Privacy Policy

Last modified: October 20, 2021

Introduction

Entertainment Benefits Group, LLC d/b/a Working Advantage ("Working Advantage" or "we", "us", or "our") respects your privacy and is committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website www.workingadvantage.com (our "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• On this Website.
• In email, text, and other electronic messages between you and this Website.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
• Offline, in accordance with relevant law, including, but not limited to, the California Consumer Privacy Act of 2018 ("CCPA").

It does not apply to information collected by:

• Any other website operated by Working Advantage or any third party (including our affiliates and subsidiaries); or
• Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children

Our Website is not intended for children, as defined under applicable law. Children may not provide any information to or on the Website. We do not knowingly collect personal information from children. If we learn we have collected or received personal information from a child without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child, please contact us here.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

• By which you may be personally identified, such as name, e-mail address, telephone number, and other identifiers by which you may be contacted online or offline ("personal information"); and/or
• About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• From third parties, for example, our business partners, employers, and single sign-on providers, including your name, company email address, birthdate, and information collected through automatic data collection technologies.

Information You Provide to Us

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering, logging in, or creating an account, entering a contest or sweepstake, signing up for email updates or other promotional materials, participating in surveys, posting content to publicly accessible areas of the Website, redeeming a reward, contacting us to sign up your company or to learn more about corporate rewards and incentives, nominating a brand you are interested in seeing, finding your company code, or chatting with us. This information may include your personal email address, work email address, password, first name, last name, birthdate, address, zip code, country, state/province, home telephone number, work telephone number, company code, reward number, industry, company name, number of employees, information related to what you need assistance with, order number, and the contents of your messages.
• Information that you provide when you submit orders. This information may include information related to your state of residency, date of birth, airline, flight number, order ID, billing information (including first name, last name, address, telephone number, email address, and information related to whether the address is residential or business), pickup information (including the first and last name of the individual who will be picking up the tickets), promo code, gift card/credit voucher/reward number, and payment information (including credit card number, expiration month and year, and CCV).
• Information that you provide when you contact us, including your first name, last name, email address, telephone number, order ID, contact reason, comments, and records and copies of your correspondence.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). See Choices about How We Use and Disclose Your Information for information on how we respond to web browser signals and other mechanisms that enable users to exercise choice about behavioral tracking.

The information we collect automatically helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Working Advantage, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across devices and different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices about How We Use and Disclose Your Information.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To facilitate advertising and marketing activities.
• To understand how our visitors use the Website and to improve and optimize its content, function, services, and presentation.
• To maintain the Website and troubleshoot problems.
• To detect and prevent fraudulent transactions.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including our Terms & Conditions of Use and Terms & Conditions of Sale.
• To notify you about changes to our Website or any products or services we offer or provide though it.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent

We may also use your information to contact you about our own and third parties' goods and services that may be of interest to you. If you do not want us to use your information in this way, please see Choices about How We Use and Disclose Your Information.

Our legal bases for processing your information include:

• your consent;
• exercising our rights and performing our obligations in connection with entering into or performing under any contract we make with you;
• compliance with our legal obligations;
• our legitimate interests that are not overridden by your interests or your fundamental rights and freedoms, like research and development, to market and promote our services, and to protect our legal rights and interests.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To operators of co-branded or white-page versions of this Website established for a third party, or some other referring business (e.g., a Marketing Affiliate, as defined in our Terms & Conditions of Use). By making a purchase or reservation through this Website, or otherwise with your consent, in any case in accordance with applicable law, you are authorizing us to disclose your personal information to such parties, and agree that they may contact you for marketing purposes. Please note, however, these third parties are not controlled by us and any personal information shared with them is subject to the applicable third party's privacy policy. Therefore, we encourage you to review the privacy policies of any supplier whose products or services you purchase through this Website.
• Third-party product or service suppliers sold or advertised through this Website, such as hotels, car rental companies, travel providers, activity providers, entertainment providers, producers, and box offices. By making a purchase or reservation through this Website, or otherwise with your consent, in any case in accordance with applicable law, you are authorizing us to disclose your personal information to such parties, and agree that they may contact you for marketing purposes.  Please note, however, these suppliers are not controlled by us and that any personal information shared with them is subject to the applicable supplier's privacy policy. Therefore, we encourage you to review the privacy policies of any supplier whose products or services you purchase through this Website.
• To contractors, service providers, and other third parties we use to support our business, including advertising networks, content sharing platforms, courier services, customer service support providers, data analytics providers, data connectivity platforms, data management platforms, fraud prevention providers, marketing providers, payment processors (including PayPal, which operates as an independent Controller for the purpose of processing customer data; for more information, please visit the PayPal privacy statement available at: www.paypal.com), social networks (including links to our LinkedIn page), technology providers, and video management and sharing platforms (including YouTube- for more information about YouTube's collection of information, see Google's privacy policy at: http://www.google.com/policies/privacy).
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Working Advantage's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Working Advantage about our Website users is among the assets transferred.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms & Conditions of Use and Terms & Conditions of Sale. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Working Advantage, our customers, or others.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. Working Advantage does not respond to Do-Not-Track signals at this time; however, we have created mechanisms to provide you with the following control over your information:

• Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Website may then be inaccessible or not function properly.
  
  Google Analytics collects personal data through the Website, including through the use of cookies. For information about how Google Analytics collects and processes data, please visit: https://policies.google.com/technologies/partner-sites. To opt out of having your information used by Google Analytics, please visit: https://tools.google.com/dlpage/gaoptout/. For more information, please visit Google's privacy policy at: https://policies.google.com/privacy?hl=en&fg=1.
  
  Additionally, third parties, including Google, may place and read cookies on your browser, or use web beacons to collect information in connection with ad serving on or through the Website. Our partners will collect personal information for personalization of ads and use cookies for personalized and non-personalized advertising and measurement. Ad serving may be based on users' visits to our Website or other websites on the Internet, and your activity may be tracked over time and across websites. For information about how Google collects, shares, and uses data, please visit: https://policies.google.com/technologies/partner-sites. You may opt out of personalized ads from Google by visiting the Google Ads Settings web page at: http://www.google.com/ads/preferences/. For more information, please visit Google's privacy policy at: https://policies.google.com/privacy?hl=en&fg=1.
  
  We may also share information with Oracle, which provides AddThis, a content sharing platform. Oracle and Oracle partners may set a cookie and track your use of the Website, including allowing Oracle partners to incorporate cookies and pixels to enable the synchronization of internal unique identifiers between Oracle and its third-party partners to facilitate online behavioral advertising. Oracle, Oracle Partners, and customers may further use information collected through our Website to enable AddThis Tools functionality, to enable AddThis Publishers and Oracle Marketing & Data Cloud customers and partners to market products and services to you, to provide personalized recommendations and messages, to link browsers and apps across devices,  to sync unique identifiers, to analyze, develop, and improve the AddThis Tools and Oracle products and services, to manage the security of Oracle sites, networks, and systems, and to comply with applicable laws and regulations and to operate Oracle's business. For more information about how Oracle, its partners, and customers may use the information collected through our Website, please visit Oracle's privacy policy, available at: https://www.oracle.com/legal/privacy/addthis-privacy-policy.html.
  
  The Website also uses Mouseflow, a third-party analytics tool, to track page content and click/touch, movement, scroll, and keystroke activity. You can opt out at: https://mouseflow.com/opt-out/.
• Promotional Offers from Working Advantage. If you do not wish to have your information used by Working Advantage to promote our own or third parties' products or services, you can opt-out by contacting us here. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions or click "unsubscribe" in the relevant communication. This opt out does not apply to information provided to Working Advantage as a result of a product purchase, warranty registration, product service experience, or other transactions.
• Targeted Advertising. We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads (including ads served using non-cookie technologies) from members of the NAI on the NAI's website, available at: https://optout.networkadvertising.org/?c=1. You can also visit the Digital Advertising Alliance's website, available at https://youradchoices.com/, to use its Consumer Choice Tools. Users in the European Union ("EU") and United Kingdom ("UK") can visit the European Digital Advertising Alliance opt-out page, located at youronlinechoices.com.
  
  We use the Facebook Pixel to analyze user activity on our Website for remarketing and behavioral targeting. The Facebook Pixel is triggered when you perform certain activities on the Website, and aids us in displaying Facebook ads to Facebooks users who have visited our Website, or Facebook users who share certain characteristics with visitors to our Website. Facebook and other third parties may use cookies, web beacons, and other storage technologies to collect information from the Website and from other Internet websites, and use that information for the purposes of targeting ads and providing measurement services. 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/explanation. For specific information about Facebook Pixel, please visit: https://www.facebook.com/business/help/742478679120153?id=1205376682832142. For more information about ad targeting and exercising your choice to opt out of the collection and use of information for ad targeting, please visit: https://www.facebook.com/help/568137493302217, or http://optout.aboutads.info/?c=2&lang=EN.
  
  We also use Zeta Global for the purposes of advertising in connection with the Website. You can refuse or opt out of Zeta DSP digital advertising technologies that include advertising tags (such as pixels, clear GIFs and similar methods), cookies, device identifiers or other identifiers and similar technologies at any time by visiting Zeta's opt-out page, available via the Zeta DSP Privacy Policy at: https://zetaglobal.com/privacy-policy/.
  
  We further use Sizmek Ad Suite for the purposes of advertising in connection with the Website. You can refuse or opt out of Sizmek digital advertising technologies that include advertising tags (such as pixels, clear GIFs and similar methods), cookies, device identifiers or other identifiers and similar technologies at any time by visiting Sizmek's opt-out page, available at https://www.sizmek.com/.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request here. However, please know we do not currently sell data triggering that statute's opt-out requirements.

Accessing and Correcting Your Information

You may log in to your account or contact us here to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Your California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us here, or write us at: Attn: Privacy and Compliance, Legal Department, 19495 Biscayne Boulevard, Suite 300 Aventura, FL 33180

International Data Transfers

When you use the Website and provide information through the Website, we may transfer your information to a destination outside your jurisdiction, including to the United States. The United States has not received a finding of "adequacy" from the EU under Article 45 of the GDPR (or other analogous international data protection regulations, such as the UK GDPR). Working Advantage relies on the safeguards set forth in Article 46 of the GDPR or derogations for specific situations set forth in Article 49 of the GDPR (or other analogous data transfer mechanisms) in order to transfer personal information across international borders.

Individuals in the European Economic Area ("EEA") and the UK may request a copy of applicable Article 46 agreements by contacting us at: Attn: Privacy and Compliance, Legal Department, 19495 Biscayne Boulevard, Suite 300 Aventura, FL 33180.

Your Rights

To the extent required by law, Working Advantage provides you with:

• reasonable access to the personal information collected through the Website;
• the ability to review, correct, export, and delete such personal information; and
• the ability to restrict processing of your personal information, or object to its processing.

When the processing of your personal information is based on your consent, you have the right to withdraw your consent at any time, but this will not affect any processing we have already performed. If you withdraw your consent, refuse to provide certain information, or provide inaccurate information, you may not be able to access or utilize all of the features or content available on or through the Website, and we may not be able to fulfill your requests for products or information.

Please contact us using any of the methods identified in the Contact Information section if you would like to exercise your individual rights. We may need to obtain or confirm certain personal information in order to accommodate your request. We will not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Individuals in the EEA and UK: In addition to the above rights, you also have the right to lodge a complaint with a supervisory authority (EEA) or the Commissioner (UK) if you believe we have processed your personal information in a manner inconsistent with your privacy rights. We kindly request that you contact us first so that we may address your concern.

Data Security and Retention

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

We retain your information for as long as needed: (i) to conduct business with you; (ii) as needed for the purposes outlined in this Privacy Policy; and (iii) as necessary to comply with our legal obligations, resolve disputes, and enforce any agreements.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users' personal information, we will notify you in accordance with applicable law. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

Working Advantage
Attn: Privacy and Compliance, Legal Department
19495 Biscayne Boulevard, Suite 300
Aventura, FL 33180

Or you may contact us here.

CCPA Privacy Notice

The following disclosures are made pursuant to the CCPA. These disclosures supplement any privacy notices we previously or contemporaneously provided to you. The below charts reflect the categories of personal information we have collected from California consumers over the past twelve months, the categories of sources from which the information was collected, the business purpose for which the information was collected, and the categories of third parties with whom we shared that information.

In the past twelve months, we have disclosed personal information to third parties for business purposes. The categories of personal information we have disclosed to third parties for business purposes are identified in the "Categories of Personal Information Collected" columns above. We have disclosed those categories of personal information to the categories of third parties identified in the "Categories of Third Parties Receiving Personal Information" columns above.

Right to Opt Out of Sale

In the past twelve months, we have shared the following categories of information with activity providers, advertising networks, affiliates, box offices, car rental companies, data analytics providers, data connectivity platforms, data management platforms, entertainment providers, hotels, marketing providers, operators of co-branded and white page versions of the Website, producers, social networks, travel providers, and video hosting and sharing platforms, which could be considered a "sale" under California law:

Personal identifiers, characteristics of protected classifications under California or federal law, commercial information, Internet and other electronic network activity information, geolocation data, and inferences drawn from any of the information identified above to create a profile about you.

While we do not sell personal information in exchange for any monetary consideration, we do share personal information for other benefits that could be deemed a "sale," as defined by the CCPA. The CCPA broadly defines "sale" in a way that may include actives such as the delivery of targeted advertising on websites or allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior.

If you are a California resident and would like to opt out of our use of your information for such purposes (to the extent this is considered a sale), you may submit a request by calling 888-217-9565 or by completing our webform, available here.

An authorized agent can submit a request to opt out on your behalf if you provide the authorized agent your signed written permission to do so

We have no actual knowledge of selling the personal information of minors under 16 years of age.

Right to Know

California residents have the right to request that we disclose the categories and specific pieces of personal information we collected, used, disclosed, and sold during the past twelve months, the categories of sources from which their personal information was collected, our business or commercial purposes for collecting their personal information, and the categories of third parties with whom we shared their personal information. California residents or their authorized agents may submit a request by calling 888-217-9565 or by completing our webform, available here. In order to process your request, we will need to verify your identity and residency by matching certain personal information you provide with information we have on file, including your first name, last name, email address, telephone number, and address. The personal information that we use to verify your identity and residency will not be used for any other purpose.

Right to Delete

California residents have the right to request deletion of the personal information we have collected from them. California residents or their authorized agents may submit a request by calling 888-217-9565 or by completing our webform, available here. In order to process your request, we will need to verify your identity and residency by matching certain personal information you provide with information we have on file, including your first name, last name, email address, telephone number, and address. The personal information that we use to verify your identity and residency will not be used for any other purpose.

Non-Discrimination

California residents have the right to not receive discriminatory treatment by exercising CCPA privacy rights. We do not discriminate against California residents who exercise their CCPA privacy rights.

Questions?

Please complete our webform, available here.