Privacy Policy

Wildfire Systems, Inc.

Effective Date: July 24, 2023

Last Updated: September 29, 2026

Wildfire Systems, Inc. (“Wildfire,” “we,” “us,” or “our”) provides this Privacy Policy to let you know about our policies and procedures regarding how we collect, use and disclose personal information from users of the software, services, programs, websites and/or applications we offer (the “Services”), including:

clients on behalf of whom we offer white-label rewards programs, loyalty solutions and monetization platform (“Clients”), as well as their customers;
customers who use rewards programs, loyalty solutions or monetization platforms powered by Wildfire that link to this Privacy Policy;
customers whose personal information Wildfire receives or collects as a controller from business partners, such as certain Clients; and
visitors of Wildfire websites, or those who contact Wildfire for support.

WHAT THIS PRIVACY POLICY COVERS

Wildfire offers white-label rewards programs, loyalty solutions and monetization platforms for our Clients, which include companies that you interact with such as merchants, financial service providers, software providers, telecommunications companies, and other companies.

For example, Wildfire’s Cashback, Rewards, or Savings programs (collectively, “Rewards Programs”) are offered as a value exchange. When you choose to participate in Rewards Programs and in return allow us to collect and use information collected through Rewards Programs, you may receive tangible benefits such as cashback rewards, discounts, coupon codes, price comparisons, and personalized savings opportunities.

When we act on behalf of our Clients, we only collect, use, and share personal information as instructed by our Clients. If you are a user of our Client’s website, service, or application that is powered by us but does not link or refer to this Privacy Policy, the terms of the Client’s privacy policy — and not this Privacy Policy — apply. Please review the terms of the Client’s privacy policy to learn more about how it processes and protects your information. This Privacy Policy also does not apply to the products, services, mobile applications or content offered by third parties (“Third-Party Services”). Data collected by these third parties is covered by their own privacy policies. We encourage you to carefully review the privacy policies of any Third-Party Services you access

Where Wildfire acts as a controller and collects information directly from you – or from a website powered by us – this Privacy Policy applies. In certain cases, where we are providing the Services solely on behalf of a Client, the Client may contractually permit us to use information for our own purposes as explained in the Privacy Policy. In those circumstances, we are an independent controller, and this Privacy Policy will apply to the information we receive from the Client. Please carefully review the Services, as well as this Privacy Policy.

By continuing to use the Services, you acknowledge the collection, storage, and use of your Personal Information as described in this Privacy Policy and agree to our Terms of Use.

WHAT INFORMATION WE COLLECT AND HOW

We receive information about you from various sources, such as from you when you interact with us or submit information to us, or indirectly when you interact with the Services through Clients, merchants or other third parties. We may also collect information from you automatically in connection with your use of the Services.

Personal Information Collected Directly From You. We may request, collect, and use the following types of information about you in connection the Services:

Registration / Account Data. When you register and administer your account or profile, we request or you may choose to provide your contact information including your name and contact information (such as email, address, or phone number).
Contact Information. We collect personal information such as your name, company name, email, phone number and information about how we can help you when you contact us directly, express an interest in obtaining information about us or our Services, or if you contact us for customer service.
Information from Other Services. You may give us permission to access your information from other services. For example, you may link your Google or email account which allows us to obtain information from those accounts (such as your contacts) or may serve as an alternate method of registering for our Services. The information we get from those services often depends on your settings or their privacy policies, so be sure to check what those are.
Payment Information. We may request payment information in order to pay rewards to you which you have earned using the Services. Payment information varies depending on which payment method you choose. For example, (a) PayPal information may consist of the email, username or phone number associated with your PayPal account (b) Bank ACH payment information may include the name on your account, the bank’s routing number, your account number, and your phone number.
Audio or Similar Information. We collect audio information when you use the Services. For example, depending on how you interact with us, we may collect audio information when you use call Customer Care.
Tax Information. For US residents, if your reward earnings reach certain thresholds set by tax authorities, we may request that you complete and submit a Form W-9 (or other form) in order for us to be able to file a Form 1099 report of your earnings. Similar forms are provided to residents of countries other than the US.
Employment and Educational Information. If you apply for a position with us, whether directly or through our Career Page, we collect certain information about you including your education, work experience, credentials, and any professional references.
Authentication Data. We collect tracking code or reference number which is unique to each user.
Inference Data. We make inferences from personal information to create a profile, e.g. individual predispositions, behavior, and attitudes.
Aggregate or De-Identified Information. We also collect statistical information about how users, collectively, use the Services.

Personal Information Collected From Third Parties. We may receive personal information about you from third parties with whom we have a relationship such as our Clients, merchants, and other business partners, including the following:

Transaction Data. We receive information pertaining to each transaction you complete, including purchases and returns, in conjunction with your use of our Clients’ sites and mobile apps. This includes a date and time stamp of a transaction, transaction amount, merchants visited, amount of reward earnings generated, discount or coupon codes used, a descriptor of item(s) in each transaction, and other characteristics of the transaction.
Authentication Data. We collect tracking code or reference number which is unique to each user from Clients.

Information Collected Automatically. When you use the Services, Wildfire automatically logs information about you, or your computer or device, including:

Device/Network Information. We automatically receive and record information when you interact with the Services, including your IP address and device information (such as IMEI, MAC, device manufacturer/model, screen resolution, browser user agent, operating system name and version). We also collect information about how your device has interacted with our Services, including the pages accessed and links clicked, as well as data from cookies or pixel tags that may be used to identify your device or behavior.
Usage and Content Information. We store information regarding how you use the Services, and we associate such usage information with your device ID or account information. Additionally, if you send a referral link after the Services are installed and enabled on your device (either by yourself or via a third-party integration), we collect, store and analyze the content adjacent to the link in order to optimize the link destination.
Geolocation Information. We collect approximate location data such as information about your device’s approximate location derived from IP addresses.
Third-Party Analytics. We use automated devices and applications, such as Google Analytics to evaluate usage of our site and Services. We use these tools to help us improve our site’s performance and user experiences. You can download the Google Analytics Opt-out Browser Add-on, which may help prevent data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.
Authentication Data. We collect tracking code or reference number which is unique to each user through automatic means.

Information Collected Using Cookies. Cookies are pieces of text that may be provided to your computer through your web browser when you access a website. Your browser stores cookies in a manner associated with each website you visit. We use cookies to enable our servers to recognize your web browser and tell us how and when you visit our website and otherwise use the Services through the Internet. We also use cookies to enable tracking and attribution of transactions which result from referrals which occur subsequent to the initial click of a referral link. Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as allowing you to decide on acceptance of each new cookie in a variety of ways. This Privacy Policy covers our use of cookies only and does not cover the use of cookies by third parties. We do not control when or how third parties place cookies on your computer. For example, third party websites to which a link points may set cookies on your computer.

Web Beacons. We or the third parties we engage to track and analyze usage data may employ clear gifs (a.k.a. Web Beacons) to help us better operate and improve the Services. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on your computer's hard drive, clear gifs are embedded invisibly on web pages.

HOW WE USE INFORMATION WE COLLECT

Depending on the context and the specific Services, Wildfire processes personal information for the following purposes:

To Provide Services

To operate and provide the Services, including by registering you to use the Services, customizing the Services, tracking transactions, and attributing rewards.
To perform and improve the Services.
To understand how Clients and other users use the Services, evaluate, fix, and improve our Services, research, develop, and test new services and features, and conduct troubleshooting activities.
To verify accounts and activity and promote safety and security on and off the Services, such as by investigating suspicious activity or violations of the Terms of Use, and to ensure our Services are being used legally.

To Communicate with You and Provide Targeted Advertising

To provide customer support, respond to you when you contact us, and otherwise communicate with you via email, app notifications or other methods regarding the Services, terms, policies, and other updates, including to personalize offers, discounts, and recommendations.
To send you products, Services, and new feature information and/or information about changes to our Terms of Use.
To send marketing and promotional communications. You can opt-out of our marketing emails at any time (see the "Your Choices" section below).

To develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and to measure its effectiveness.

To Research, Develop and Improve the Services

To share, license, sell, or otherwise make available information to our affiliates, business partners, Clients, and select third parties.
To create analytics, insights, models, scores, attributes, segments, or profiles, including for market research, advertising, and product development.
To develop commercial data products, including datasets, reports, benchmarks, or insights derived from user activity.
To combine or enrich personal information with data from third-party sources to improve accuracy, relevance, or utility.

For Other Business Purposes

For other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our Services and to evaluate and improve our Services, products, marketing, and your experience.
If you are applying for a position with us, to consider you for employment.

For Legal Reasons and to Protect the Services

To protect our Services as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention).
To enforce our Terms of Use for business purposes, to respond to legal requests, comply with legal and regulatory requirements or in connection with our contract with our Clients and other business partners.

With Your Consent

To fulfill other business or commercial purposes at your direction or with your consent.

Aggregate and De-Identified Information

To aggregate or de-identify information so that it can no longer reasonably be used to identify you. Once de-identified, we may use and share such information for any lawful purpose, including commercial, research, analytical, and modeling purposes, including with third parties for marketing, advertising, research, or other purposes as permitted by applicable law. We may also use de-identified or aggregated information that does not identify you for any purpose in compliance with applicable law.

HOW WE SHARE INFORMATION WE COLLECT

Service Providers. Like many businesses, we engage third-party vendors, service providers, contractors or agents to perform business functions or services for us or on our behalf. For example, we may share your payment information with (i) payment companies to store your payment information and remit payments to you; (ii) third party to facilitate the collection of a Form W-9 and distribution of a Form 1099; or (iii) security consultant to help us get better at identifying spam or fraud. In addition, some of the information you submit may be collected and stored by third party providers on our behalf. Other examples include cloud computing, IT services, and payment processing, data analysis, email delivery, hosting services, customer service and marketing agencies.

Clients and Merchants. We share personal information and your usage and transaction information, with Clients or merchants and their intermediaries for their use in marketing products and services to you, profile enrichment, customer segmentation, analytics, and validating the transactions resulting from your use of the Services. For example, we may share personal information with merchants that provide products or services as part of our Rewards Programs.

Business Partners. To make certain products, services, and experiences available to you, we work closely with business partners, including loyalty and rewards partners, merchants, advertisers, or distributors. We also share your personal information and your usage and transaction information, as well as de-identified or aggregate information with our business partners to enable certain products, services, or promotions, as well as for analytics, profiling, profile enrichment, eligibility assessment, or financial and marketing insights, including by financial institutions or consumer data organizations acting under their own legal obligations.

Analytics and Advertising Providers. We share information with marketing, advertising and analytics providers to deliver advertising to you on behalf of Wildfire, including ad impressions, ad audiences, and personalized advertising based on your interactions with our Services as well as your activity on Third-Party Services.

Affiliates. We share your personal information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

Merger, Sale or other Asset Transfer. We share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, acquisition, or any other change of control or corporate re-organization.

Aggregate or De-identified Information. We share aggregate or de-identified information with our business partners, Clients, service providers, and other organizations with whom we conduct business. We do this to help them better understand how users engage with our Services and their own websites or offerings, which in turn supports improvements to their services as well as enhancements to how our Services integrate and interact with theirs. In addition, these third parties may share with us aggregate information that they have independently developed or acquired.

As Required by Law. We also reserve the right to access, read, preserve, and disclose any information as it reasonably believes is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) determine and enforce your adherence to our Terms of Use, including investigation of potential violations thereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

To Third Parties When You Give Consent. We may share information about you with third parties if you give us permission or direct us to share the information.

Third-Party Links. If you use the Services to submit content or personal information to Third-Party Services, such information is governed by the privacy settings of those particular Third-Party Services. We therefore urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through the Services. In addition, you may access Third-Party Services through the Services, for example by clicking on links to Third-Party Services, and subsequently submit information directly to such Third-Parties Services. We are not responsible for the privacy policies and/or practices of these Third-Party Services, and you are responsible for reading and understanding those Third-Party Services' privacy policies.

Credit-Related and Financial Use Disclaimer. Some third-party business partners that receive information from Wildfire, such as financial institutions, card issuers, analytics providers, or consumer data organizations, may use that information to enrich consumer profiles, perform analytics, assess eligibility for offers, or conduct preliminary evaluations related to marketing, risk assessment, or financial products. Wildfire is not a consumer reporting agency and does not make credit, lending, insurance, or employment decisions. Any such decisions are made solely by the applicable third party pursuant to its own processes, disclosures, and legal obligations. Where required by law, such third-party uses occur only in connection with optional programs or consents described in this Privacy Policy and remain subject to applicable consumer rights, including rights related to automated decision-making.

DATA RETENTION

We retain personal information for so long as it, in our discretion, is necessary to achieve the processing purposes described in this Privacy Policy, and in any event, for so long as is required by law or necessary to provide the Service. We review retention periods periodically and sometimes pseudonymize or anonymize data held for longer periods.

We also retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and/or for the period required or permitted by laws in applicable jurisdictions. Please note that some or all of the personal information we have collected may be required for the Service to function properly.

INFORMATION SECURITY

We employ procedural and technological security measures designed to safeguard your personal information from loss, unauthorized access, disclosure, alteration, or destruction. Please be aware that despite our efforts, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your password, mobile device, and computer. We are not responsible for any lost, stolen, or compromised devices or passwords, or for any activity on your account via unauthorized access.

INTERNATIONAL USAGE

Our Services are provided Worldwide. By using our Services, you authorize us to transfer, process, and store your personal information outside of your home country, including in the United States, for the purposes described in this Privacy Policy. Our computer systems are currently based in the United States where data protection requirements and privacy regulations may be different than other parts of the world. If you use the Services as a user from outside the United States, you will have agreed to the terms of this Privacy Policy and our Terms of Use, you will have consented to processing of all such information in the United States, and you will have agreed that your personal information will be subject to the requirements of the privacy regulations of the United States, which may not offer an equivalent level of protection as certain other countries.

If you are located in the EEA, UK, Switzerland or other countries which restrict the transfer of personal information, we comply with applicable data protection laws when transferring your personal information outside of these areas. In particular, we may transfer your personal information to countries for which adequacy decisions have been issued; implement appropriate and suitable safeguards such as the European Commission’s Standard Contractual Clauses or the Addendum B.1.0 issued by the Information Commissioner of the UK for the transfer of personal information to our U.S. headquarters, other offices or third parties, where applicable, or where required, we will ask you for your prior consent.

YOUR CHOICES

Opt-out of offers and marketing communications. You can opt out of promotional emails from us by following the instructions provided in the communications you receive, or you may log into your account and update your preferences. Please note that even if you opt out or stop using the Services, you may still receive certain transactional or operational communications regarding the Services, such as updates to the terms applicable to the Services or this Privacy Policy.

Consent. If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Withdrawing consent will not affect processing that occurred before withdrawal.

Push Notifications. You may opt out from allowing us to send you push notifications by adjusting the permissions in your mobile device. You may also choose which types of push notifications to receive by adjusting the permissions within the application. This opt-out choice does not apply to in-app notifications.

Do Not Track. Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preferences. At this time, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

Clients may offer additional choices and allow you to exercise any rights accorded to you under applicable laws. For more information, please contact the Client with whom you directly interacted or the Merchant directly.

YOUR PRIVACY RIGHTS

EEA & UK

If you are an individual residing in the EEA and UK, you have certain rights regarding your personal data that we collect as a data controller under applicable data protection laws. These include the right (i) to request access and obtain a copy of your personal data, (ii) to request that we delete or erase your personal data (iii) to request rectification or correct inaccurate information; (iv) to restrict the processing of your personal data; (v) right to object to processing of personal data in certain circumstances such as marketing activities; and (vi) if applicable, to data portability.

To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws and when applicable, the instructions of our Clients.

In our role as a controller under applicable data protection laws, we may process your personal information under the following legal bases:

Consent: We may process your personal data if you have given us specific consent to use your personal data for a specific purpose. You have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Legitimate Interests: We may process your personal data when it is reasonably necessary to achieve our legitimate business interests.
Performance of a Contract: Where we have entered into a contract with you, we may process your personal data to fulfill the terms of our contract.
Legal Obligations: We may disclose your personal data where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

If you are a resident in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to lodge a complaint with your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Please note that the rights described above are not absolute, and where an exception under applicable law applies, we may be entitled to refuse requests in whole or in part.

ADDITIONAL NOTICE FOR RESIDENTS OF CERTAIN U.S. STATES

This section applies to residents of certain U.S. states that have enacted privacy laws that apply to us. If you are a resident of any such U.S. state, this section will prevail over any conflicting provisions in other sections of this Privacy Policy.

Shine the Light Law

California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. To learn more about how to opt out of such disclosure, please email us at privacy@wildfire-corp.com.

Personal Information We Collect

We have collected the following categories of personal information in the last 12 months:

Identifiers, such as real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
Personal information described in subdivision (e) of Cal. Civ. Code Section 1798.80, such as name, address, telephone number, or payment information.
Commercial information, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other similar network activity, such as browsing history, search history, and information regarding your interaction with a website, application, or advertisement.
Geolocation data, if you consent to location-based Services.
Sensory data, such as audio, electronic, visual, or similar information.
Professional or employment-related information, such as your resume or work history, if provided in job applications.
Education information, such as your education history or certifications, if provided in job applications.
Inferences, such as a profile about your preferences, characteristics, and behavior.
Sensitive personal information, such as account login credentials or payment data provided for purchases.

We collect above categories of personal information from you, through automatic data collection, and from other sources and retain each category of personal information as described in the “Data Retention” section above.

Disclosures of Personal Information

Within the last 12 months, we have disclosed all or substantially all categories of personal information above for our business purposes. To learn more about the categories of entities to whom we disclose such information, please see the “How We Share Information We Collect” section above.

As of the “Last Updated” date of this Privacy Policy, we sell or share identifiers, commercial information, internet or similar network activity, and inferences with our business partners, including advertising partners and social media companies for valuable consideration, cross-context behavioral advertising or targeted advertising. We do not sell or share, and in the past 12 months have not sold or shared, personal information of California consumers we know to be under 16 years of age for valuable consideration or cross-context behavioral advertising.

Profiling

We do not process your personal information for the purpose of profiling in furtherance of decisions that produce legal or similarly significant effects under applicable law.

Your Privacy Rights

You may have certain rights related to your personal information subject to applicable privacy laws, including the following:

The right to know and/or request access to personal information we have collected about you, which may include the categories of personal information, the categories of sources from which your personal information is collected, the business or commercial purpose for collecting, selling, or sharing your personal information, the categories of third parties to whom we disclose your personal information, and the specific pieces of personal information we have collected about you. If applicable, this can be provided in a portable and readily usable format.
The right to request that we delete personal information we have collected about you.
The right to request we correct inaccurate personal information that we have collected about you.
The right to opt out of the sale or sharing of your personal information for cross-context behavioral advertising or targeted advertising.

To make any request of the above privacy rights, please email us at privacy@wildfire-corp.com. As required or permitted under applicable law, we may ask you to give us your name, e-mail address, telephone number, and other similar information to verify your identity.

Our website also recognizes the Global Privacy Control (“GPC”) signal, which enables you to opt out of certain uses or disclosures of your information. If you notify us of your preference through GPC, we will treat such signal as a valid request to opt out of sharing or targeted advertising for the associated browser or device, and, if we are able to associate the device sending the signal to a specific account, we will apply the opt out request to the account as well. To learn more about GPC, you can visit https://globalprivacycontrol.org/.

If your rights request is denied, you may have a right to lodge an appeal with us. If you would like to appeal against our decision for your request, you may submit a request for appeal by emailing us at privacy@wildfire-corp.com.

You also have the right not to receive discriminatory treatment by us for the exercise of any privacy rights.

You may designate an authorized agent to make a request of the above privacy rights on your behalf providing the agent with written permission to act on your behalf. We may require the agent to provide proof of that written permission, or may require you to verify your own identity, even if you choose to use an agent. If you are an authorized agent submitting a request on behalf of another individual, please email us at privacy@wildfire-corp.com.

Notice of Financial Incentive

Rewards Programs provided through the Services that link or refer to this Privacy Policy is considered a “financial incentive” under applicable privacy laws. You can enroll in Rewards Programs by creating an account with us. The value of your data is reasonably related to the benefits you receive through cashback, discounts, and savings opportunities.

You can review the terms for Rewards Programs here [LINK]. We collect substantially all categories of personal information described in “Personal Information We Collect” above for Rewards Programs, which we disclose to categories of third parties listed in “How We Share Information We Collect” above, including for targeted advertising purposes. You also can opt-out of the Rewards Program at any time by managing your account settings.

CHILDREN

We do not knowingly collect personal information from or market to children under the age of 18. We do not knowingly solicit data from or market to children. If we learn that personal information from children has been collected, we will deactivate the account and take reasonable measures to promptly delete such personal information from our records. If you become aware of any personal information, we may have collected from children, please contact us at privacy@wildfire-corp.com.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. We will update this Privacy Policy through our website as necessary to stay compliant with relevant laws. The updated version will be indicated by an updated date. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

QUESTIONS OR CONCERNS

If you have any questions or concerns regarding privacy using the Services, please send us a detailed message via email at privacy@wildfire-corp.com or via postal mail at Wildfire Systems, Inc., 153 S. Sierra Ave., #1282, Solana Beach, CA 92075.