Privacy Policy


  1. Introduction
  2. Information We Collect
  3. How and Why We May Use Your Information
  4. How We May Share Your Information
  5. How We Protect Your Information
  6. Data Retention
  7. Rights and Choices You Have with regard to Your Information
  8. How We Use Tracking Technologies
  9. International Visitors
  10. Information Collection from Children
  11. Your California Privacy Rights
  12. Changes to Our Privacy Policy
  13. Contact Us
  1. Introduction.Insticator Inc. and its affiliates (collectively, “Insticator”, “we”, “our” or “us”) wants you to be familiar with how we “process” (i.e., collect, store, use and disclose) information from and about you. This Privacy Policy only applies to the information processed by Insticator or any third parties acting with our authorization or otherwise provided to us by third parties about you, in each instance, in connection with your (a) interaction with our products and services, including the Widget, (b) use of and all corresponding domains, subdomains, web pages and websites associated therewith (the “Sites”) and, (c) use of our mobile, web, tablet, desktop and other applications, including applications made available through Facebook, iOS and Android (the “App(s)”), and (d) use of any other content, applications, features, functionality, information and services offered by us, whether through our Apps, the Sites or otherwise (each of the above individually and collectively referred to herein as the “Services”), and it applies to all individuals, including clients or users of Insticator, who use our products and services (whether offline or online), whether you are accessing and/or using the Services as a registered User or otherwise. This Privacy Policy applies regardless of the Device you use to access the Services. Please review our Terms of Service which governs your use of the Services. Any capitalized terms that are not defined in this Privacy Policy shall have the meaning ascribed in the Terms of Service. This Privacy Policy will remain in full force and effect, even if your use of the Services or any particular feature or activity offered in connection therewith terminates, expires or is deactivated or suspended for any reason. We will either rely on our legitimate interest or our need to perform under a contract to process your information or you will be asked to affirmatively consent to our processing of your information, all in accordance with the terms and conditions of this Privacy Policy. If you do not agree with this Privacy Policy, please do not access and/or use the Services or any features, activities, products or services offered through or in connection therewith.
  2. Information We Collect.We process personal data or other information about you when you interact with any of our properties or facilities, visit our Sites or otherwise use our Services. The information we may process depends upon your interaction with us. The types of personal data that we may process include the following:
    • Registration Information: In order to access and use certain features, portals, content or functions of the Services (e.g., monitoring marketing analytics, viewing Redemption Point status, creating surveys and viewing results, etc.), you may need to register for a User Account and provide or make available (e.g., via third party services) to us certain information. When you create a User Account, we will collect personal data as necessary to offer and fulfill the Services you request. Depending on the Services you elect to use, we may ask you to provide your name, email address, mailing address, date of birth, IP address, device identifier, residency information, tax id number and tax information, bank account information and profession or ask that you link your social media account (e.g., Facebook, Twitter, etc.) with our Services. If you choose not to provide some of this information, you may not be able to use all of the features of the Services.
    • Redemption Points Information: If you access or use certain features, portals, content or functions of the Services, including the Widget and accumulate Redemption Points, you may need to provide us with certain information in order for you to use or redeem the Redemption Points. This information includes your name, email address, mailing address, profession and date of birth.
    • Fee-Based Services Information: If you engage in any Fee-Based Services or other transaction offered on or in connection with the Services, we and/or our third party payment processors may require certain payment information (e.g., credit or debit card number, card type, expiration date and address associated with such credit or debit card) and additional information (e.g. your full name, physical address, employee or employer details, telephone number(s)) to fulfill the applicable services or deliver the applicable products. If you are using Redemption Points to make certain purchases, including in-game purchases, we may require you to provide us with your name, email address, mailing address and profession.
    • Location Information: With your permission, we may process the specific geographic location of your Device (e.g., by accessing your Device’s GPS and/or using your mobile device ID) via our Sites or Apps to provide you with personalized content within the Services. If you no longer wish to have this location information processed, you can withdraw your consent at any time by disabling the location and/or Bluetooth features in the operating system of your Device and/or in the App. If you have any questions about disabling you location and/or Bluetooth features, you can contact us at priva[email protected].
    • Personal Data You Choose to Provide for Marketing or Additional Services: We may process personal data that you choose to provide to us when you elect to participate in optional Site-features or Services. For example, if you sign up to receive newsletters, marketing emails, promotions or other communications regarding the Services and/or promotions, from us or our preferred third-party products or services providers, or participate in contests, surveys, questionnaires, games and other promotions related to the Services (including the Widget), we may process your name, email address, mailing address, interests, IP address, device identifier, search history, profession and date of birth in order to provide the additional features or Services.
    • Comments, Feedback, Customer Service and Other Inquires: You have the ability to use the Services to contact us with questions you may have and provide us with comments and or feedback about the Services (e.g., completing a “Contact Us” form on our Sites or surveys relating to our Services) or to communicate with other users of the Services and post comments to or otherwise interact with certain aspects of the Services that are available to the public and/or other users. We will process any information you submit, post or provide in the course of such activities to respond to your comments or feedback. In the event you contact us, we may process information related to conversations, including recording or monitoring customer service calls for quality assurance and training purposes, and to verify your identity.
    • Third Party Platform Information: If you access the Services by logging in using your account credentials from a third-party owned or operated platform/service (e.g., Apple (iTunes, etc.), Facebook, Twitter, LinkedIn, etc.) (each, a “Third Party Platform”), post content from our Sites, the Widget or Apps to a social network, or use various social media features (e.g., “Like” button), we may process certain information from the Third Party Platform, such as your username, “likes”, location, birthday, comments and reviews, direct messages you may send to us, interests, photos, friends, status updates and other information you provided to the Third Party Platform in connection with your account. Depending on your account and privacy settings, we may also be able to see information that you post when using these Third Party Platforms whether or not you are using our Services. The information you post or provide to Third Party Platforms, as well as the controls surrounding these disclosures are governed by the respective policies of these third parties.
    • Information Collected by Tracking Technologies: As further described in Section 8 of this Privacy Policy and Cookie Policy, when you use the Services and/or third parties may use “cookies” (which are small data files containing information about you that is stored on your device), “embedded scripts”, and other similar tracking technologies (collectively, “Tracking Technologies”) to collect additional information automatically as you interact with the Services. Information collected and processed by our Tracking Technologies will be processed in accordance with our Cookie Policy located here.
    • Advertising Data: We may also use the services of trusted third parties, including advertising networks, social media networks, data exchanges, traffic measurement service providers and marketing analytics service providers to, for example, serve you advertisements on the Services or while using other websites, populate user-specific advertisements and/or measure and analyze advertising effectiveness and/or traffic on or in connection with the Services (“Third Party Advertising Providers”). Third Party Advertising Providers enable us to provide you with more useful advertisements about our Services or the services of third parties which are tailored specifically to your interests or to individuals with similar characteristics to our customers and users, including by using tools like Google’s “Customer Match” or Facebook “Custom Audiences”. These tools combine information you have provided to us through your use of our Services with other data processed about you through third party sites, permitting you to view personalized advertisements about Insticator or our third party partners on other websites you browse or when you are searching for similar products or services. Additionally, we may use platform tools like Facebook’s “Lookalike Audiences” to share information you have provided us with social media sites to create “lookalike audiences” (i.e., users with similar characteristics to our customers or like-minded consumers) and provide such users with tailored advertisements about Insticator or our third party partners. When we use these tools, you can withdraw your consent to this use of your personal data at any time by emailing us at [email protected] . Third Party Advertising Providers may use their own cookies and other tracking technologies. Insticator does not control these Third Party Advertising Providers and/or their use of cookies, which is instead governed by the privacy policies and/or cookie policies of any such Third Party Advertising Provider.
    • Browsing Information, Logs, Usage Data and Other Device Information: When you visit our Sites and use our Widget, we may process information about your activities on third party websites and our Sites and Widget through the use of Tracking Technologies, as further explained in Sections 8 below and our Cookie Policy. Providing this information is not mandatory and cookies can be disabled by visiting or Cookie Management Tool located here . However, please note that our Sites and Widget may not offer the same functionalities when certain cookies are disabled.
  3. How and Why We May Use Your InformationWe may process your personal data (depending on your interaction with us) for any reason that is permitted under data protection laws in accordance with this Privacy Policy, which may include the purposes below. Note that the legal bases outlined below are required to be included under European Union (“EU”) data protection laws, but are not required to be included if you do not reside in the EU.
    • To fulfill our contractual obligations under an existing agreement with you to provide you with products and services you requested, or in anticipation of entering into such an agreement with you, including, without limitation:
      • To provide or fulfill any services, orders or products that you request or purchase in connection with the Services including for accounting, auditing or other internal functions, and to offer you an overview of your transactional history;
      • To enable you to collect, use and redeem Redemption Points;
      • To communicate with you about your account, transactions, applications and the Services;
      • To respond to requests for information and services, including services from a third party;
      • To manage, evaluate and administer your User Account, including sending you information about your account status and provide you with information and statics about your use of the Services;
      • To manage and administer your business accounts, including sending you transaction-related emails for such things as account verification, purchase and billing confirmation;
      • To enforce your legal rights under an agreement; and
      • To provide you with an estimate for our products or services.
    • To pursue our legitimate business interests, including, without limitation:
      • To provide you with a more personalized level of service, including information and services related to the products and services you purchase from us or that may be available from a trusted third party;
      • To manage our business needs, such as monitoring, analyzing, modifying and improving our Services’, including the Sites’, functionality and performance, including changes/updates to features of the Sites/Apps, technical and security notices;
      • For the security and safety of our users, clients, publishers, advertisers and visitors, and for purposes of fraud prevention, including preventing fraud and abuse on and unauthorized access to the Services and Sites;
      • To provide you with information about products and services you have purchased or indicated your interest in;
      • To determine which features and functionality of the Services users like best to help us operate, enhance and improve the Services, including by asking you to participate in a survey relating your use of the Services;
      • To provide you with information about how the Services work and interact with the services of our third party partners;
      • To respond to any customer service requests, such as resolving your problems or responding to your questions, managing any complaints or feedback you provide;
      • For statistical analysis of aggregated data to help us segment our offerings and develop our Services;
      • To better understand the way in which our Sites and Apps are working and offer you a better Site and/or App user experience, to create statistics in relation to the use of our Sites, Apps and our Services generally;
      • To help us diagnose technical issues and problems related to our Services;
      • To grow our business, including our products and services;
      • To get to know our potential and existing users, publishers, advertisers, clients, consumers, and users; and
      • To identify relevant content shared with potential and current users.
    • To comply with our regulatory and legal obligations or to enforce our legal rights, including, without limitation:
      • To meet reporting requirements (e.g., filing tax forms);
      • To retain documents and information related to a legal action;
      • To enforce the Terms of Service; and
      • To report data breaches or unauthorized access to the Services.
    • With your consent*, including, without limitation:
      • To provide location-specific functionality, features, services or offers;
      • To market to you by delivering marketing materials about Insticator’s and our third party partners’, products and services, as well as the products and services of unaffiliated third party businesses;
      • To display online advertising and marketing information based on your use of the Services, including interaction with the Widget, and other websites services and platforms that you have visited;
      • To provide you with tailored advertisements about Insticator or our third party partners on third party websites, we may provide your personal data to Third Party Advertising Providers that combine such data with information collected by third-parties to send you advertisements on our Sites and third party websites, about our exclusive offers, news and products or services tailored to you and your interests;
      • To provide personalized services offered by us or third party partners on third-party websites and online services;
      • To enable you to connect with others who use our Services; and
      • For other purposes for which you may grant consent.

      *You can withdraw your consent at any time by following the steps in Section 8 of this Privacy Policy.

  4. How We May Share Your InformationIn connection with our global operations, we may share information we collect from you or about you with some of our affiliates, publishers, third party partners and third party service providers as necessary to assist us in providing the Services to you, as set forth in more detail below:
    • Our Group Entities: We may disclose your personal data to our group entities that are affiliates and/or subsidiaries of Insticator in order to provide you with tailored products, services and communications.
    • Publishers, Clients and Third-Party Partners: We may disclose your personal data to publishers, clients and third party partners in connection with the Services, including with respect to your interaction with the Widget embedded in the websites of publishers, clients and third party partners, to share information about your interaction with the Widget and publishers’ websites, to provide you with Services you request and to enable a publisher or third party partner to provide you with information about their service and/or product offerings. Please note that if you visit a website operated by a publisher or third party partner, any personal data you provide through that website will be subject to the privacy policy of that third party and not to this Privacy Policy.
    • Service Providers: We may partner with other companies to help us operate certain aspects of our businesses, including the hosting of our Sites and Apps, operation of our technology infrastructure, processing of payments and redemption of Redemption Points, and fulfillment of certain services or products you request from us. We carefully select such third party operators, merchants, website hosts, service providers and participants to your transactions for the purpose of (1) assisting with facilitating transactions on or through the Services, (2) providing information technology and customer service assistance, and (3) providing, offering, supporting, administering, maintaining and enabling the Services (including providing a full range of content, services, features and functions offered on or in connection with the Services).
    • Advertising Providers: In order to provide you with marketing and exclusive offers, including emails and advertisements tailored to you and your interests on and off the Services, we may provide your information to Third Party Advertising Providers.
    • Co-Sponsors of Promotions: From time to time, we may co-sponsor promotions, sweepstakes, prize draws, competitions or contests with other companies. If you enter one of these sweepstakes or contests, we may share your information with the co-sponsor or third-party sponsor.
    • Corporate Transactions or Events: We may disclose your personal data in connection with a merger, sale of substantially all of our assets or stock, joint venture, transfer, corporate reorganization or other disposition of our business.
    • Pursuant to Law, Rule or Regulation: We may share or disclose your information with other parties as we deem necessary or appropriate under applicable law, rule or regulation. Examples of these purposes include: to respond to requests from public, governmental and regulatory authorities, to comply with court orders, to obtain legal remedies or limit our damages, to enforce this Privacy Policy or the Terms of Use, and to protect the rights, safety and/or property of you, our employees or others.
    • To Fulfill Your Requests: If you elect to use certain authentication or sharing features available on the Sites or via the Services, we may use your personal data to fulfill your request to share content with or provide access to such third parties (e.g. Facebook, LinkedIn, or Twitter).
    • TAdditional Non-Personal Information: We may share aggregated and anonymized data, meaning data that cannot identify you personally (i.e., non-personal information), that we collect through your interaction with the Services. We may share this information with our publishers, clients and third party partners in order to improve the Services and their services and to better understand your interaction with the Widget, the Services and their products and services.

    With regard to our third party service providers, we only provide such third parties with access to your information to the extent reasonably necessary for them to provide the services for which they are contractually engaged to provide. We request that all of our service providers maintain commercially reasonable standards of security and confidentiality and must agree to keep such information secure and confidential in line with this Privacy Policy.

  5. How We Protect Your Information While no data transmission over the internet or wireless networks is 100% secure from intrusion, we maintain and have implemented reasonable physical, electronic, technical and procedural security policies and measures to protect the personal data that we process, which are consistent with applicable privacy and security laws. These policies and measures are designed to prevent against loss, misuse, unauthorized access, modification and disclosure and unlawful destruction of your personal data. The security measures can change and be modified over time, but generally include, but are not limited to, firewalls, data encryption, physical access controls to our data centers, servers and hardware and information access authorization controls and regular testing and updating of the systems.While we are dedicated to securing your personal data and our systems and Services, you are responsible for securing and maintaining the privacy of your credentials (e.g., user name, password or account information) and verifying that personal data we maintain about you is accurate and current. It is your responsibility to give us current, complete, truthful and accurate information, and to keep such information up to date. We cannot and will not be responsible for any problems or liability that may arise if you do not give us accurate, truthful or complete information, or you fail to update such information. We will reject and delete any entry that we believe in good faith to be false, fraudulent or inconsistent with this Privacy Policy.
  6. Data Retention We access, retain, store and use personal data for the least amount of time necessary pursuant to our relationship with you (e.g., to provide you with or access to our products and services), in accordance with our data retention policies and applicable law. We do not process more personal data than is necessary to fulfill our obligations to you or at law or for purposes stated in this Privacy Policy.
  7. Rights and Choices You Have with regard to Your Information If you are an EU citizen or reside in the EU, you may have certain additional rights with respect to the personal data you provided to us. To the extent permitted by applicable data protection laws, under EU laws you may:
    • Access or modify your personal data;
    • Object, on grounds relating to your particular situation, at any time to the processing of your personal data if the legal ground we are relying on is our legitimate interest or in the public interest;
    • Request that your personal data be erased if it is no longer necessary for the purposes for which it was processed, you have withdrawn consent to, or object to, the processing of such personal data and we meet no other legitimate basis for such processing or it has been unlawfully processed;
    • Restrict the processing of your personal data if you contest its accuracy or the lawfulness of our processing, we no longer need it but you need it for a legal claim or you have objected to its processing and await verification of our legitimate grounds for processing it;
    • Stop receiving our marketing communications. If you opt out of marketing emails, you will continue to receive messages from us about your relationship with us where permitted by law;
    • Under certain circumstances, have your personal data transferred to another company; and
    • Withdraw any consents that you have previously provided to allow us to process your personal data.

    If you wish to exercise any of these rights please contact us at [email protected]. Although we urge you to contact us to find a solution for every concern you may have, you always have the right to lodge a complaint with your competent data protection authority. Please note that some requests may require you to verify your identity.

    Modifying Privacy Settings: You also may be able to adjust certain privacy, permission and user account settings by sending an “unsubscribe” email to [email protected], responding to request alerts or notifications on your Device or by navigating to the settings, account or privacy section (as the case may be) of your Device or the applicable Third Party Platform and limiting certain Service functionality (e.g., location services, etc.). Please be aware that if you limit the collection of certain information, you may not be able to use all of the features and functionality of the Services.

  8. Withdrawing Consent; How We Use Tracking Technologies When you visit our Sites, use our Services (including the Widget), or visit a third-party website for which we provide online services, we and our publishers, third party partners and vendors may use Tracking Technologies to recognize you as a repeat visitor, authenticate your usage and/or Device, keep track of your preferences, visits and Redemption Points and to customize your online experiences, the Services you use, and other online content and advertising, measure the effectiveness of promotions and perform analytics, and to mitigate risk, prevent potential fraud, and promote trust and safety across the Sites and the Services. Certain aspects and features of our Services and Sites are only available through the use of Tracking Technologies, so if you choose to disable or decline Tracking Technologies, your use of the Sites and Services may be limited or not possible. Please review our Cookie Policy here to learn more about how we use and how you may adjust and disable Tracking Technologies.If you wish to receive more information about our privacy practices or to withdraw your consent to Insticator’s use of your personal information as set forth in this Privacy Policy, please email us at [email protected].
  9. International Visitors Our operations are supported by a network of computers, cloud-based servers, and other infrastructure and information technology, including, but not limited to, third-party service providers. We and some of our subsidiaries and affiliates, servers, publishers, partners, vendors and service providers may not be located in your jurisdiction and may also be located outside of the European Economic Area and Switzerland. If you are an EU citizen or resident in the EU, we will transfer your personal data to the United States or Ukraine in accordance with EU data protection law requirements by using model contractual clauses that have been approved by the European Commission or other appropriate means.Please note that such transfers may also be necessary in order to perform our obligations under a contract with you, to fulfill a request made by you, to meet a legal or regulatory obligation and/or through obtaining you express consent. If you make transactions with parties outside the EEA or Switzerland or connect our Service with platforms, such as Facebook, outside the EEA or Switzerland, we are required to transfer your Personal Data with those parties in order to provide the requested Service to you. If you wish to gain more information about such transfers, please contact us at [email protected].
  10. Information Collection from Children Our Sites and Services are not directed to children under the age of 13 (if you are located in the United States) and under the age of 16 (if you are located outside the United States). We do not knowingly collect information, including personal data from children or other individuals who are not legally able to use our Sites and/or Services. If we obtain actual knowledge that we have collected personal data from someone under the applicable age listed above, we will promptly delete it, unless we are legally obligated to retain such data. If you believe that we have mistakenly or unintentionally collected information from someone under the applicable age listed above, please email us at [email protected]. For users in the United States, please also visit the Federal Trade Commission’s website here for information about protecting children’s privacy online.
  11. Your California Privacy Rights If you are a resident of the State of California, we provide you with information on how to exercise your disclosure choice options such as your right to opt-out (which we may sometimes refer to as “unsubscribe”), as described in Section 7 , or opt-in for use of your information by third parties (such as advertisers) for marketing purposes. Therefore, pursuant to the California Civil Code, we are not required to maintain or disclose a list of the third parties that received your information for marketing purposes during the preceding year. If you are a California resident and you wish to request information about how to exercise your third party disclosure choices, please submit your request at [email protected] or by postal mail to Insticator Inc., c/o Privacy Administrator, 2 Park Avenue, 10th Floor, New York, New York, 10016, Attn: Your California Privacy Rights. All requests must be labeled “Your California Privacy Rights” on the email subject line or envelope or post card. For all requests, please clearly state that the request is related to “Your California Privacy Rights”, include your name, street address, city, state, zip code and e-mail address (your street address is optional if you wish to receive a response to your request via email) and indicate your preference on how our response to your request should be sent (email or postal mail). We will not accept requests via the telephone or by fax. We are not responsible for notices that are not labeled or sent properly, or do not have complete information. You can always opt-out or unsubscribe by emailing [email protected].
  12. Changes to Our Privacy Policy From time to time, we may modify this Privacy Policy to reflect industry initiatives, third party requirements or changes in the law, technology, our information processing practices or the features and functionality of the Services, and such modifications shall be effective upon posting. When we change this Privacy Policy in a material way, a notice will be posted on our Site along with the updated Privacy Policy. Your continued use of the Services after we post a revised Privacy Policy (and, where appropriate, notify you of same) signifies your acceptance of the revised Privacy Policy. It is therefore important that you review this Privacy Policy regularly to ensure you are updated as to any changes. We may continue to process your information based on our legitimate interests or in order to fulfill our obligations under a contract and/or may also seek your affirmative consent to the terms of the updated Privacy Policy. For example, we may ask for your consent before implementing new uses of the personal data that we’ve already collected from you based on such consent, if such new use was not addressed by the privacy policy under which such information was collected or if our legal basis for processing such information changes.The Services (including the Widget) may be linked to, rely on and/or be integrated with websites, applications, interfaces, services and/or platforms operated by third party companies, including service providers and Third Party Platforms. The Services may also feature advertisements from other third parties. Insticator is not responsible for the privacy practices of any websites, applications, interfaces, services and platforms operated by such third parties that are linked to, rely on and/or integrated with the Services, or for the privacy practices of third party advertising companies. Once you leave the Services via such a link, access a third party application, interface, service, or platform, including Third Party Platforms and websites operated by service providers or third parties, or click on or navigate to an advertisement, you should check the applicable privacy policy of such third party to determine, among other things, how they will handle any personally identifiable or other information that they may collect from you.
  13. Contact UsIf you have any questions or concerns about our privacy practices, how we handle your personal data or any of the terms or conditions of this Privacy Policy, please feel free to contact us at:

    By Email: [email protected]
    By Mail:

    Insticator Inc.
    Attn: Privacy Matters
    2 Park Avenue, 10th Floor
    New York, NY 10016