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Privacy Policy
Effective September 1, 2011:

Summary of the SmartSource Privacy Policy:

  1. INTRODUCTION – The Introduction identifies the basic SmartSource Services covered by this Privacy Policy and provides a brief overview of what the Policy covers. 
  2. SUBMISSION AND COLLECTION OF INFORMATION - This section addresses the types of information that SmartSource collects directly from users and the collection of non-personally identifiable information via cookies and related technologies by SmartSource and third parties.
  3. NOTICE AND CHOICE - This section provides information on users’ options to control how their information is collected and used, how SmartSource notifies users about future Policy changes, where SmartSource stores data, and third-party web sites that may link to the SmartSource Services.
  4. USE AND DISCLOSURE - This section describes how SmartSource uses your information to provide and manage the SmartSource Services, including when SmartSource may disclose your information to third parties that assist SmartSource in providing those services.  
  5. SECURITY - This section describes SmartSource’s security measures. 
  6. USER CONTROL AND ACCOUNT CANCELATION - This section informs users how to access and change their personal information stored by SmartSource, and how to stop receiving emails from SmartSource.
  7. CONTACT US - This section instructs users how to contact SmartSource.



News America Marketing Interactive L.L.C. and, in Canada, News Marketing Canada Corp. (collectively, “SmartSource” or “we”) operates www.smartsource.com, www.smartsource.ca, the SmartSource branded applications and microsites hosted by SmartSource that are linked from business partner websites (collectively, the “SmartSource Site”).  The SmartSource Site allows users to obtain coupons and free product samples from SmartSource and its product partners, to enter contests, sweepstakes and promotions, and to enjoy any other features, content, or applications offered from time to time by SmartSource in connection with SmartSource’s business, including when the SmartSource Site is accessed via the Internet, mobile, applications or other methods(collectively, the “SmartSource Services”).  SmartSource is based in the United States and the SmartSource Services are hosted in the United States.  SmartSource is part of the United States based operations of News Corporation.  

As set forth in our Terms of Use, the SmartSource Site is a general audience site, is not targeted to children, and does not knowingly collect personal information from children under 13 years of age. 

This Privacy Policy applies to all “users” of the SmartSource Services, including users who visit our website without obtaining any coupons or samples, or participating in a contest or sweepstakes.  The Policy describes SmartSource’s collection and use of users’ personal information (e.g., information that identifies a specific person, such as full name or email address).  It also describes generally SmartSource’s practices for handling non-personally identifiable information (e.g., site usage, browser type) to the extent such information is associated with a particular user.



User Submitted Information

Users submit information to SmartSource in order to take advantage of the following SmartSource Services:

Targeted Coupons.  Users are given the option of submitting their zip/postal code to SmartSource in order to receive coupons and offers that are targeted to the area in which they live.

 Direct To Card (D2C) Coupons.  Users who want to download coupon offers directly to their frequent shopper cards or other indicia, must provide their frequent shopper card numbers or other unique identifier. 

 New Coupon Alerts.  Users who want to be notified via email about SmartSource Services available on the SmartSource Site must provide SmartSource with their email address, zip/postal code and gender (so that relevant offers may be sent).

 Free Samples.  Users who want to receive free samples through SmartSource from a Product Partner (the company that supplies the product or service) must provide their names and mailing addresses to SmartSource so that their request can be fulfilled. 

 Sweepstakes, Contests and Promotions.  Users who enter contests, sweepstakes or promotions must provide their full name, mailing address and email address to SmartSource.

 Partner Services.   Users who want to obtain SmartSource coupons or offers through a Product Partner website, or who want to receive product information, newsletters or promotional material from a Product Partner, must provide their personal information (e.g., email and/or mailing address) to SmartSource and/or the Product Partner so that their request can be fulfilled.   When personal information is provided to a Product Partner it is subject to the Product Partner’s privacy policy which should be reviewed by the user.


Collected Information

 Activity Information. When users visit the SmartSource Site, we may collect certain non-personally identifiable information about those visits.  For example, in order to permit your connection to the SmartSource Services, our servers receive and record information about your computer and browser, including potentially your IP address, browser type, other software or hardware information.  If you access the SmartSource Services from a mobile or other device, we may also collect transactional information such as a unique device identifier assigned to that device (i.e., a UDID) or other information about the device, including your location if you enable your device to send us location information.  This information, along with information about the date and time on which a coupon is printed, is also used to help us prevent the fraudulent use of SmartSource coupons.  We also may use cookies and other tracking technologies (including browser cookies, pixels, beacons, and Adobe Flash technology including cookies), which are small bits of data that often include an anonymous unique identifier.  Web sites send this data to your browser when you first request a web page and then store the data on your computer so the web site can access information when you make subsequent requests for pages from that site.  We may use these technologies to collect and store information about your usage of the SmartSource Services, such as pages you have visited and advertisements you have seen. If SmartSource wishes to combine your personal information with information we obtain through these technologies in order to determine what messages SmartSource provides to you, we will obtain your express affirmative consent.

 Third-parties that support the SmartSource Services by, for example, serving advertisements or providing services, such as tracking aggregate site usage statistics, may also use these technologies to collect similar information.  SmartSource does not control these third-party technologies and their use is governed by the privacy policies of third parties using such technologies.  For more information about third party ad networks that use these technologies, see www.aboutads.info/consumers

 Most browsers are initially set to accept cookies, but you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether.  Please consult the "Help" section of your browser for more information (e.g., http://windows.microsoft.com/en-US/windows-vista/Block-or-allow-cookies).  Users can manage the use of Flash technologies including cookies with the Flash management tools available at Adobe’s website, see http://www.adobe.com/products/flashplayer/security/privacy_policy/faq.html.  Please note that by blocking any or all cookies you may not have access to certain features or personalization available through SmartSource Services.

Third Parties.  To improve the quality of SmartSource Services, we may supplement the information we collect with information from third parties. If you access SmartSource through a third-party connection or log-in, we may also collect your public user ID associated with that third-party service, and any information you may have made public in connection with that service and that the third party shares with partner services.



Means of Notice and Choice.  This Privacy Policy is the primary means by which SmartSource provides you with notice about its collection and use of your personal information.   SmartSource will not use your personal information in a manner different from what is described in this Privacy Policy without your permission.  Your use of this site or the SmartSource Services or submission of personal information constitutes your consent to SmartSource’s collection, use and disclosure of your personal information as described in this Privacy Policy.

Privacy Policy Changes.  SmartSource may modify this Privacy Policy as necessary.  If we make material changes to this Privacy Policy that expand our rights to use your personal information, we will notify you to seek your consent through email or a prominent posting on the site.

 Storage and Processing of Data.  The SmartSource Services are hosted on servers located in the United States.  If you are a user located outside the United States, you understand and consent to having any personal information you provide transferred to and processed and stored in the United States and other countries where data protection and other privacy laws may not offer the same level of protection as those in your jurisdiction, such as the European Union.  This includes the use of cookies, and other tracking technologies as described above.    As a result, please read this Privacy Policy with care.

Linked Websites and Partner Services.  The SmartSource Services may also be linked to sites operated by SmartSource affiliates (i.e., that are part of the News America Group: “Affiliated Companies”) or third parties (including third-party web sites that may be co-branded with a SmartSource logo), and may carry advertisements or applications developed and maintained by third parties.  As noted above, personal information is sometimes collected by Product Partners in connection with the SmartSource Services. SmartSource is not responsible for the privacy practices of any such third parties or Product Partners, and once you leave SmartSource Services via a link, enable a third party application, click an advertisement, or submit your personal information to a Product Partner, you should check the applicable privacy policy of the third-party site or Product Partner.  Additionally, although all Affiliated Companies adhere to the News Corporation corporate Privacy Principles, users who visit an Affiliated Company site should still refer to its separate privacy policy, which may differ in some respects from this Privacy Policy. 



We only share your personal information with non-affiliated third parties when we have your consent or as authorized by this Privacy Policy.  SmartSource may share your personal information with Affiliated Companies in order to fulfill our reasonable business needs or legal obligations.

We use the information you provide us for the following purposes:

To provide and manage the SmartSource Services.  We use the information we collect from and about users to provide the SmartSource Services and SmartSource Site features to you, including to measure and improve those services and features, to personalize your experience by delivering relevant content, advertising and marketing messages, to provide you with customer support, and to respond to inquiries.  We may use aggregated, anonymous data about use of and activity on the SmartSource Site to assist us in this regard and such data is not subject to this Privacy Policy.  

The information that users submit to the SmartSource Site in order to obtain Free Samples, to enter Sweepstakes, Contests or Promotions or to obtain coupons or products from a Product Partner is transferred to the Product Partner who will fulfill the user’s request or, in the case of Sweepstakes, Contests or Promotions, to our sweepstakes administrator, sweepstakes partner and/or prize sponsor.  

To allow third-party service providers to assist us in providing and managing the SmartSource Services.  SmartSource may make your personal information available to certain third-party service providers, such as contractors, agents or sponsors, who help us manage or provide the SmartSource Services.  These outside service providers are required to protect personal information entrusted to them and not use it for any other purpose than the specific service they are providing to SmartSource. 

To deliver relevant advertising.  We may use the information you provide to us, and information we collect about your use of the SmartSource Services through cookies and other technologies, to assist us in delivering you relevant ads when you visit the SmartSource Services.  We may work with third-party advertising networks and advertisers who help deliver these ads to you.  We do not share your personal information with these third parties, but we may share anonymized or aggregated information with them to improve the relevancy of the ads you see on the SmartSource Services. As noted above, these third-party advertising networks and advertisers may also use cookies and similar technologies to collect and track non-personally identifiable information such as demographic information, aggregated information, and Internet activity to assist them in delivering advertising that is more relevant to your interests.  To find out more about third-party online advertising and to opt out of this type of advertising, visit the Network Advertising Initiative website at http://www.networkadvertising.org/managing/opt_out.asp.   

To contact you.  SmartSource may send promotional materials or notifications to the email address you provided to us when you registered for New Coupon Alerts.  If you want to stop receiving promotional materials from SmartSource, follow the unsubscribe instructions at the bottom of each email.  There are certain service notification emails that you may not opt-out of, such as notifications of changes to the SmartSource Services or policies. 

To protect the rights of SmartSource and our users and comply with legal obligations.  There may be instances when SmartSource may disclose user information without providing notice or choice, including situations where SmartSource has a good faith belief that such disclosure is necessary in order to: (i) protect or defend the legal rights or property of SmartSource, our Affiliated Companies or their employees, agents and contractors (including enforcement of our agreements); (ii) protect the safety and security of users of the SmartSource Services or members of the public; (iii) protect against fraud or for risk management purposes; or (iv) comply with the law or legal process. 

To complete a merger or sale of assets.  If SmartSource sells all or part of its business or makes a sale or transfer of its assets or is otherwise involved in a merger or transfer of all or a material part of its business, SmartSource may transfer your information to the party or parties involved in the transaction as part of that transaction.


5.      SECURITY

SmartSource uses commercially reasonable administrative, technical, personnel and physical measures to safeguard user information in its possession against loss, theft and unauthorized use, disclosure or modification.



Upon request, and unless prohibited by law, we shall inform users of the existence, use and disclosure of their personal information and provide access to that information.  We will take reasonable steps to correct any personal information a user informs us is incorrect or incomplete as appropriate.  If you want to change the personal information maintained by SmartSource, please contact us at webmaster@smartsource.com.

If want to stop receiving emails from SmartSource, please use the “unsubscribe” link at the bottom of the email you receive.  Remember that even after SmartSource stops using your personal information, we may also retain backup information on our servers for some time for fraud detection or to comply with applicable law or our internal security policies.   SmartSource cannot control the continued use of your personal information by Product Partners, sweepstakes partners and/or prize sponsors.


7.      CONTACT US
If you have questions about this Privacy Policy, please contact SmartSource at:

Email: webmaster@smartsource.com

Mail: News America Marketing Interactive L.L.C.
1211 Avenue of the Americas
13th Floor
New York, New York 10036