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Pier39.ai Privacy Policy and Notice at Collection

Last Updated: June 19, 2025

Pier39.ai is committed to protecting your privacy. This Privacy Policy explains how Persona XYZ Inc., doing business as Pier39.ai (collectively, "Pier39.ai," "we," "our," or "us") collect, use, disclose, and safeguard your personal Information, and describes the choices and rights available to you.

1. Scope of This Privacy Policy

This Privacy Policy applies to all users of:

  • Pier39.ai–Owned Sites – pier39.ai and any other websites or applications we operate (collectively, "Pier39.ai Sites");
  • Pier39.ai Technology embedded on third-party ecommerce stores' post-checkout pages or within their mobile applications (collectively, "Partner Sites"); and
  • Individuals who interact with Pier39.ai in a professional capacity on behalf of their employer (e.g., advertisers, merchants, agencies, or technology vendors).

2. About Pier39.ai

Pier39.ai powers a post-checkout advertising network. We connect ecommerce merchants ("Partners") with third-party brands ("Advertisers") by displaying performance-based Offers on Partner Sites. Shoppers ("End Users") who engage with an Offer may earn store credits from the Partner, funded by the Advertiser.

3. What Does Pier39.ai Do?

When a customer completes a transaction on a Partner Site, Pier39.ai's technology may display a personalized Offer (e.g., a subscription, coupon, or product recommendation). Interacting with an Offer is treated as an opt‑in to that specific Offer experience.

We may collect limited Personal Information and purchase-related data directly or indirectly through our Partners and, where applicable, through Advertisers, in order to fulfill and optimize Offer experiences.

3.1 Information We Collect at Offer Engagement

  • Identifiers – We may capture your email address and phone number (either entered by you or provided by the Partner's system) so we can deliver rewards, confirmations, or other Offer‑related follow‑ups.
  • Transaction & Conversion Data – From Partners and, where permitted, Advertisers, we may receive:
    • Items purchased, order value, purchase history, purchase method/date
    • Conversion events or attribution signals linked to a campaign or Offer engagement
  • Additional Identifiers from Partners/Advertisers – Partners and Advertisers may also supply optional demographic attributes (e.g., gender, age/DOB, postcode, title) to help us improve Offer targeting, ensure compliance (e.g., age gating), and reduce fraud.
  • Voluntary Submission to Advertisers – If you submit Personal Information directly on an Advertiser's landing page (after clicking through from our Offer), that data is governed entirely by the Advertiser's privacy and cookie policy, and not by Pier39.ai.

Fulfill Offers & Rewards – Send credits, confirmations, or reminders tied to the Offer you engaged with.

Campaign Measurement – Attribute conversions, improve relevance, and prevent duplicate or invalid rewards.

No Onward Sharing – Pier39.ai does not share your identifiers, demographic attributes, or purchase history with any Advertiser or external partner.

3.2 Your Choice to Limit Data Use

If at any time you wish to restrict or revoke our access to your purchase history or other Partner or Advertiser‑supplied data, email hello@pier39.ai (see Section 13). We will process your request within 72 hours.

4. Definition of Personal Information

"Personal Information" (or "Personal Data") means any information that identifies, relates to, describes, or could reasonably be linked to an individual, including identifiers (such as name, email address, or device ID) and inferences drawn from such data.

5. Types of Personal Information We Collect and When

CategoryExamplesHow We CollectLegal Basis¹
IdentifiersEmail address, phone numberCaptured from Partner systems at the time of Offer engagement or post-checkout eventConsent / Legitimate Interests
Commercial & Transaction DataProducts purchased, order value, purchase frequency, purchase historyGiven by Partner systemsLegitimate Interests (performance attribution)
Device & Usage DataIP address, browser type, referring URL, Offer click-throughs, page viewsAutomatically via cookies, pixels, or SDKsConsent (where required) / Legitimate Interests
Professional DataNot collectedNot applicableNot applicable
Inferences & SegmentsInterest categories, predicted preferencesDerived from other dataLegitimate Interests

¹ Pier39.ai relies on the legitimate interests of itself and its Partners to deliver relevant Offers, measure performance, and fund Partner rewards, balanced against your privacy rights.

6. How We Use Personal Information

We use your Personal Information to:

  • Select and display relevant Offers on Partner Sites.
  • Fulfill Offers (e.g., send confirmation emails or reward credits).
  • Attribute conversions and reward issuance by matching Offer interactions with subsequent purchases.
  • Prevent fraud and ensure brand safety (e.g., age gating, duplicate suppression).
  • Provide analytics and reporting to Partners (never including user-identifiable information).
  • Improve and develop our products and machine-learning models.
  • Communicate with you or your business regarding our services.
  • Comply with legal obligations and enforce our Terms.

7. How We Disclose Personal Information

We may disclose Personal Information in the following cases:

  • To service providers & subprocessors (e.g., cloud hosting, email platforms, anti-fraud providers) under data-processing agreements.
  • Within the Pier39.ai Group for internal administration and governance.

We do not share, sell, or disclose your email address or purchase history with any Advertiser or external partner.

8. International Data Transfers

Pier39.ai is headquartered in the United States and currently operates its cloud infrastructure solely within the United States. We do not store or process data outside the U.S. If this changes in the future, any international transfers of Personal Information will be done in accordance with applicable laws using standard contractual clauses or other legally recognized safeguards.

9. Cookies and Tracking Technologies

We use cookies, pixels, local storage, and similar technologies to remember preferences, personalize Offers, and measure conversions. You may control cookies through your browser settings. Blocking cookies will not stop all ads, but it may reduce Offer relevance.

10. Data Security

We employ administrative, technical, and physical safeguards, including:

  • Encryption in transit and at rest
  • Role-based access controls
  • Pseudonymisation (e.g., hashing email addresses)
  • Regular penetration testing and third-party security audits

11. Data Retention

We retain Personal Information for the shortest time necessary to fulfill the purposes outlined above, to comply with legal obligations, or to resolve disputes. Transaction and attribution data are typically retained for up to 36 months unless a shorter or longer period is mandated by applicable law.

12. Your Privacy Rights

Depending on your jurisdiction, you may have rights to:

  • Access the Personal Information we hold about you;
  • Correct inaccuracies;
  • Delete your Personal Information;
  • Restrict or object to certain processing;
  • Port your data to another service;
  • Opt out of cross-context behavioural advertising or automated decision-making.

How to Exercise Your Rights

Email hello@pier39.ai with your request. We may need to verify your identity (e.g., via the email address associated with an Offer) before acting on your request. We respond to all requests within 72 hours, or sooner where required by law.

13. Opt-Out and Marketing Preferences

  • Opt-out of seeing third-party Offers across Pier39.ai Partner Sites: Email hello@pier39.ai with the subject line "Opt-Out of Offers."
  • Restrict or revoke access to your purchasing history provided by a Partner: Email hello@pier39.ai with the subject line "Revoke Purchase History Access."

There are no negative consequences for opting out; however, you may still see first-party promotions from the Partner Site you are visiting.

14. Children's Privacy

Pier39.ai does not knowingly collect Personal Information from children under 13, nor do we target Offers to individuals under 16. If we discover we have collected such data, we will delete it promptly.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with a revised "Last Updated" date. Continued use of Pier39.ai Sites or Offers after such changes constitutes acceptance of the revised policy.

16. Contact Us

For privacy inquiries, data requests, or complaints, contact:

Persona XYZ Inc.

100 Pine Street, Suite 1250

San Francisco, California 94111

Email: hello@pier39.ai