TargetBay Sampling Community Privacy Policy

Draft status

DRAFT FOR LEGAL REVIEW. This text has not yet been approved by TargetBay counsel and is not in effect. Enrollment stays closed until approved versions are published.

1. Who this policy covers

This Privacy Policy explains how TargetBay, Inc. ("TargetBay," "we," "us," or "our") collects, uses, shares, and protects personal information through the TargetBay Sampling Community website at community.targetbay.com, the member portal, product review pages reached by QR code, and related emails (together, the "Community"). How it applies depends on who you are:

• Visitors: people who browse the Community without an account. Sections 3(a) and 6 apply.
• Members and applicants: people who apply to join or have a Community account. Sections 3(b) through 3(d) apply, along with the rest of this policy.
• Product reviewers using a QR code: people who submit a review from the card that came with a product, without a Community account. Section 3(e) applies.
• Brand contacts: people who represent a participating brand or ask about running a campaign. Section 3(f) applies.

2. Definitions

• "Brand" means a company whose products are offered through the Community.
• "Campaign" means a sampling program in which a Brand's products are offered to selected members.
• "Personal information" means information that identifies, relates to, or can reasonably be linked to a particular person or household.
• "Review content" means a rating, title, written review, and any photos or other material you submit about a product.
• "Usage data" means information collected automatically when you use the Community, such as IP address, browser and device type, pages viewed, and timestamps.
• "Destination" means a website or marketplace where review content may be published, such as a Brand's own site or a retailer such as Walmart.com.

3. Information we collect

(a) From visitors. Usage data and the cookies described in Section 6. If you contact support or submit a form, the information you provide.

• (b) When you apply: your email address, first name, a display name, confirmation that you are at least 18, your state and ZIP code, the product categories that interest you, your answers to optional questions, the policy versions you accepted, and the date and time of each consent. We do not ask for your date of birth, government ID, income, or medical history to apply.
• (c) After you are admitted: your shipping address and optional phone number for delivery, profile answers that help match you with suitable products, your communication preferences, and the offers you accept, decline, or let expire.
• (d) While you take part: shipment and delivery records, your confirmation that a product arrived, the review content you submit, its revisions, your attestations that you used the product and that the review is your own, support conversations, and records of moderation decisions about your reviews.
• (e) From QR code reviewers: your name as you want it shown, your email address (kept separately from the review and never published), the product's verification code, your review content, and your attestations.
• (f) From brand contacts: name, work email, company, phone number if provided, and details of the campaign you discuss with us.
• (g) Automatically: usage data, security logs, and abuse prevention signals such as a coarse indication of whether two accounts share a household. We store household signals as a keyed hash, not as a readable address.
• (h) From others: delivery and tracking updates from shipping carriers and fulfillment partners, and confirmation from a Destination about whether a review was published.

4. How we use information

We use personal information to:

• review applications, manage the waitlist, and operate your account;
• match members with products that fit their stated interests and location, using fit and eligibility only, never past ratings;
• ship products you accept and handle delivery problems;
• collect, moderate, and record honest reviews, including the required free product disclosure;
• share approved review content with Brands and Destinations as described in Section 5;
• send essential program emails about your application, offers, shipments, review tasks, and policy changes;
• send optional community news only if you opt in, which you can withdraw at any time without affecting participation;
• prevent fraud, duplicate accounts, fake reviews, and other abuse, and keep the Community secure;
• comply with law, respond to lawful requests, and enforce our Terms; and
• understand and improve the Community using aggregated or de-identified information.

5. How information is shared

We do not sell your personal information, and we do not share it for cross-context behavioral advertising. We share it only as follows:

• Fulfillment: your name and shipping address go to the authorized warehouse or carrier that ships a product you accepted, only for that shipment. Brands do not receive your address unless the Brand itself ships the product, and then only for that delivery.
• Review content: approved review content may be shared with the Brand and published on the Brand's site and on approved Destinations. It appears with the display name you chose, the free product disclosure, the product, and the date. Your email address, shipping address, and account details are never published.
• Destination requirements: Destinations such as Walmart.com may receive the metadata they require to publish a review, such as the product identifier, submission date, incentive badge, and verification status. Destinations apply their own policies and privacy practices.
• Brands: Brands receive campaign results, such as how many units shipped and aggregated review statistics. They do not receive your contact details.
• Service providers: companies that host, secure, or support the Community, such as Google Cloud and Firebase for hosting and authentication and our email delivery provider, under contracts that limit their use of the information.
• Legal and safety: when required by law or legal process, or when needed to protect the rights, property, or safety of members, Brands, the public, or TargetBay.
• Business transfers: as part of a merger, acquisition, or sale of assets, subject to this policy.

6. Cookies and similar technologies

The Community uses only cookies and browser storage that are necessary to sign you in, keep your session secure, protect against abuse, and remember choices you make. We do not use advertising cookies or third party ad trackers. Fonts and images are served from our own site. You can set your browser to refuse cookies, but signing in will not work without them.

7. Your rights and choices

Depending on where you live, you may have the right to know what personal information we hold about you, to get a copy, to correct it, to delete it, and to opt out of certain uses. We honor these requests for all members regardless of state, and we will not discriminate against you for making one.

• Account changes: update your profile, address, and email preferences in the member portal at any time.
• Leaving: you can pause or close your account through support. Closing your account stops new offers. Reviews already published by a Destination may remain there under the Destination's control; we will ask that they be removed where the Destination allows it.
• Requests: email community-support@targetbay.com from the address on your account, or write to TargetBay, Inc., Attn: Legal, Global Privacy Officer, 7000 Central Pkwy, Suite 220, Atlanta, GA 30328. We may need to verify your identity before acting. An authorized agent may submit a request with your written permission.
• Marketing: unsubscribe using the link in any optional email or in your preferences. Essential program emails continue while your account is active.

8. State privacy disclosures

California and other state residents: in the past 12 months we collected the categories of information described in Section 3 (identifiers, location such as state and ZIP code, commercial information about products offered and accepted, internet activity, and review content) for the purposes in Section 4, and disclosed them only to the recipients in Section 5. We do not sell or share personal information as those terms are defined by California law, we do not knowingly sell or share the information of anyone under 16, and we do not use sensitive personal information to infer characteristics about you. Global Privacy Control signals are honored as an opt out request.

9. Where information is stored

The Community is offered only to people in the United States. Information is stored and processed in the United States using Google Cloud. If you contact us from outside the United States, your information will be processed in the United States.

10. How long we keep information

We keep account information while your account is open and for a reasonable period after it closes to resolve disputes, prevent fraud, and meet legal obligations. Shipping addresses used for a delivery are kept only as long as needed to handle that shipment, returns, and related questions. Review records, revisions, disclosures, and moderation decisions are kept for as long as the review is published anywhere and for a period afterward, because Destinations and regulators may require proof of how a review was collected. Applications that are not admitted are deleted or de-identified after a set period.

11. Security

We use administrative, technical, and physical safeguards, including encryption in transit, restricted and logged staff access to shipping addresses, separate storage of sensitive data, and an audit trail of staff actions. No system is completely secure, so we cannot guarantee absolute security. If we learn of a breach that affects you, we will notify you as required by law.

12. Children

The Community is only for adults 18 and older. We do not knowingly collect personal information from anyone under 18, and reviews that indicate the reviewer is a child are rejected. If you believe a minor has given us information, contact us and we will delete it.

13. Links to other websites

The Community may link to Brand websites, retailers, and carrier tracking pages that we do not operate. Their privacy practices are their own, so please review their policies.

14. Changes to this policy

We may update this policy. Each version has its own version number and effective date. For material changes we will notify members by email or in the portal before the change takes effect, and where the law requires it, ask for your agreement again.

15. Contact us

Questions or requests: community-support@targetbay.com, or by mail at TargetBay, Inc., Attn: Legal, Global Privacy Officer, 7000 Central Pkwy, Suite 220, Atlanta, GA 30328.