Privacy Policy

Effective December 26, 2025

1) Scope

This Privacy Policy describes how PREMES LLC d/b/a PuffPass ("we," "us") handles personal information for our websites, apps, and services (collectively, the "Services"), and for offline interactions that reference this Policy.

2) Personal Information We Collect

• Identifiers & contact: name, email, phone number, postal address, device IDs, account credentials.
• Commercial & subscription data: store affiliation, plan tier, purchase/transaction details, member IDs, subscription dates, rewards, promotional program participation.
• Communications: support messages, marketing preferences, SMS/email interaction data.
• Internet/technical: IP address, cookies, pixel tags, analytics data, pages viewed, referral/UTM parameters, approximate location derived from IP.
• Inferences: customer segments, preferences, purchasing patterns, propensity scores.
• Sensitive data (limited): where voluntarily provided or required by law (e.g., age or DOB to verify eligibility). We do not intentionally collect precise geolocation, health, or biometric identifiers.

3) Sources

We collect information directly from you, from your device/browser, from business clients using PuffPass, from partners (e.g., payment processors, email/SMS providers, analytics), from publicly available sources, and from data brokers where permitted by law.

4) How We Use Information

• Provide, secure, and troubleshoot the Services.
• Customer service and account management.
• Personalize content and offers; analytics and measurement.
• Marketing by email/SMS (with required consent/opt-out), including audience creation and lookalike modeling.
• Research and product improvement.
• Compliance with law, fraud prevention, and safety.
• Commercial purposes including data monetization, analytics products, and advertising.

5) Promotional Program Data

When you participate in PuffPass promotional programs, member rewards, or other benefit programs, we collect and use your information as follows:

• Participation Information: We collect your name, email address, and optionally phone number to administer program participation, track engagement, and communicate regarding benefits.
• Recipient Information Sharing: If you are selected to receive Promotional Value or benefits, we will share your name, email, and contact information with the participating retail partner ("Merchant") designated for fulfillment. This disclosure is necessary for you to redeem your benefit.
• Tax Reporting: For Promotional Value exceeding applicable IRS thresholds, we may collect additional information (such as mailing address and taxpayer identification) for tax reporting purposes as required by law.
• Program Communications: Recipient names and participation details may be used in program communications, testimonials, or promotional materials. Contact us if you wish to limit such use.
• Merchant Data Use: Merchants receiving recipient information are contractually obligated to use it solely for benefit fulfillment and platform-related services, and are prohibited from using it for unrelated marketing without your separate consent.

6) Disclosures; Selling & Sharing

7) Your Choices and Legal Rights

• Marketing communications: Opt out of marketing emails via the unsubscribe link. For SMS, reply STOP to opt out and HELP for help.
• Opt out of sale/sharing/targeted ads: Email support@premes.org with your request. We will honor browser signals (e.g., Global Privacy Control) where required by law.
• Data subject requests: Depending on your location, you may have rights to access, correct, delete, obtain a portable copy, or limit certain processing. Submit requests to support@premes.org.
• Appeals: If we deny your request, you may appeal by replying to our decision email. If unresolved, you may contact your state Attorney General.

8) State Privacy Notices (United States)

California: We provide opt-out of sale and sharing and honor Global Privacy Control signals where applicable. We do not knowingly sell or share personal information of consumers under 16 without affirmative authorization.

Colorado: We recognize a universal opt-out mechanism (UOOM), currently Global Privacy Control, for targeted advertising and sale where required.

Connecticut: We honor opt-out preference signals for targeted advertising and sale where required.

Virginia, Utah, Texas, Oregon, Delaware: We provide opt-out of sale and targeted advertising and will comply with applicable request, appeal, and sensitive-data requirements.

Additional state privacy laws may grant similar rights; we will comply where such laws apply to our processing.

9) Children

The Services are not directed to children under 13, and we do not knowingly collect personal information from them. We do not sell or share personal information of consumers we know are under 16.

10) Cookies & Tracking

We use cookies, pixels, SDKs, and similar technologies for essential functions, analytics, and advertising. You can manage browser settings, use Global Privacy Control where supported, or contact us to opt out.

11) Data Retention

We retain information as needed to provide the Services, for legitimate business purposes (including commercial data use), and as required by law. When no longer needed, we take steps to de-identify or delete data.

12) Security

We use reasonable administrative, technical, and physical safeguards to protect information. No method of transmission or storage is 100% secure.

13) International Users

If you access the Services from outside the United States, you understand your information may be processed in the U.S. and other countries with different data protection laws. Where required, we rely on appropriate legal bases and safeguards.

14) Changes

We may update this Policy from time to time. Material changes will be posted with an updated Effective date.

15) Contact

Email: support@premes.org

© 2025 PREMES LLC d/b/a PuffPass. All rights reserved.