow the
procedures described in this Notice, including failure to lodge your request
through the channels or processes specified above, there may be significant
delays in responding to your request.

Please note that we will only respond directly to you, or your duly authorized
agent (with authority documented in strict accordance with applicable law), in
cases where we are the Controller of your personal information. Where we are
acting as a Processor on behalf of a client or partner, we will refer you to the
client or partner who is the data controller of your personal information. Our
agreements with data controllers, as well as applicable laws, require that we
process data in strict accordance with the controller’s explicit instructions,
therefore any actions we take to access, edit, or delete your data will only be
undertaken with their direct authorization and upon their explicit instructions.


PROTECTING CHILDREN’S PRIVACY ONLINE

Our Sites are not directed to children and we do not knowingly collect personal
information from children under the age of sixteen (16). We request that such
individuals do not provide personal information through our Sites. We reserve
the right to delete the personal information and terminate the account of anyone
violating this age policy.


INTERNATIONAL TRANSFERS

The personal information we collect from you may be transferred to, stored at,
or processed in other countries, including the United States or outside the
European Economic Area, which may not provide equivalent levels of data
protection to your home jurisdiction.

We will take steps to ensure that your personal information receives an adequate
level of protection in the jurisdictions in which we process it, including
through appropriate written data processing terms and/or data transfer
agreements. For transfers from the EU, United Kingdom (“UK”), or Switzerland, to
the US, Blackhawk relies on adequacy decisions by the EU Commission or putting
in place standard contractual clauses as approved by the European Commission or
another applicable supervisory body.


PRIVACY SHIELD CERTIFICATION

The Blackhawk Network Holdings, Inc., and the subsidiary companies listed below
comply with the EU-US Privacy Shield Framework (“EU Privacy Shield”) and the
Swiss-US Privacy Shield Framework (“Swiss Privacy Shield”), as set forth by the
US Department of Commerce regarding the collection, use, and retention of
personal information transferred from the European Union, the United Kingdom
(“UK”), and/or Switzerland, to the United States:

 * Blackhawk Engagement Solutions (DE), Inc.
 * Blackhawk Engagement Solutions (MD), Inc.
 * Blackhawk Engagement Solutions, Inc.
 * Blackhawk Issued Content, LLC
 * Blackhawk Network (Overseas Territories), LLC
 * Blackhawk Network California, Inc.
 * Blackhawk Network Holdings, Inc.
 * Blackhawk Network, Inc.
 * CardLab (TX), Inc.
 * CardLab, Inc.
 * CashStar Inc.
 * GiftCardLab, Inc.
 * GiftCards.com, LLC
 * Global Incentive Solutions, LLC
 * IMShopping, Inc.
 * Incentec Solutions, Inc.
 * Main Street Solutions US Inc.
 * Measureprepaid, LLC
 * NGC US, LLC
 * Omni Prepaid, LLC
 * OmniCard, LLC
 * S.V.M., L.P.
 * SVM PromoCo, LLC
 * SVM, LLC
 * TouchPoint Promotions, LLC

Blackhawk has certified to the Department of Commerce that the above companies
adhere to the Privacy Shield Principles with respect to such information. If
there is any conflict between the terms in this Notice and the Privacy Shield
Principles, the Privacy Shield Principles shall govern. To learn more about the
Privacy Shield program, and to view our certification, please visit
https://www.privacyshield.gov/.

Prior to July 16, 2020, Blackhawk relied on its EU-US Privacy Shield
certification as one means of demonstrating adequacy and safeguarding transfers
of data from the EU. In addition to Privacy Shield, Blackhawk also executed
Standard Contractual Clauses with entities involved in such data transfers. As
of July 16, 2020, Blackhawk will primarily rely on country-level adequacy
decisions or the Standard Contractual Clauses for EU and UK transfers. For
transfers occurring prior to July 16, 2020, Blackhawk will continue to be
responsible for the processing of EU and UK Personal Information under the EU
Privacy Shield Framework and will maintain full compliance with the requirements
of that framework until further notice. Subsequent transfers of EU or UK
Personal Information to any third-party acting as an agent on our behalf
occurring after July 16, 2020, will be under the terms of the EU Commission’s
Standard Contractual Clauses.

Prior to September 8, 2020, Blackhawk relied on its Swiss-US Privacy Shield
certification as one means of demonstrating adequacy and safeguarding transfers
of data from Switzerland. In addition to Privacy Shield, Blackhawk also executed
Standard Contractual Clauses with entities involved in such data transfers. As
of September 8, 2020, Blackhawk will primarily rely upon country-level adequacy
decisions or the Standard Contractual Clauses which will be made applicable by
contract to Swiss transfers. For transfers occurring prior to September 8, 2020,
Blackhawk will continue to be responsible for the processing of Swiss Personal
Information under the Swiss Privacy Shield Framework and will maintain full
compliance with the requirements of that framework until further notice.
Subsequent transfers of Swiss Personal Information to any third-party acting as
an agent on our behalf occurring after September 8, 2020, will be under the
terms of the Standard Contractual Clauses.

With respect to Personal Information received or transferred pursuant to the EU
or Swiss Privacy Shield Framework, Blackhawk is and will continue to be subject
to the regulatory enforcement powers of the U.S. Federal Trade Commission until
further notice.

In certain situations, Blackhawk may be required to disclose Personal
Information in response to lawful requests by public authorities, including to
meet national security or law enforcement requirements. To the best of our
knowledge, Blackhawk’s systems are not subject to routine access by government
authorities without warrants or appropriate accountability via established legal
process (such as subpoenas or court-ordered discovery).

If you have an unresolved privacy or data use concern that we have not addressed
satisfactorily, please contact our US-based third-party dispute resolution
provider (free of charge) at: https://feedback-form.truste.com/watchdog/request.
We are committed to cooperating in the resolution of disputes with individuals
through this process.

Under certain conditions, more fully described on the Privacy Shield website
https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may
invoke binding arbitration when other dispute resolution procedures have been
exhausted.

 


UPDATES TO THIS NOTICE

This Notice is subject to change, so if this is your first time reading it,
please make sure it is not the last. If we make any changes to this Notice, we
will post those changes on this page and revise the “Last Updated” date at the
top. If we make any changes to the ways in which we process your information
that could be reasonably be considered material or substantial, we will make
additional efforts to notify you of those changes, either by email or via a
prominent notice on this Site prior to the change becoming effective. Where
required by law, we will obtain your consent or give you the opportunity to opt
out of such changes. Any changes will become effective when we post the revised
Notice.


CONTACT INFORMATION

If you have any questions or concerns regarding this Privacy Notice, the ways in
which your personal information is being processed, or wish to exercise any of
the rights described above, please reach out to us using the contact information
below:

GLOBAL PRIVACY INQUIRIES

You may contact the Blackhawk Network Global Privacy Office:

 * Via the Toll-Free Number on the back of your gift card or debit card;
 * Via email to our Global Privacy Office at
   ourprivacycommitments@bhnetwork.com;
 * Via postal mail at: Blackhawk Network, Westside, London Road, Hemel
   Hempstead, Hertfordshire, HP3 9TD

 

Blackhawk Network,
Westside,
London Road,
Hemel Hempstead,
Hertfordshire, HP3 9TD

 

EU PRIVACY INQUIRIES

Blackhawk has appointed Data Protection Officers (DPOs) for the EU. You may use
the Global Privacy Office contact information shown above, or you may contact
the DPO for your region directly via email using the following address:
ourprivacycommitments@bhnetwork.com


CUSTOMER SERVICE INQUIRIES

The Global Privacy Office CANNOT assist you with general Customer Service
matters. Non-privacy matters sent to the Global Privacy Office may result in a
delay in resolving your Customer Service issue. For the quickest action on card
or transaction-related issues, please use the following links:

 * Blackhawk Network Corporate Customer Support –
   https://blackhawknetwork.com/customer-support
 * GiftCards.com Customer Support – https://www.giftcards.com/help-links
 * GiftCardMall.com Customer Support -- https://www.giftcardmall.com/contact-us
 * Happy Cards Customer Support – https://gethappy.happycards.com/pages/contact
 * MyPrepaidCenter.com Customer Support –
   https://www.myprepaidcenter.com/contact-us
 * OmniCard by Hawk Incentives Customer Support –
   https://www.omnicard.com/about-us/contact-us
 * Reloadit Customer Support – https://reloadit.com/Help

 


OTHER QUERIES OR COMPLAINTS

If you have any further queries or complaints that we are not able to answer,
you are recommended to contact the Data Privacy Supervisory Authority for the
country in which you reside. A list of EU/EEA Data Protection Authorities can be
found via the European Data Protection Board here. A list of data protection
authorities in other countries/regions can be found here.

 

 


BLACKHAWK NETWORK SHORT-FORM PRIVACY NOTICE

FACTS

WHAT DOES BLACKHAWK NETWORK (“BLACKHAWK”) DO WITH YOUR PERSONAL INFORMATION?

WHY?

Financial companies choose how they share your personal information. Federal law
gives consumers the right to limit some but not all sharing. Federal law also
requires us to tell you how we collect, share, and protect your personal
information. Please read this notice carefully to understand what we do.

WHAT?

The types of personal information we collect and share depend on the product or
service you have with us. This information can include:
 * Social Security number and payment history
 * Account balances and account transactions
 * Transaction history and purchase history

When you are no longer our customer, we continue to share your information as
described in this notice.

HOW?

All financial companies need to share customers’ personal information to run
their everyday business. In the section below, we list the reasons financial
companies can share their customers’ personal information; the reasons Blackhawk
Network chooses to share; and whether you can limit this sharing.

REASONS WE CAN SHARE YOUR PERSONAL INFORMATION

DOES BLACKHAWK SHARE?

CAN YOU LIMIT THIS SHARING?

FOR OUR EVERYDAY BUSINESS PURPOSES –

SUCH AS TO PROCESS YOUR TRANSACTIONS, MAINTAIN YOUR ACCOUNT(S), RESPOND TO COURT
ORDERS AND LEGAL INVESTIGATIONS, OR REPORT TO CREDIT BUREAUS

Yes No

FOR OUR MARKETING PURPOSES –



to offer our products and services to you Yes No

FOR JOINT MARKETING WITH OTHER FINANCIAL INSTITUTIONS

Yes No

FOR OUR AFFILIATES’ EVERYDAY BUSINESS PURPOSES –



information about your transactions and experiences Yes No

FOR OUR AFFILIATES’ EVERYDAY BUSINESS PURPOSES –



information about your creditworthiness No We don’t share

FOR OUR AFFILIATES TO MARKET TO YOU

No We don’t share

FOR NONAFFILIATES TO MARKET TO YOU

No We don’t share

QUESTIONS?

Visit www.blackhawknetwork.com or email us at privacy@bhnetwork.com

WHO WE ARE

WHO IS PROVIDING THIS NOTICE?

Blackhawk Network, Inc., on behalf of itself and its affiliates: Blackhawk
Network California, Inc., and Blackhawk Engagement Solutions, Inc.

WHAT WE DO

HOW DOES BLACKHAWK PROTECT MY PERSONAL INFORMATION?

To protect your personal information from unauthorized access and use, we use
security measures that comply with federal law. These measures include computer
safeguards and secured files and buildings.

HOW DOES BLACKHAWK COLLECT MY PERSONAL INFORMATION?

We collect your personal information, for example, when you:
 * open an account or provide account information
 * give us your contact information or show us your government issued ID
 * use your credit or debit card

We also collect your personal information from others, such as credit bureaus,
affiliates, or other companies.

WHY CAN’T I LIMIT ALL SHARING?

Federal law gives you the right to limit only:
 * sharing for affiliates’ everyday business purposes – information about your
   creditworthiness
 * affiliates from using your information to market to you
 * sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit
sharing. See below for more on your rights under state law.

DEFINITIONS

AFFILIATES

Companies related by common ownership or control. They can be financial and
nonfinancial companies.
 * Blackhawk’s affiliates include companies with a Blackhawk name and others,
   such as OmniCard and Hawk Incentives.

NONAFFILIATES

Companies not related by common ownership or control. They can be financial and
nonfinancial companies.
 * Blackhawk does not share with nonaffiliates so they can market to you

JOINT MARKETING

A formal agreement between nonaffiliated financial companies that together
market financial products or services to you.
 * Blackhawk may partner with nonaffiliated financial companies to jointly
   market financial products or services to you.

OTHER IMPORTANT INFORMATION

CA residents: Blackhawk will limit sharing with its affiliates to the extent
required by California law. Blackhawk will not share your personal information
for joint marketing with other financial institutions.

VT residents: If Blackhawk shares your personal information for joint marketing
with other financial institutions, it will share only your name, contact
information, and information about your transactions.

NV residents: We are providing this notice pursuant to Nevada law.


THIRD-PARTY PRIVACY NOTICES

If you have a card issued by MetaBank, NA, your cardholder data is governed by
the MetaBank Privacy Policy.

If you have a card issued by Sunrise Banks, your cardholder data is governed by
the Sunrise Banks Privacy Policy.

If you have a card issued by Peoples Trust Company, your cardholder data is
governed by the Peoples Trust Privacy Policy.

--------------------------------------------------------------------------------

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