Fishbowl, Inc. and Fishbowl Marketing LTD (“Fishbowl”) takes the privacy and security of our clients and their customers very seriously. Fishbowl provides this Internet Privacy Statement because our clients and their customers have a right to know what information we collect, how it is used, and how it is protected. This policy may be amended from time to time and was last updated on May 7, 2018.
Information Collection, Use and Registration for Fishbowl Client Customers
In order receive emails sent by Fishbowl on behalf of its clients; you must first complete a signup form (a) in a participating store, (b) at an event, (c) by dropping your business card in a fishbowl or basket or other collection device that states you are choosing to join the client’s email list, or (d) by registering online through its website, or (e) by opting in to receive emails from the client’s brand when making a reservation, or (f) by opting in to receive emails when signing up for a Loyalty Program, or (g) by opting in to receive emails from the client’s brand when accessing their WiFi in store. During registration, you are required to give contact information (such as first and last name, month and day of birth, and email address). The client provides this registration information to us. Fishbowl collects personally identifiable information from our users during the initial signup process as well as during surveys or preference requests. We use this information to contact you with offers, newsletters, birthday treats and special promotions which you have expressed interest in receiving. Additional Information such as dietary preferences, preferred location, interest in offers such as kids, events or group bookings enable clients to send relevant offers based on your interests.
You may also be given the opportunity to provide your cell/mobile phone number during the sign-up process or through a separate email from a Fishbowl client. By providing your cell phone number, you are agreeing to receive text (SMS) messages on your cell phone. You have the option to provide demographic information (such as gender and zip/postal code) to us; we encourage you to submit this information so we can provide you a more personalized experience. If you elect not to provide such demographic information, you may still participate in the client’s program offerings.
Communications may include offers, newsletters, updates, special promotions, surveys and unsubscribe confirmations.
Personal data processed by Fishbowl shall not be kept for longer than is necessary for the intended process or purposes and as long as a customer wishes to stay in a client’s email program. Customers have the right to request that their information be deleted, once the request has been verified the data will be deleted within 30 days.
Uses of Customer Information
Fishbowl follows an opt-out permission-based email and text message (SMS) enrollment policy. Fishbowl will not send unsolicited, bulk or commercial offers or advertisements. Fishbowl will NOT rent, sell, trade or loan our clients’ lists to anyone. All emails contain links on how to unsubscribe from the client list, how to request your data be updated or deleted. All SMS messages contain information on how to unsubscribe from the client list. You may leave our client’s lists at any time for any reason. If you have any questions or feel that you received unsolicited email or an unsolicited SMS message please contact us here.
Fishbowl will use personally identifiable information to contact you when responding to email support requests and other direct requests for information from Fishbowl. To protect your privacy and security, we will take reasonable steps to verify your identity before granting access or making corrections.
Surveys or Contests
From time to time we may provide you the opportunity to participate in web-based contests or surveys. If you participate, we will request certain personally identifiable information from you. Participation in these surveys or contests is completely voluntary and you therefore have a choice whether or not to disclose this information. The requested information typically includes contact information (such as name address and phone number(s)), demographic information (such as zip code) and personal preference information (such as your opinions). This information is used by our clients to better understand their customers.
Fishbowl may use a third party service provider to conduct these surveys or contests; that company is prohibited from using your personally identifiable information for any other purpose. We will not share the personally identifiable information you provide through a contest or survey with any third party except with the client unless we give you prior notice and you elect to permit the provision of that information to the third party.
Forward to a Friend
If you choose to use our referral service to tell a friend about an email club to which you subscribe, we will ask you for your friend’s name and email address. This process will automatically send your friend a one-time email inviting him or her to join the client email list. Fishbowl stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program, after which the names collected are removed from the database.
Information Sharing and Disclosure
Fishbowl only shares your data with the client from which you have requested to receive offers. We do not provide the client with your personally identifiable data; however, we do share reports about your statistics and information about your preferences. While the client retains ownership of your data, it has agreed that Fishbowl retains sole management during the term of their agreement and that it will not rent, sell or otherwise provide to third parties.
We use third parties to provide data entry and storage for our client list member data. When you sign up for an email club or any other Fishbowl service, we may share and/or store your enrollment information with our data entry company TDEC, or with our infrastructure hosting vendor(s). The Fishbowl platform and client data is stored securely with our infrastructure hosting vendors, Amazon Web Services (AWS) and Zayo. Such third parties are prohibited from using your personally identifiable information for any other purpose.
Upon request from a Fishbowl client, Fishbowl may use additional third party vendor(s) to fulfill promotions on behalf of Fishbowl and the client. Any third party vendor of Fishbowl is contractually prohibited from using your information for any other purpose.
We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to (a) protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our Company; (b) protect and defend Fishbowl’s rights or property or the users our services, and (c) act under exigent circumstances to protect the personal safety of users of our services or the public.
If you no longer wish to receive our communications, you may opt-out of receiving them by following the instructions included in each communication or by submitting a request here.
Alternatively, you may contact us at:
US Customers: 703-836-3421 ext. 110 or mail the information to Fishbowl Inc., Attention: Privacy Dept., 44 Canal Center Plaza, Suite 500, Alexandria, VA 22134.
UK Customers: 0808-189-1495 Ext. 110 or post the information to Fishbowl, Attention: Privacy Dept. Fifth Floor
11 Leadenhall Street, London, EC3V 1LP
We use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If you would like to opt-out of these emails, please see “Opt-out/Unsubscribe”.
Fishbowl places a “cookie” on the browser of a Fishbowl.com user’s computer to store and sometimes track information about you. Cookies are information files that your web browser places on the hard drive of your computer when you visit a website. Cookies were designed to help a web site recognize the prior visits to a site made by a user’s browser. Cookies cannot damage user files, pass on computer viruses, capture e-mail addresses or read information from a user’s hard drive.
You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to sign in or use some features of Fishbowl’s website and services that depend on cookies.
Links to Other Sites
Emails that we send on a client’s behalf may contain links to other sites that are not owned or controlled by Fishbowl. Please be aware that Fishbowl is not responsible for the privacy practices of such other sites and do not exercise authority over such web sites. Fishbowl therefore assumes no responsibility for the privacy and data collection policies and procedures of such linked web sites, nor for the content or reliability of such web sites. If you choose to access a third party web site, you do so at your own risk.
You have the right to access the personal information that we hold about you. This may be called a ‘Subject Access Request’. If you make a request for your information we will provide it to you or your designated agent free of charge within 30 days.
Before providing personal information to you or your designated agent on your behalf, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information.
If any of the personal information we hold about you is inaccurate or out of date, you may ask us to correct it or correct, update, delete, or deactivate it yourself by making the change on our member information page or submitting a request here or by contacting us using the contact information listed below.
You have the right to object to us processing your personal information if we are not entitled to use it anymore, to have your information deleted if we are keeping it too long, or have its processing restricted in certain circumstances.
If you would like to exercise any of these rights or lodge a complaint, please contact us using the information as set out below.
We will retain a copy of your information in accordance with law and only so long as necessary to provide you with high quality and consistent services including marketing services and account information.
Fishbowl has put in place certain technological and procedural security functions in order to protect the personal information it collects, uses or transfers from loss, misuse, alteration or destruction. Fishbowl uses firewalls to help prevent outside parties from accessing our database server through the Internet, and physical access to the database server is restricted to authorized individuals.
When transferring personally identifiable information to and from third parties Fishbowl uses TLS & SFTP (Secure FTP) (which includes SHA-2 hashing & RSA 2048 bit keys), as required for Email Sender and Provider Coalition (ESPC) membership.
Information collected by our website or transferred to us from other sources will be processed in the United States.
Fishbowl complies with the EU-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles.
You can review the details about the Privacy Shield program, and our certification.
The United States Federal Trade Commission (FTC) is the enforcement authority with jurisdiction over this compliance with the Privacy Shield.
We are responsible for the processing of personal data we receive, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
Our third-party dispute resolution provider is Privacy Trust.
Finally, and as a last resort in limited situations, individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.
US Phone: 703-836-3421, Ext. 110
UK Phone: 0808-189-1495 Ext. 110
Online: Submit a request here.
US Mail: Fishbowl, Inc., Attn: Privacy Dept., 44 Canal Center Plaza, Suite 500, Alexandria, VA 22314
UK Post: Fishbowl, Attn: Privacy Dept., Fifth Floor, 11 Leadenhall Street, London, EC3V 1LP United Kingdom
Changes in this Privacy Statement
We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will publicize such changes by means of a notice on our home page by providing thirty (30) days’ notice to you by displaying a prominent notice, in all caps, above the text of the Privacy Statement.
If you have not received a timely or satisfactory response from Fishbowl Inc. to your question or complaint, please contact Privacy Trust here.