Effective October, 2021
“EBT Transaction” means a transaction subject to the requirements set by the US Department of Agriculture Food and Nutrition Services (“FNS”) and any state or local requirements governing online purchases of households benefiting from the Electronic Benefits Transfer (“EBT”) system under the Supplemental Nutrition Assistance Program or any other similar program adopted by the FNS, including without limitation any requirements applicable to payments using EBT benefits and store eligibility requirements, as such requirements may be updated from time to time.
“Personal Data” in this policy means protected information about you, including without limitation your identity, finances, and online behavior as detailed in Section 1 below.
“Website” means https://www.joinforage.com/ and any successor website. Please note that we also act on behalf of and under the instructions of financial institutions, merchants and other partners which act as data controllers, including for processing payment transactions. Please refer to their respective privacy policies for more information regarding the processing of your Personal Data in these contexts.
1. Personal Data we collect
Depending on how you interact with our website and services, we may collect the following categories of Personal Data:
- Transaction information, such as type of purchase, personal account number, the merchant’s information, the date and the total amount of the transaction, and other information provided by financial institutions or merchants needed to process EBT Transactions.
- Website, device and mobile app usage, the browser you use, your network connection, your IP address, and details and similar information collected via automated means, such as cookies and similar technologies directly from your device.
- Information you provide about yourself like your name, billing address, email address, phone number, and payment information.
2. How we may use your Personal Data
We May Use Your Personal Data to:
- Process your EBT transactions
- Operate, evaluate, support and improve our services, through the use of aggregated and anonymized Personal Data and usage data
- Detect security breaches, protect against fraud and malicious activity and take action against wrongdoers (e.g. fraudsters and hackers)
- Perform other business purposes
3. How we protect your Personal Data
We have implemented appropriate technical and organizational security measures designed to protect the security of any Personal Data we process, including compliance with the security standards set by the Payment Card Industry (aka PCIDSS).
4. How we store your Personal Data
We use Amazon’s distributed cloud storage resources to store your Personal Data. Accordingly, your Personal Data may be stored on servers inside or outside the United States.
5. How long do we keep your information?
6. Your rights over Personal Data
Depending on how you use the Forage Services, you may have the right to request access to, correct, amend, delete, port to another service provider, restrict, or object to certain uses of your Personal Data. If you complete an EBT Transaction and wish to exercise these rights over information about your purchase, you need to directly contact the merchant you interacted with. We are only a processor on their behalf, and cannot decide how to process their information. If we have a direct contractual relationship with you, please submit your data subject request to firstname.lastname@example.org. Finally, because there is no common understanding about what a “Do Not Track” signal is supposed to mean, we don’t respond to those signals in any particular way.
7. Your specific rights under CCPA
Your specific rights under the California Consumer Privacy Act (“CCPA”) are as follows:
- (a) CCPA Privacy Notice (The California Code of Regulations) defines a "resident" as: (1) every individual who is in the State of California for other than a temporary or transitory purpose and (2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose All other individuals are defined as "non-residents." If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your Personal Data. The payment transaction information that Forage collects is regulated by existing federal financial privacy laws. The CCPA recognizes that such financial information is already protected by federal privacy law, so the CCPA does not apply to this information. Beyond financial information, Forage may collect certain information that is subject to the CCPA. This supplemental privacy notice explains our practices for this CCPA covered information.
- (b) We have collected the categories of Personal Data listed in Section 1 in the past twelve (12) months. We may also collect other Personal Data outside of these categories instances where you interact with us in-person, online, or by phone or mail in the context of: (i) Receiving help through our customer support channels; (ii) Participation in customer surveys or contests; and (iii) Facilitation in the delivery of our services and to respond to your inquiries.
- (c) You may contact us by email for support via email@example.com, or by referring to the contact details at the bottom of this document. If you are using an authorized agent to exercise your right to opt-out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
- (d) We may disclose your Personal Data with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf. We may use your Personal Data for our own internal business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal data. Other than to provide the services, Forage has not disclosed and Forage has not sold any Personal Data to third parties for a business or commercial purpose. Forage will not sell Personal Data in the future belonging to website visitors, users and other consumers.
- (e) Your rights with respect to your Personal Data are as follows;
- (i) Right to request deletion of the data - You can ask for the deletion of your Personal Data. If you ask us to delete your Personal Data, we will respect your request and delete your Personal Data, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, and/or our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.
- (ii) Right to be informed - Depending on the circumstances, you have a right to know: § whether we collect and use your Personal Data; § the categories of Personal Data that we collect; § the purposes for which the collected Personal Data is used; § whether we sell your Personal Data to third parties; § the categories of Personal Data that we sold or disclosed for a business purpose; § the categories of third parties to whom the Personal Data was sold or disclosed for a business purpose; and § the business or commercial purpose for collecting or selling Personal Data. In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
- (iii) Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights - We will not discriminate against you if you exercise your privacy rights.
- (iv) Verification process - Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate. We will only use Personal Data provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as We finish verifying You.
- (v) Other privacy rights § You may object to the processing of your Personal Data § You may request correction of your Personal Data if it is incorrect or no longer relevant, or ask to restrict the processing of the data § You can designate an authorized agent to make a request under the CCPA on Your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA. § You may request to opt-out from future selling of your Personal Data to third parties. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission. To exercise these rights, you can contact us by email at firstname.lastname@example.org. If you have a complaint about how we handle your data, we would like to hear from you.