ALLTROO PRIVACY POLICY 

Last modified April 25th, 2024

ATTENTION: PLEASE READ THIS ALLTROO PRIVACY POLICY (“PRIVACY POLICY”) CAREFULLY. THIS PRIVACY POLICY PERTAINS TO YOUR ACCESSING, DOWNLOADING, OR USING THE ALLTROO.COM WEBSITE AND YOUR ACCESSING ANY ASSOCIATED CONTENT INCLUDING EMAIL SUBSCRIPTIONS, SOCIAL MEDIA CONTENT, AND RSS FEEDS (COLLECTIVELY, THE “SERVICE”). 

ATTENTION: PLEASE READ OUR PRIVACY POLICY CAREFULLY BEFORE ACCESSING OR USING THE SERVICE. ACCESSING OR USING THE SERVICE INDICATES THAT YOU ACCEPT THIS PRIVACY POLICY IN FULL. IF YOU DO NOT ACCEPT THIS PRIVACY POLICY, DO NOT ACCESS OR USE THE SERVICE. You acknowledge (a) that You have read and understood this Privacy Policy; (b) that You consent to the terms of this Privacy Policy; and (c) that by agreeing to this Privacy Policy, You consent to receive notifications regarding security incidents to the email address We Consumer Health Data Privacy Policyhave on file for You.

The Service is operated by ALLTROO, Inc., 211 N 1st St, Suite 325, Minneapolis, MN 55401 (“We,” “us,” “our,” or “Alltroo”). This Privacy Policy describes the information collected through your (“Your”) use of the Service, how We use it, how We share it, how We protect it, and the choices You can make about Your information. Capitalized terms not defined in this Privacy Policy have the meaning given to them in the Terms of Use.

Unless explicitly stated otherwise, any new features that augment or enhance the current Service shall be subject to this Privacy Policy.

Please review the Privacy Policy each time You use the Service. BY USING THE SERVICE, YOU AGREE TO ACCEPT THE MOST RECENT VERSION OF THE PRIVACY POLICY. If We materially change this Privacy Policy, We will let You know by showing it to You again when You access the Service and sending an email notifying You of the changes to the email address We have on file for You. 

SUMMARY

Below is a high-level summary of the Personal Information We collect, and how We use and disclose it. When you provide your Personal Information to us, you understand and agree to our collection, use and disclosure as explained in the detailed policy provided below. 

Information We Collect: 

How We Use Your Information:

We use the information that We collect for the purposes You provide it and to:

  • offer our Service, to respond to your requests, inquiries and comments.
  • display advertising and information about our sweepstakes and charities. 
  • operate and improve the Service.
  • send You news, updates and other information if permitted by law.
  • evaluate and analyze our Service and email usage patterns including by compiling aggregate data.
  • for purposes related to prevention of fraud, abuse and response to law enforcement.

To Whom We Disclose Your Information:

How We Secure Your Information: We implement a variety of security measures to protect the safety of Your Personal Information when You enter, submit, or access Your Personal Information. We cannot guarantee its absolute security. No Internet, email, or mobile application transmission is ever fully secure or error free.

Our Retention and Storage of Your Data: We will retain Your information for as long as You use the Service and for a reasonable time thereafter. If you use the Service outside of the United States, You consent to having Your data transferred to the United States and understand and agree that your information may be subject to lawful requests by law enforcement and other authorities. 

Your Choices Regarding Your Information: You can change Your information or account by following the instructions in this Privacy Policy. You may have other rights as explained in this Privacy Policy. Please contact us by email at [email protected], or by writing us at ALLTROO, Inc., 211 N 1st St, Suite 325, Minneapolis, MN 55401, if You have any questions about this Privacy Policy.

DETAILED POLICY

  1. Information We Collect 

The following describes the information We collect relating to identified or identifiable individuals (“Personal Information”).

  1. From You

We collect information from You when You use the Service, contact or interact with us, and voluntarily provide us with Your comments and other content in connection with using the Service. 

  1. When You sign up for our email newsletter or interact with emails from Us

We may collect Your email address, IP address, and browser user agent string. When you interact with an email, we may collect whether you saw the email and/or entered into a Sweepstakes from it, donation entry amount, total recipients, unique opens, unique clicks, cart activity, cancelled orders, whether you viewed a Sweepstakes page, fulfilled orders, whether you mark an email as spam, and bounced email information.

  1. When You sign up to receive SMS/text messages

We may collect Your first name, last name, mobile phone number, and carrier information.

  1. When You create an account on the Service

We may collect Your first name, last name, email address, password, telephone number, previous and active Sweepstakes, entry history, and Donation history.

  1. When You enter a sweepstakes

We collect Your first name, last name, email address, billing address, mailing address, telephone number, account login information, bank account details, and payment card information.

  1. If You have won a prize

We may collect Your first name, last name, email address, physical address, mailing address, telephone number, user ID for video conference apps (such as Zoom Video Communications, Microsoft Teams, GoToMeeting, or other video telephony platforms), date of birth, age, and audio visual information (such as videos or photographs of You related to Your win). We collect date of birth and age solely for purposes of verifying eligibility of our winners. In some cases, we may collect Consumer Health Data as defined by applicable law. For more information, please review our Consumer Health Data Privacy Policy below.

  1. When You donate directly to a Charity through the Service

We may collect Your first name, last name, email address, billing address, mailing address, telephone number, Alltroo account login information, bank account details, and payment card information. In some cases, we may collect Consumer Health Data as defined by applicable law. For more information, please review our Consumer Health Data Privacy Policy below.

  1. When You Contact Us or submit a Business Inquiry through the Service

We may collect Your first name, last name, email address, telephone number, user agent, IP address, and any other information You choose to provide in your message. 

  1. When You register as a Celebrity Partner

For an ongoing partnership, one-time sweepstakes, or as part of the Walter Payton NFL Man of the Year, We may collect Your first name, last name, email address, telephone number, title, professional resume and accolades, agency information, professional affiliation (e.g. professional sports league, other industry information), IP address, and any other information that You or your representative choose to provide.

  1. When You register as a Charity Partner

We may collect Your first name, last name, email address, telephone number, mailing address, proof of tax-exempt status, other charity information (e.g. mission, causes, affiliations, financial records), and any other information that You choose to provide.

  1. From Third Parties

We may also collect information about you from third-party sources, including social media, service providers, partners, and analytics companies. 

  1. Facebook, Instagram, TikTok, and X

The Service provides links to our Facebook, Instagram, TikTok, and X pages. If You connect with these platforms through the Service, We may receive Personal Information about You, including information related to actions You take with social plugins, such as share or like buttons. 

  1. Google and YouTube

We use Google analytics and adverting tools on our Service. We also host videos using YouTube API. When You use the Service, We receive Personal Information about you from Google and YouTube, such as IP address, Your internet service provider, and Personal Information created or inferred via Google Analytics, such as your interests, preferences, and internet browsing history. 

  1. Charitable Organizations and Change Starts With Me

As described in the TOU, We work with Change Starts With Me, a U.S. 501(c)(3) tax-exempt public charity, federal tax ID # 85-1322019 (“CSWM”) to effectuate Donations. If You make a Donation to CSWM, We may receive Personal Information about you and Your Donation from CSWM. We may also receive Personal Information from other charitable organizations who partner with us through the Service. 

  1. Automatic Collection

We automatically collect information regarding each user of our Service, including Your IP address, the domain name of Your Internet service provider, the Service features You use and the time of Your use, and Your device information (e.g., device model and operating system version). Additional information collected is described in the Analytics and Cookies sections below. We may combine all of the information We collect from or about You and use it in the manner described in this Privacy Policy.

  1. How We Use Your Information 

We use the information that We collect for several purposes, including:

  • The purposes for which You provided it, such as processing your donation, recording your Sweepstakes entry, or as part of your story when you win a Sweepstakes;
  • To provide information and respond to requests for information;
  • To process and respond to inquiries and comments;
  • To display relevant advertising, information about Sweepstakes, and information about Charities;
  • To administer, operate, and improve the Service;
  • To personalize and enhance Your experience using the Service;
  • To send periodic marketing emails. If You choose, the email address You provide may be used to send You occasional news, updates, related product or service information, etc. Note: If at any time You would like to unsubscribe from receiving future commercial emails, We include detailed unsubscribe instructions at the bottom of each email; 
  • To send periodic marketing SMS/text messages. If You choose, the mobile phone number You provide may be used to send You occasional news, updates, related product or service information, etc. via SMS/text message. Note: If at any time You would like to unsubscribe from receiving future commercial text messages, You may reply STOP and/or follow the unsubscribe instructions that We provide via text message;
  • To generate and review reports and data about our user base and Service usage patterns;
  • To analyze the accuracy, effectiveness, usability, or popularity of the Service;
  • To compile aggregate data for internal and external business purposes;
  • To prevent fraud and abuse of the Service and to otherwise protect users and visitors and our business;
  • To assist law enforcement and respond to subpoenas; 
  • To advertise the Service to You, including through the use of Targeted Advertising; and
  • To perform other business activities as needed, or as described elsewhere in this Privacy Policy.
  • As explained elsewhere in this Privacy Policy, Personal Information We collect may be processed by our partners and service providers in providing services related to the Service (such as administration services, technical services relating to the maintenance, servicing, and upgrading of software, hosting services, customer service, data migration services, and analytical services, among others). 
  1. How Your Information is Disclosed 

Information may be transferred or disclosed to third parties in accordance with our Privacy Policy. Please note that a user may choose not to share certain information as described in the Analytics section below.

  1. Third Party Service Providers and Business Partners

We may use third-party service providers and business partners to perform functions in connection with the Service, such as marketing, website hosting, analyzing the Service, managing relationships, advertising, analyzing and improving the Service usefulness, reliability, user experience, and operation, storing data, and as otherwise described in this Privacy Policy. We also may share Your Personal Information with these providers and partners for their direct marketing and promotional purposes and so they can provide services to You. These service providers may be located in countries outside of your jurisdiction of residence, and your information may be accessible to law enforcement or other authorities pursuant to lawful request. We use the following service providers or business partners for the purposes described below:

  • Adobe.
  • Attentive. We use Attentive for email marketing and customer relationship management. For more information about the data Attentive collects through this service, please visit: https://www.attentive.com/legal/privacy. 
  • Brandwatch. We use Brandwatch for social media marketing management. For more information about the data Brandwatch collects through this service, please visit: https://www.brandwatch.com/legal/author-privacy-policy/. 
  • Canva. We use Canva for design marketing and social media content. For more information about the data Canva collects through this service, please visit: https://www.canva.com/policies/privacy-policy/. 
  • Facebook/Meta. By clicking on the Facebook button on the Service, You will be automatically transported to the official Facebook Page for Alltroo, https://www.facebook.com/Alltroo/.
    • General. We use Facebook for social media marketing purposes. Facebook may track Your activity over time and across websites. For more information about the data Facebook collects, please visit Facebook’s data policy at: https://www.facebook.com/privacy/policy/.
    • Custom Audience and Meta Pixel. We use Facebook Custom Audience and the Meta Pixel to analyze user activity on our Service for remarketing and behavioral targeting. Facebook Custom Audience helps us to identify audiences for ad targeting among people who are on Facebook. Using the actions You take on Meta’s family of apps and services, and the actions You take on the Service, Facebook Custom Audience aids us in displaying ads to Meta users who have visited our Service, Meta users who have engaged with our content across the Meta family of apps and services, and Meta users who share certain characteristics with visitors to our Service or users who have engaged with our Meta content. Meta and other third parties may use cookies, web beacons, and other storage technologies to collect information from the Service and from other Internet websites, and use that information for the purposes of targeting ads and providing measurement services. For specific information about Meta Pixel, please visit: https://www.facebook.com/business/help/742478679120153?id=1205376682832142. If You are logged into Facebook, You can opt out of the collection and use of Your information for targeted advertising by visiting: https://www.facebook.com/settings?tab=ads. You can also visit http://optout.aboutads.info/?c=2&lang=EN for more information about ad targeting and exercising Your choice to opt out of the collection of certain information for ad targeting. Facebook/Meta may track Your activity over time and across websites. 
    • Facebook Connect. We use Facebook Connect to perform site analytics. For more information on the information that Facebook collects, please visit the Facebook privacy policy at https://www.facebook.com/about/privacy.
  • Google. We use various Google products and services, including:
    • Tag Manager and Dynamic Remarketing. We use Google Tag Manager and Dynamic Remarketing to deploy marketing tags and cookies. Google Tag Manager or Dynamic Remarketing may collect information related to tag firing, information contained in standard HTTP requests logs, and information related to online identifiers, such as cookie identifiers and IP addresses. For more information, please visit Google’s privacy policy at: https://policies.google.com/privacy?hl=en-US. 
    • APIs and Static. We use Google APIs and Static to deliver our website to You by deploying content delivery network (CDN) headers and cookies. For more information, please visit Google’s privacy policy at: https://policies.google.com/privacy?hl=en-US.
    • Custom Audiences. Google Custom Audiences features help us to identify audiences for ad targeting among people who use Google. Using the actions You take on Google’s services and the actions You take on the Service, Google aids us in displaying Google ads to Google users who have visited our Service, Google users who have engaged with our content across Google’s services, and Google users who share certain characteristics with visitors to our Service or users who have engaged with our content. For specific information about Google Custom Audiences, please visit: https://support.google.com/google-ads/answer/9805516?hl=en. If You are logged into Google, You can opt out of the collection and use of Your information for certain advertising by visiting the Data & personalization portion of your account settings.
    • Analytics. We use Google Analytics to analyze user activity on our Service for remarketing and behavioral targeting. Google and other third parties may use cookies, pixels, web beacons, and other storage technologies to collect information from the Service and from other Internet websites, and use that information for the purposes of targeting ads and providing measurement services. Google may track Your activity over time and across websites. 
    • Meet. We use Google Meet to record video calls, such as when we chat with Sweepstakes winners. For more information, please visit the Google Meet privacy policy at: https://support.google.com/meet/answer/9852160?hl=en.
  • Instagram. We use Instagram for marketing purposes. By clicking on the Instagram button on the Service, You will be automatically transported to the official Instagram Page for Alltroo, https://www.instagram.com/alltroo.  For more information, please visit the Instagram privacy policy at:  https://privacycenter.instagram.com/policy.
  • Klaviyo. We use Klaviyo for email marketing and customer relationship management. For more information about the data Klaviyo collects through this service, please visit: https://www.klaviyo.com/legal/privacy/privacy-notice. 
  • Linktree. We use Linktree for social media marketing services. For more information about the data Linktree collects through this service, please visit: https://linktr.ee/s/privacy/. 
  • Mailchimp. We use Mailchimp to send emails. Mailchimp may collect Your name, email address, telephone number, address, device information (including Your IP address, operating system, browser ID, email client type, and other information about Your system and connection), and usage data (including the dates and times when You access emails and Your browsing activities, such as information related to the pages You view and the emails You open), including through the use of cookies and tracking technologies. For more information, please visit the Mailchimp privacy policy at: https://mailchimp.com/legal/privacy/. 
  • Meta Ad Manager. We use Meta Ad Manager for targeting paid media ads and advertising cookies. For more information about the data Meta collects through this service, please visit: https://www.facebook.com/privacy/policy/. See other Meta-related disclosures in Facebook section of this Privacy Policy.
  • Monday.com. We use Monday.com for project management and work OS. For more information about the data Monday.com collects through the Service, please visit: https://monday.com/l/privacy/privacy-policy/. 
  • Mountain. We use Mountain for advertising and marketing services. For more information about the data Mountain collects through the Service, please visit: https://mountain.com/privacy-policy/. 
  • PayPal. We use PayPal for payment processing. For more information about the data PayPal collects through the Service, please visit: https://www.paypal.com/us/legalhub/privacy-full. 
  • Power Bi. We use Power Bi for customer performance reporting and dashboards. For more information about the data Power Bi collects through the Service, please visit: https://www.powerbitiles.com/PBIPortalPrivacy/. 
  • Priority. We may use Priority for payment processing. For more information about the data Priority collects through the Service, please visit: https://prioritycommerce.com/privacy/. 
  • Reddit. We use Reddit for marketing purposes, including the Reddit Pixel to analyze user activity on our Service for remarketing and behavioral targeting. The Reddit Pixel helps us to identify audiences for ad targeting among people who are on Reddit. Using the actions You take on Reddit’s services and the actions You take on the Service, the Reddit Pixel aids us in displaying Reddit ads to Reddit users who have visited our Service, Reddit users who have engaged with our content across Reddit’s services, and Reddit users who share certain characteristics with visitors to our Service or users who have engaged with our content. Reddit and other third parties may use cookies, pixels, web beacons, and other storage technologies to collect information from the Service and from other Internet websites, and use that information for the purposes of targeting ads and providing measurement services. Reddit may track Your activity over time and across websites. For more information about the data Reddit collects, please visit Reddit’s privacy policy at: https://www.redditinc.com/policies/privacy-policy. For specific information about Reddit Pixel, please visit: https://advertising.reddithelp.com/en/categories/managing-ads/implementing-reddit-pixel. If You are logged into Reddit, You can opt out of the collection and use of Your information for targeted advertising by visiting: https://www.reddit.com/personalization and in your account settings.
  • Scan-IT to Office. We use Scan-IT for processing entry data for mailed in Sweepstakes entries. For more information about the data Scan-IT collects through the Service, please visit: https://www.tec-it.com/en/website/legalconditions/Default.aspx#Privacy. 
  • Square. We use Square for payment processing. For more information about the data Square collects through the Service, please visit: https://squareup.com/us/en/legal/general/privacy. 
  • TikTok. By clicking on the TikTok button on the Service, You will be automatically transported to the official TikTok Feed for Alltroo, @Alltroo_Official https://www.tiktok.com/@alltroo_official. We use TikTok Analytics and the TikTok Pixel to analyze user activity on our Service for remarketing and behavioral targeting. These services help us to identify audiences for ad targeting among people who use TikTok. Using the actions You take on TikTok’s services and the actions You take on the Service, TikTok Analytics and the TikTok Pixel aid us in displaying TikTok ads to TikTok users who have visited our Service, TikTok users who have engaged with our content across TikTok’s services, and TikTok users who share certain characteristics with visitors to our Service or users who have engaged with our content. TikTok and other third parties may use cookies, pixels, web beacons, and other storage technologies to collect information from the Service and from other internet websites and use that information for the purposes of targeting ads and providing measurement services. TikTok may track Your activity over time and across websites. For more information about the data TikTok collects, please visit TikTok’s privacy policy at: https://www.tiktok.com/legal/page/us/privacy-policy/en. For specific information about TikTok’s Pixel, please visit: https://ads.tiktok.com/help/article/tiktok-pixel?redirected=2. If You are logged into TikTok, You can opt out of the collection and use of Your information for targeted advertising by visiting: https://www.tiktok.com/safety/en/ads-and-data/ and in your account settings. 
  • Woo Commerce. We use Woo Commerce for online store and website back end operations. For more information about the data Woo Commerce collects through the Service, please visit: https://woo.com/fr-be/privacy%20policy/. 
  • WordPress. We use WordPress for website back end operations and content management. For more information about the data WordPress collects through the Service, please visit: https://wordpress.org/about/privacy/.  
  • WP Engine. We use WP Engine for hosting WordPress. For more information about the data WP Engine collects through the Service, please visit: https://wpengine.com/legal/privacy/. 
  • YouTube. We use YouTube for marketing. For more information about the data Youtube collects through the Service, please visit: https://www.youtube.com/howyoutubeworks/our-commitments/protecting-user-data/. 
  • X. By clicking on the X button on the Service, You will be automatically transported to the official X Feed for Alltroo, @AlltrooOfficial https://twitter.com/alltrooofficial. You can also click-to-Tweet about Alltroo directly from the Service. When you do this, X may receive information including the web page you visited, your IP address, browser type, operating system, and cookie information. We use the X Tag for remarketing and advertising purposes. We use the X advertising cookies to analyze user activity on our Service for remarketing and behavioral targeting. The X advertising cookies help us to identify audiences for ad targeting among people who are on X. Using the actions You take on X’s services and the actions You take on the Service, the X advertising cookies aid us in displaying X ads to X users who have visited our Service, X users who have engaged with our content across X’s services, and X users who share certain characteristics with visitors to our Service or users who have engaged with our content. X may use cookies, tracking pixels, and other storage technologies to collect information from the Service and from other Internet websites, and use that information for the purposes of targeting ads and providing measurement services. X may track Your activity over time and across websites. For more information about the data X collects, please visit X’s privacy policy at: https://twitter.com/en/privacy. For specific information about X advertising cookies, please visit https://business.twitter.com/en/help/campaign-measurement-and-analytics/conversion-tracking-for-websites.html. If You are logged into X, You can opt out of the collection and use of Your information for certain advertising by visiting the Personalization and data portion of your account settings.
  1. Public

If you win a Sweepstakes or attend events with a Sweepstakes winner, We may disclose your photo, video, and name for promotional purposes. More information about such uses will be provided to winners once they have been selected.

  1. Business Changes

If We become involved in a merger, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution, or other transaction, or if the ownership of all or substantially all of our business otherwise changes, We may transfer Your information to a third party or parties in connection therewith. 

  1. Affiliates

We may also share Your information with our affiliates for purposes of providing our Service to you and for purposes consistent with this Privacy Policy. Our affiliates will be required to maintain that information in accordance with this Privacy Policy.

  1. Charitable Organizations

We may also share Your information with companies, charities, nonprofit organizations, sponsors, and celebrities donating prizes and providing promotions. Before You complete a donation or recommended donation, you will have the option to provide Your name and contact information to our grantmaking authority Change Starts With Me.

  1. Payment Processor

Any payment-related information You provide through the Service may be shared with and may be stored by our payment processors and is subject to their policies, including in the case of data breach.

  1. Investigations and Law

We may disclose information about You to third parties if We believe that such disclosure is necessary to:

  • Comply with the law or guidance or cooperate with government or law enforcement officials or private parties;
  • Investigate, prevent, or take action regarding suspected illegal activities, suspected fraud, the rights, reputation, safety, and property of us, users, or others, or violations of our policies or other agreements with us;
  • Respond to claims and legal process (for example, subpoenas); and/or 
  • Protect against legal liability.
  1. Aggregated Information

We may share aggregated information relating to users of the Service with affiliated or unaffiliated third parties. This aggregated information does not contain Personal Information about any user.

  1. Analytics

We use third-party analytics tools to better understand who is using the Service and how people are using it. These tools may use cookies and other technologies to collect information about Your use of the Service and Your preferences and activities. These tools collect information sent by Your device or the Service and other information that assists us in improving the Service. This information may be used to analyze and track data, determine the popularity of certain content, and better understand Your online activity, among other things.

We use Google Analytics to better understand who is using the Service and how people are using it.   Google Analytics uses cookies to collect and store information, such as Service pages visited, places where users click, time spent on each Service page, Internet Protocol address, type of operating system used, language preference, location-based data, device ID, search traffic, gender, and age. We use this information to improve the Service and as otherwise described in this Privacy Policy. Please see: https://policies.google.com/technologies/partner-sites for information about how Google Analytics uses this information, and visit: https://tools.google.com/dlpage/gaoptout for information about the Google Analytics Opt-out Browser Add-on. Google may track Your activity over time and across websites.

We may deliver advertisements to You, including cross-contextual behavioral advertisements, also known as targeted ads. We may also work with third-party advertising companies that help deliver these advertisements. To learn more about third-party online advertising and to opt out of certain types of advertising, please see: http://optout.networkadvertising.org/?c=1.

  1. Cookies and Other Tracking Technologies

We, along with third parties, use cookies, web beacons, pixels, and other technologies. These technologies are used for tracking, analytics, and personalization and optimization of the Service.

Cookies are small files that are transferred to and stored on Your computer through Your Web browser (if You allow it) that enable the website’s or service provider’s system to recognize Your browser and capture and remember certain information. You can instruct Your browser to stop accepting cookies. But, if You do not accept cookies, You may not be able to use all portions of all functionality of the Service.

Web beacons and pixels are small strings of code that provide a method for delivering a graphic image on a web page or in an email message for the purpose of transferring data. You can disable the ability of web beacons to capture information by blocking cookies and disabling remote content and images in your email system and browser.

We and authorized third parties may use cookies and similar technologies for the following purposes:

  • for “strictly necessary” purposes necessary for our Service to operate (such as maintaining user sessions, content delivery, online shopping carts and the like);
  • for “functional” purposes, such as to enable certain features of our Service (for example, to display custom or localized content or configurations, fonts, or similar features);
  • for “analytics/performance” purposes and to improve our digital services, such as to analyze the traffic to and on our digital services (for example, We can count how many people have looked at a specific page, or see how visitors move around the Service when they use it, to distinguish unique visits/visitors to our digital services, and what website they visited prior to visiting our Service, and use this information to understand user behaviors and improve the design and functionality of the Service); 
  • for “targeting,” Targeted Advertising, or other advertising and marketing purposes, including technologies that process information about your online activities, preferences, and other data so that We and authorized third parties can deliver, buy, or target advertisements which are more likely to be of interest to you; and
  • for “social media” e.g. via third-party social media cookies, or when you share information using a social media sharing button or “like” button on our Service or you link your account or engage with our content on or through a social media website such as Facebook, Reddit, TikTok, or X.

See Your Choices Regarding Your Information for information regarding opt-out rights for cookies and similar technologies.

Third parties may view, edit, or set their own cookies or place web beacons on our websites. We, or third party providers, may be able to use these technologies to identify you across platforms, devices, sites, and services. Third parties may engage in Targeted Advertising using this data. Third parties have their own privacy policies and their processing is not subject to this Policy.

  1. Targeted Advertising

In some jurisdictions, Alltroo, and certain third parties operating on or through the Service, may engage in advertising targeted to your interests based on Personal Information that We or those third parties obtain or infer from your activities across non-affiliated websites, applications, or services to predict your preferences or interests (“Targeted Advertising”). This form of advertising includes various third parties and service providers engaged in the processing of Personal Information in connection with advertising. These parties may be able to identify you across sites, devices, and over time.

The parties that control the processing of Personal Information for Targeted Advertising purposes may create or leverage information derived from Automatic Collection, Third Party Collection, or Collection from You. In some cases, these parties may also develop and assess aspects of your activity on the Service to determine whether you are a type of person to whom a company wants to advertise, and determine whether and how ads you see are effective. These third parties may augment your profile with demographic and other Personal Information, and may track whether you view, interact with, or how often you have seen an ad, and whether you purchased advertised goods or services or entered a Sweepstakes.

We generally use Targeted Advertising for the purpose of marketing our Service and third-party goods and services, and to send marketing communications, including by creating custom marketing audiences on third-party websites or social media platforms.

  1. Security

We implement a variety of security measures to protect the safety of Your Personal Information when You enter, submit, or access Your Personal Information. Please keep Your account password secure to help ensure the safety of Your Personal Information. 

While We take reasonable measures to protect the information You submit via the Service against loss, theft, and unauthorized use, disclosure, or modification, We cannot guarantee its absolute security. No Internet, email, text message, or mobile application transmission is ever fully secure or error free. Email or other messages sent through the Service may not be secure. You should use caution whenever submitting information through the Service and take special care in deciding with which information You provide us.

We cannot guarantee that transmissions of Your Personal Information will be fully secure and that third parties will never be able to defeat our security measures or the security measures of our partners. WE ASSUME NO LIABILITY FOR DISCLOSURE OF YOUR INFORMATION DUE TO TRANSMISSION ERRORS, THIRD-PARTY ACCESS, OR CAUSES BEYOND OUR CONTROL.

If you use the Service outside of the United States, You consent to having Your data transferred to the United States, where it may be accessible to law enforcement of other authorities pursuant to lawful request. 

  1. Data Retention Policy, Managing Your Information

The primary location of storage of data obtained from Service visitors from the United States is on Microsoft cloud data centers located in various U.S. cities. The primary location of storage of data obtained from Service visitors from Canada is on Microsoft cloud data center located in Quebec City and Toronto. 

We will retain Your information for as long as You use the Service and for a reasonable time thereafter to fulfill our business purposes and may retain data for such longer purposes as is required to fulfill legal or regulatory requirements. We may maintain anonymized or aggregated data, including usage data, for analytics purposes. We may retain and use Your information as necessary to comply with our legal obligations, resolve disputes, and/or for the period required by laws in applicable jurisdictions. Please note that some or all of the information We have collected may be required for the Service to function properly.

  1. Links to Other Websites or Applications

This Privacy Policy applies only to the Service. The Service may contain links to other websites or apps or may forward users to other websites or apps that We may not own or operate and to which this Privacy Policy does not apply. The links from the Service do not imply that We endorse or have reviewed these websites or apps. The policies and procedures We describe here do not apply to these websites or apps. We neither can control nor are responsible for the privacy practices or content of these websites or apps. We suggest contacting these websites or app providers directly for information on their privacy policies. Nonetheless, We seek to protect the integrity of the Service and welcome any feedback about these linked websites and mobile applications.

  1. Your Choices Regarding Your Information

You have choices regarding the use of information by the Service.

  1. Changing Your Information

To change Your information, please contact us at [email protected].  

  1. Closing Your Account

If the email account associated with Your email address is not active, We may remove it from our system without notice. To close Your account, click on your profile, click to edit settings, and then click “deactivate account” or email us at: [email protected].

  1. Marketing Communications

You can withdraw your consent to receive marketing communications by clicking on the unsubscribe link in an email (for email), by responding with “OPT-OUT,” STOP, or other supported unsubscribe message (for SMS), by adjusting the push message settings for our mobile apps using your device operating system (for push notifications), or for other communications, by contacting us using the information above. To opt-out of the collection of information relating to email opens, configure your email so that it does not load images in our emails.

  1. Cookies, Similar Technologies, and Targeted Advertising

General– If you do not want information collected through the use of cookies, you can manage/deny cookies (and certain technologies) using your browser’s settings menu or our Manage Cookies page. You may need to opt out of third-party services directly via the third party. For example, to opt-out of Google’s analytic and marketing services, visit Google Analytics Terms of Use, the Google Policy, or Google Analytics Opt-out.

Targeted Advertising– You may opt out or withdraw your consent to Targeted Advertising by Contacting Us. In some cases, you may be able to opt-out by submitting requests to third party partners, including for the vendors listed below: 

Do-Not-Track – Your browser or device may offer You a “Do Not Track” option, which allows You to signal to operators of websites, web applications, mobile applications, and services (including behavioral advertising services) that You do not wish such operators to track certain of Your online activities over time and/or across different websites or applications. The Service does not support Do Not Track requests at this time, which means that We or our analytics providers or other third parties with which We work may collect information about Your online activity both during and after Your use of the Service. 

  1. Children

The Service is not intended for children under 18 years of age. We do not knowingly collect Personal Information from an individual under age 18. If You are under the age of 18, please do not submit any Personal Information through the Service. If You have reason to believe that We may have accidentally received Personal Information from an individual under age 18, please contact us immediately at [email protected]. 

  1. Changes to Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this Privacy Policy periodically, and especially before You provide any information. This Privacy Policy was made effective on the date indicated above. 

  1. How to Contact Us

Please feel free to contact our Privacy Officer by email at [email protected], or by writing us at ALLTROO, Inc., 211 N 1st St, Suite 325, Minneapolis, MN 55401, if You have any questions about this Privacy Policy.

  1. Your Nevada Privacy Rights 

The Nevada Revised Statutes (NRS 603A.300 et seq.) permit a Nevada consumer to direct an operator of an Internet website or online service to refrain from making any sale of any covered information the operator has collected or will collect about that consumer. If You are a Nevada consumer, You may submit a request pursuant to this directive by emailing us at [email protected]. We will provide further information about how We verify the authenticity of the request and Your identity. For more information on how we process the Consumer Health Data of Nevada residents, please see our Consumer Health Data Privacy Policy below.

  1. Your California Privacy Rights

Section 1798.83 of the California Civil Code permits California residents to request from a business, with whom the California resident has an established business relationship, certain information about the types of Personal Information the business has shared with third parties for those third parties’ direct marketing purposes, and the names and addresses of the third parties with whom the business has shared such information during the immediately preceding calendar year. If You are a California resident, You may make one request each year by emailing us at [email protected], or by writing us ALLTROO, Inc., 211 N 1st St, Suite 325, Minneapolis, MN 55401. 

  1. Your Canadian Privacy Rights 

Consent. Subject to contractual and legal restrictions, You may withdraw your consent to the use of Your Personal Information at any time by contacting us. However, it should be noted, that in certain circumstances, this may affect Your ability to use the Service. We will inform You of the consequences of the withdrawal of consent, if applicable. 

Your Choices. You may opt out of all secondary uses of Personal Information for marketing and promotional purposes. You may contact us to opt out of the use or sharing of your Personal Information for these purposes.

Access and Correction. We permit a reasonable right of access to Your Personal Information. You may contact us to request access to and/or correction of the Personal Information We hold about You. We will take steps to authenticate Your identity prior to providing You with access to your Personal Information. If You demonstrate the inaccuracy or incompleteness of Your Personal Information, We will amend the information as required.

Such rights of access and correction are subject to any legal requirements and applicable exceptions. We endeavor to respond to all requests within a reasonable timeframe. Where an access request is refused, We will notify You in writing and provide our rationale for refusal along with a list of next steps available to You.

  1. Consumer Health Data Privacy Policy

  1. Categories of Consumer Health Data We Collect

We collect the following categories of personal information defined as consumer health data under Washington’s My Health My Data Act (“MHMDA”) and similar laws (“Consumer Health Data”), for the following purposes:

Categories of Consumer Health DataThe purposes of collecting, using and sharing How Consumer Health Data will be used or  processed
Individual health conditions, treatment, diseases, or diagnosisIf You have won a prize

When You donate directly to a Charity through the Service		The purposes for which You provided it, such as part of your story when you win a Sweepstakes, or if You include it when you make a donationIf shared by a past winner, to advertise the Service through past winner stories and social media posts
Social, psychological, behavioral, and medical interventions
Health-related surgeries or procedures
Diagnoses or diagnostic testing, treatment, or medication
Gender-affirming care information
Biometric data (voice recordings, imagery of face)The purposes for which You provided it, such as part of your story when you win a Sweepstakes, when You are a guest of a winner, or when we do a video call with YouTo advertise the Service through past winner stories, if You register as a celebrity partner, or through social media postsTo provide information and respond to requests for information, such as when You call us and leave a voicemailTo process and respond to inquiries and comments left via voicemail
  1. Sources of Consumer Health Data We Collect

We collect, use, and share Consumer Health Data from various sources, which include: 

From You: when You enter a Sweepstakes; if You have won a prize; if You are the guest of a Sweepstakes winner; When You donate directly to a Charity through the Service; When You Contact Us or submit a Business Inquiry through the Service; when we have recorded video or audio calls with You or you leave us a voicemail; and when You register as a Celebrity Partner.

From Social Media: when You post to social media or Your content is shared through social media to us.

  1. Sharing of Consumer Health Data

Categories of Consumer Health Data We Share 

We may share the following categories of Consumer Health Data with third parties and specific affiliates: 

Individual health conditions, treatment, diseases, or diagnosis; Social, psychological, behavioral, and medical interventions; Health-related surgeries or procedures; Diagnoses or diagnostic testing, treatment, or medication; Gender-affirming care information; Biometric data (voice recordings, imagery of face)

Categories of Third Parties with Whom We Share

We may share Consumer Health Data with the following categories of third-party recipients: third party service providers and business partners; public; affiliates; charitable organizations. 

Specific Affiliates with Whom We Share

We may share Consumer Health Data with the following Affiliates: Change Starts with Me.

  1. Washington My Health My Data Rights

Your Rights

Under the Washington State My Health My Data Act, Washington State residents and natural persons whose Consumer Health Data is collected in Washington may have the following rights, subject to verification, exceptions, and limitations:

Right to Confirm/Access/Know: Up to twice annually, you have the right to (a) confirm whether we are collecting, sharing, or selling your Consumer Health Data, and (b) access such data, including a list of all third parties and affiliates with whom we have shared or sold the consumer health data and an active email address or other online mechanism that you may use to contact these third parties. 

Right to Delete: You have the right to request deletion of the Consumer Health Data held by us and our affiliates, processors, contractors, and other third parties.

Right to Withdraw Your Consent/Opt-Out: You may withdraw any consent you have provided at any time. The consequence of your withdrawing consent might be that we cannot perform certain services for you, such as location-based services, personalizing or making relevant certain types of advertising, or other services conditioned on your consent or choice not to opt-out.

Right to Non-Discrimination: You have the right to not to receive discriminatory treatment as a result of your exercise of rights conferred by the My Health My Data Act.

How to Exercise Your Rights

You may submit requests as follows (please our review verification requirements below). 

  • You may send an email to [email protected] with your email address, phone number or address on file, and your request. 

If you have any questions or wish to appeal any refusal to take action in response to a MHMDA rights request, contact us at [email protected]. We will respond to any request to appeal within the period required by law. 

Washington Residents: If your appeal is unsuccessful, you can raise a concern or lodge a complaint with the Washington State Attorney General here.

Nevada Residents: If your appeal is unsuccessful, you can raise a concern or lodge a complaint with the State of Nevada Attorney General here.  

Verification of Consumer Health Data Rights Requests

If you submit a request, we typically must verify your identity to ensure that you have the right to make that request, to reduce fraud, and to ensure the security of Consumer Health Data. If an agent is submitting the request on your behalf, we reserve the right to validate the agent’s authority to act on your behalf. 

We may require that you match Consumer Health Data we have on file in order to adequately verify your identity. If you have an account, we may require that you log into the account to submit the request as part of the verification process. We may not grant access to certain Consumer Health Data to you if prohibited by law.