Effective Date: June 30, 2019
Information We Collect and How We Collect It
We collect contact information you voluntarily provide through our Application Service. As part of our core offering, we also collect, store, and analyze your transaction history.
We ask for your login information to the official EBT balance checking portal. The Application Services pull data from that portal in order to render services for you. We do not store your actual login information or your EBT card number on our servers. Instead, we use the login to create a unique (hashed) user ID to manage your Fresh EBT account.
If you allow this during the download or management on your smartphone of the Application Service, we will collect your location information so we can provide a more relevant experience tailored to your location.
We collect and store your Internet Protocol Address, MAC address, and Device ID. We may collect and store your email address if you choose to receive emails from Fresh EBT or if you participate in our referral program and redeem your rewards, your phone number if you choose to provide it to get updates about Fresh EBT, and the year that you were born if you provide it while creating your Fresh EBT account.
Data is also stored locally on the device you use to access the Application Service that contains information about your EBT account, your activities on the Application Service or allows the Application Service to remember information about you and your activities. You can control what is stored locally on your phone through the Settings on your device.
What We Do With Your Information
We use your information:
- to provide your account information, including balance and transaction history
- if you allow this during the download or management on your smartphone of the Application Service, to send you push notifications
- to promote goods and services that may be of interest to you, as inferred from your general location or transaction history
- to visualize your transaction history
- to operate features of the application
We do not store your EBT account login information, such as user ID, password, card number, or PIN, on our servers. This information remains on your own device. We are not responsible for anything that happens to data stored on your device.
Any contact information you voluntarily provide is never sold to third parties. We will only contact you or use your contact information for specific uses that you authorize (for example, to cash out rewards earned through the Referrals program or receive marketing emails from Fresh EBT). If you do opt in to receiving marketing email, you may choose to stop receiving emails by following the unsubscribe instructions included in these emails. If you provide your phone number to receive updates about Fresh EBT, standard text message rates apply. You can stop receiving text messages from Fresh EBT by replying ‘STOP’ to any text message. You may also request to have your contact information removed from our system at any time by emailing email@example.com.
Information about your use of your EBT account or our Application Service may be aggregated or otherwise de-identified for business and marketing uses by us or by third parties. For example, aggregate or de-identified data may be used to improve our services, measure and analyze the use of services and to help make services and advertising more relevant to you.
Google Analytics is a web analysis service provided by Google. Google utilizes the data collected to track and examine usage of the Application Service and the www.freshebt.com website, to prepare reports on activities and to analyze and improve the Application Service based on how it is used.
For the Application Service, anonymous user statistics are also collected using Google’s Firebase Analytics. The data collected cannot be used to identify individual users, and is used to gather statistics on how the platform and app is used in order to obtain feedback on how to improve the app. Users can opt-out of mobile analytics by disabling Ad Tracking on their device. See the Firebase Analytics terms for more information: https://firebase.google.com/terms/analytics
Special Notice on Account Creation
To protect your privacy, Fresh EBT does not collect any personally identifiable information that is not required to operate the service. Consequently, for users who live in certain states, Fresh EBT automatically generates some anonymous information to create an account for you in the ebtEDGE system. Specifically, Fresh EBT may automatically generates the following information:
- Phone number
- First name
- Last name
- Three (3) security questions
- Answers to those security questions
You may create a new account at any time directly in the ebtEDGE portal using a new User ID if you want to change any of this account information.
Special Notice for Coupons Feature
Special Notice for Foodtown Customers
Fresh EBT has a unique relationship with Foodtown, via the Foodtown customer loyalty program. If you have specially enrolled in the Foodtown customer loyalty program, you can choose to link your “Club Card” to your Fresh EBT account. If you do this, you may receive promotions, offers, and rewards tailored to your Foodtown shopping activities. We share summary information about the effectiveness and reach of the customer loyalty program with Foodtown.
Sharing Your Information as Permitted by Law
We may share your information with others as required by law. We may also share your information with others as permitted by law. This may include sharing your information with government entities or third-parties in response to subpoenas, court orders, and other legal process. We may also share your information if we believe it is necessary to exercise our legal rights, to defend against legal claims that have been brought against us, or to defend against possible legal claims that we determine might be brought against us.
As we continue to develop our business, we may buy, merge or partner with other companies. If a portion or all of Propel’s assets are sold or transferred to a third-party, customer information (including your email address and phone number) would likely be one of the transferred business assets.
How We Secure Personal Information
We take reasonable and appropriate measures to help keep information secure and to help prevent it from becoming disclosed to individuals who are not described in this policy. Even though we follow reasonable procedures to try to protect the information in our possession, no security system is perfect, and we cannot promise, and you should not expect, that your information will be secure in all circumstances.
How You Can Contact Us
Special notice for Survey respondents
To improve our application services, we will occasionally post links to external surveys inside of Fresh EBT. These surveys are entirely optional. We use data collected in these surveys to inform decisions about the application, our business, and our partnerships. When you complete a survey, you consent to sharing your responses with us, including any personal information you choose to share. The surveys are hosted by third-parties, and when you complete a survey, you are also agreeing to share your survey responses with these third parties, and are also subject to their privacy policies. We never share any individual survey results outside of Propel. Occasionally we may share aggregated or summary results with our partners and other third-parties.
We do not provide products and services to children. We do not knowingly collect or solicit information from children under the age of 13. If you are a parent or guardian of a child under the age of thirteen (13) and believe he or she has disclosed personally identifiable information to us, please contact us at firstname.lastname@example.org.
A parent or guardian of a child under the age of thirteen (13) may review and request deletion of a child’s personally identifiable information as well as prohibit the use thereof. If we become aware that a child under 13 has provided us with personal information, we take steps to remove that information and terminate the child’s account.
Special Notice for Participants in the Beta Testing Program:
If you agree to participate in the Beta Testing Program, you provide us your account information so that we can test features and improve the app. The information you provide is used only for testing purposes by Propel; it is never shared with third parties. We take reasonable and appropriate measures to store your information in a secure manner. If you no longer wish to participate in our Beta Testing Program, please contact us at email@example.com.
If you have any questions about this Privacy Statement or any other issue with our Application Services, you may contact us at: firstname.lastname@example.org