Nift Networks Data Privacy Framework Policy



Effective as of January 24, 2025.

Policy Purpose

Nift Networks, Inc. (together "Nift," “us,” “our,” and “we”) is committed to and complies with the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework as set forth by the United States Department of Commerce. Nift has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) with regard to the processing of Personal Data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Nift has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (“Swiss-U.S. DPF Principles”) with regard to the processing of Personal Data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Privacy Statement and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (“DPF”) program, and to view our certification page, please visit https://www.dataprivacyframework.gov.

Scope

Nift provides an online and mobile application platform (“Nift Sites”) to enable you to discover new brands. We team with third-party ecommerce, restaurants and other businesses (“Partners”) who enable you to be matched with promotional offers and discounts for goods or services (“Gifts”) from our third-party advertisers (“Advertisers”) displayed on the Nift Sites (together, our “Services”). As part of the Services, you may choose to sign up to receive communications from Advertisers or Partners online (mobile web and desktop web, mobile application(s)), through email, phone or SMS mobile text messages.

This Policy applies to the processing in the U.S. of Personal Data transferred from the EU, the UK, or Switzerland to Nift in the U.S. of: (i) end users of the Nift Sites or social media accounts, (ii) end users of Nift technology that is integrated on our Partners’ websites, emails and mobile applications that are branded “Nift” and link to or reference this Policy or our Privacy Policy, and (iii) contact information associated with our Advertisers or Partners.

Definitions

“Data Subject” means the individual to whom any given Personal Data covered by this DPF Policy refers.
“Personal Data” means any information relating to an individual residing in the European Union, European Economic Area, the United Kingdom (including Gibraltar), and Switzerland that can be used to identify that individual either on its own or in combination with other readily available data.
“Sensitive Personal Data” means Personal Data specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, or information specifying the sex life of an individual.

Data Privacy Framework Principles

Nift commits to applying the DPF’s Principles to all Personal Data that Nift in the U.S. receives from European Economic Area member countries, the United Kingdom, and Switzerland in reliance on the respective DPF.

1. Notice
In accordance with our Privacy Policy, Nift notifies Data Subjects about its data practices regarding Personal Data received by Nift in the U.S. from member countries of the European Economic Area, United Kingdom, and Switzerland in reliance on the respective DPF, including the types of Personal Data it collects about them, the purposes for which it collects and uses such Personal Data, the types of third parties to which it discloses such Personal Data and the purposes for which it does so, and how Data Subjects can contact Nift with any inquiries or complaints.

2. Choice
Data Subjects have the right to opt out of (i) disclosures of their Personal Data to third parties not identified at the time of collection or subsequently authorized, and (ii) uses of Personal Data for purposes materially different from those disclosed at the time of collection or subsequently authorized.

To opt out of such uses or disclosures of Personal Data or Sensitive Personal Data, Data Subjects may contact Nift by e-mailing privacy@gonift.com.

3. Accountability for Onward Transfer
If we have received your Personal Data covered by this DPF Policy in the United States and subsequently transfer that information to a third party acting as an agent, we will transfer only the Personal Data covered by this DPF Policy needed for an agent to deliver to Nift the requested product or service. Furthermore, we will (i) permit the agent to process such Personal Data only for limited and specified purposes; (ii) require the agent to provide at least the same level of privacy protection as is required by the DPF Principles; (iii) take reasonable and appropriate steps to ensure that the agent effectively processes the Personal Data transferred in a manner consistent with Nift’s obligations under the DPF Principles; and (iv) require the agent to notify Nift if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the DPF Principles. Upon receiving notice from an agent that it can no longer meet its obligation to provide the same level of protection as is required by the DPF Principles, we will take reasonable and appropriate steps to stop and remediate unauthorized processing.

Nift remains liable under the DPF Principles if an agent processes Personal Data covered by this DPF Policy in a manner inconsistent with the DPF Principles, except where Nift is not responsible for the event giving rise to the damage.

4. Security
Nift takes reasonable and appropriate measures to protect Personal Data covered by this DPF Policy from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Data.

5. Data Integrity and Purpose Limitation
Nift limits the collection of Personal Data to information that is relevant for the purposes of processing. Nift does not process such Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the Data Subject.
Nift takes reasonable steps to ensure that such Personal Data is reliable for its intended use, accurate, complete, and current. Personal Data will be retained in accordance with our business purposes and our obligations to comply with legal requirements and professional standards, unless a longer retention period is otherwise permitted by law and its retention adheres to the DPF Principles.

6. Access
Data Subjects whose Personal Data is covered by this DPF Policy have the right to access such Personal Data and to correct, amend, or delete such Personal Data if it is inaccurate or has been processed in violation of the DPF Principles (except when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to the Data Subject’s privacy, or where the rights of persons other than the Data Subject would be violated). Nift will make reasonable and practical efforts to comply with your request, so long as our doing so would be consistent with applicable law. To make a data access request, Data Subjects may contact Nift by e-mailing privacy@gonift.com.

7. Recourse, Enforcement and Liability
The Federal Trade Commission has jurisdiction over Nift’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. In compliance with the DPF Principles, Nift commits to resolve DPF Principles-related complaints about our collection or use of your Personal Data. Data Subjects with inquiries or complaints regarding our handling of Personal Data received in reliance on the DPF should first contact Nift by e-mailing privacy@gonift.com.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Nift commits to refer unresolved complaints concerning our handling of Personal Data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to JAMS, an independent, alternative dispute resolution provider, at no cost to the complaining party. To contact JAMS and/or learn more about the company’s dispute resolution services, including instructions for submitting a complaint, please visit: https://www.jamsadr.com/DPF-Dispute-Resolution.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may be able to invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf for further information.
Nift agrees to periodically review and verify its compliance with the DPF Principles, and to remedy any issues arising out of failure to comply with the DPF Principles. Nift acknowledges that its failure to provide an annual self-certification to the U.S. Department of Commerce will remove it from the Department’s list of DPF participants.

Changes to this Data Privacy Framework Policy

This DPF Policy may be amended from time to time consistent with the requirements of the DPF. We encourage you to periodically review this DPF Policy to be aware of updates to our practices.

How to Contact Us

Nift is committed to protecting the privacy of your Personal Data. If you have any questions or comments about this DPF Policy, please contact us by e-mailing privacy@gonift.com.