Privacy policy
COUPIAN PRIVACY POLICY
Effective Date: 08/22/2026
Last Updated: 08/22/2026
Coupian [LEGAL ENTITY NAME] (“Coupian,” “we,” “us,” or “our”) respects your privacy and is committed to explaining clearly how we collect, use, disclose, and protect information when you use Coupian.
This Privacy Policy applies to Coupian's websites, applications, marketplace, merchant and organizer tools, Event ticketing services, Deal Voucher and Gift Card services, customer-support systems, The Buzz, newsletters, waitlists, and related services (collectively, the “Platform”).
This Privacy Policy applies to:
* visitors who browse Coupian;
* registered shoppers;
* Deal Voucher purchasers and recipients;
* Gift Card purchasers and recipients;
* Event Ticket purchasers and attendees;
* Merchants;
* Event Organizers and Hosts;
* Merchant and Organizer staff;
* readers of The Buzz;
* newsletter and waitlist subscribers; and
* people who communicate with Coupian Support.
This Privacy Policy should be read together with the applicable Coupian Terms of Service, Merchant Agreement, Organizer terms, and other terms that apply to the service you use.
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1. WHO WE ARE
Coupian operates a local marketplace that connects Customers with participating businesses, experiences, and Event Organizers.
Coupian provides technology for discovery, purchases, payments, vouchers, Gift Cards, Event Tickets, redemption, admission, and customer support.
Participating Merchants provide the underlying goods and services associated with Deal Vouchers and other Merchant offerings.
Event Organizers are responsible for organizing and providing their Events.
Coupian's legal contact information is:
Coupian [LEGAL ENTITY NAME]
[MAILING ADDRESS]
New York, New York [ZIP CODE]
Email: [PRIVACY EMAIL]
Website: coupian.com
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2. INFORMATION WE COLLECT
The information we collect depends on how you interact with Coupian.
2.1 Account Information
If you create a Coupian Account, we may collect:
* first name;
* last name;
* email address;
* telephone number, if provided;
* postal address;
* geographic coordinates derived from an address where used for Platform functionality;
* selected city or approximate location;
* profile image or avatar;
* password credentials stored in protected form;
* two-factor authentication information;
* referral code;
* information identifying the person who referred you;
* marketing preferences;
* Account status;
* last-login information; and
* information relating to unsuccessful login attempts.
Email verification may be required to activate certain Account functionality.
If telephone verification functionality is enabled, Coupian may also process telephone numbers for verification purposes.
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3. TRANSACTION INFORMATION
When you make or receive a purchase through Coupian, we collect and maintain information relating to the transaction.
This may include:
* orders;
* Deal Vouchers;
* Gift Cards;
* Event Tickets;
* purchase amounts;
* discounts;
* promotional codes;
* service fees;
* transaction dates and times;
* Merchant or Organizer information;
* refunds;
* payment disputes;
* chargebacks;
* settlement information;
* voucher redemption information;
* Ticket usage; and
* related transaction records.
Payment information is processed using third-party payment processors such as Stripe or Square.
Those payment processors receive payment information necessary to process transactions.
Coupian also receives and maintains records necessary to administer the transaction, reconcile payments, process refunds, respond to disputes, and provide customer support.
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4. VOUCHER REDEMPTION INFORMATION
When a Deal Voucher or other Coupian entitlement is redeemed, Coupian may record information including:
* the Voucher involved;
* the date and time of redemption;
* the participating Merchant;
* the Merchant location;
* the staff member who processed the redemption;
* the method used to redeem it;
* Internet Protocol address or technical information associated with the redemption; and
* related audit information.
We use this information to verify that a Voucher was properly redeemed, prevent duplicate or fraudulent redemption, maintain transaction records, assist Customers and Merchants, and resolve disputes.
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5. EVENT AND ATTENDANCE INFORMATION
When you obtain or use an Event Ticket, Coupian may collect information about your Ticket and attendance.
This may include:
* the Event;
* Ticket type;
* Ticket holder;
* purchaser;
* guest-list information;
* Ticket transfer information;
* admission code;
* whether a Ticket was scanned;
* when it was scanned; and
* admission or redemption records.
Event Organizers and authorized Event staff may see information reasonably necessary to administer admission, such as attendee or guest-list names.
5.1 Offline Door Scanning
Coupian may permit authorized Event staff to scan Tickets even where Internet access is temporarily unavailable.
For offline validation, Coupian's system may store a hashed fingerprint derived from Ticket information on the scanning device.
The system is designed so the device does not need to store a collection of raw valid admission codes merely to perform offline verification.
This is intended to reduce the risk that loss of a scanning device would expose usable Tickets.
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6. INFORMATION ABOUT HOW YOU USE COUPIAN
We collect certain information concerning use of the Platform.
This may include:
* pages viewed;
* offers viewed;
* Buzz articles viewed;
* Event pages viewed;
* dates and times of interactions;
* request and network information;
* device and browser information where made available to the Platform;
* approximate location;
* referral information; and
* Platform interaction information.
We use this information to operate Coupian, understand Platform usage, maintain security, improve the service, measure content and offer performance, and perform attribution as described below.
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7. COUPIAN ATTRIBUTION IDENTIFIER
Coupian uses a first-party identifier currently known internally as `cpn_vid`.
This identifier is associated with a random value and may be stored in a cookie on your browser when you visit Coupian, including when you are not logged in.
7.1 Why We Use It
The purpose of this identifier is to determine whether an Event purchase was sourced through Coupian's own discovery surfaces.
This matters because an Event Organizer may elect to participate in Coupian's optional discovery program, under which the Organizer can be charged a promotional fee only when Coupian's own surfaces generated the attributable sale.
The identifier allows Coupian to determine whether such attribution occurred.
7.2 What We Do Not Use It For
Coupian does not use this identifier to build an advertising profile about you across unrelated websites.
Coupian does not provide this identifier to third-party advertisers for behavioral advertising.
Coupian currently does not operate third-party behavioral advertising technology on the Platform.
7.3 Cookie Choices
You may be able to block or delete cookies through your browser settings.
Blocking certain cookies may affect Platform functionality.
Additional information concerning Coupian's cookies and similar technologies will be provided in our Cookie Notice.
Where Coupian provides a cookie or privacy preference control, Coupian intends for the control to accurately reflect and implement the choices presented to you.
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8. LOCATION INFORMATION
Coupian may process location information to provide geographically relevant marketplace functionality.
Location information may come from:
* a postal address you provide;
* geographic coordinates derived from an address;
* a city you select; or
* other approximate location information available through Platform interactions.
Coupian may use this information to:
* display nearby offers;
* organize neighborhood content;
* identify relevant Merchants or Events;
* provide location-based search results; and
* improve marketplace discovery.
Coupian does not currently use third-party advertising networks to sell or target advertising based on your location.
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9. SUPPORT COMMUNICATIONS
If you contact Coupian Support, we may collect and retain:
* your messages;
* email correspondence;
* support requests;
* attachments you provide;
* the complete support conversation;
* information necessary to investigate the issue;
* internal notes created by authorized Coupian personnel; and
* actions taken to resolve the request.
Internal support notes may not be visible to you.
Support communications may contain information concerning purchases, payments, refunds, disputes, Merchant activity, or other Account matters.
Please avoid submitting unnecessary highly sensitive personal information through customer-support communications.
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10. AI-ASSISTED CUSTOMER SUPPORT
Coupian may use artificial-intelligence-assisted technology to help provide customer support.
When you communicate with an AI-assisted Coupian support feature, Coupian may provide the AI service with information necessary to understand and respond to your request.
Depending on your question, that information may include:
* the content of your support conversation;
* relevant Account information;
* Deal Voucher information;
* Gift Card information;
* Event Ticket information;
* expiration information;
* redemption information;
* refund status;
* Merchant or Organizer information;
* commission information for authorized business users;
* payout status for authorized business users; and
* other relevant Coupian Account facts.
Coupian currently uses Anthropic as a third-party AI technology provider for AI-assisted support.
Information submitted to the AI provider is used for the purpose of generating and supporting Coupian's customer-service functionality.
Anthropic's commercial services currently state that commercial API inputs and outputs are not used for model training by default unless the customer affirmatively opts into such use or submits qualifying feedback. Anthropic also currently states that standard API inputs and outputs are generally deleted from its backend within thirty (30) days, subject to contractual, safety, misuse-prevention, and legal exceptions.
These third-party practices may change and are also governed by Coupian's contractual arrangement with the provider.
Coupian should not be understood to guarantee that an AI-generated response is error-free.
You may request human assistance where human escalation is available.
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11. MARKETING AND COMMUNICATION INFORMATION
Coupian may collect information when you:
* subscribe to a newsletter;
* join a pre-launch waitlist;
* request neighborhood launch information;
* opt into marketing communications;
* subscribe to push notifications;
* interact with promotional communications; or
* unsubscribe from marketing.
Newsletter and waitlist information may include:
* email address;
* postal code;
* communication preferences; and
* related signup information.
11.1 Transactional Communications
Coupian may send communications necessary to provide the services you request, including:
* Account verification;
* receipts;
* Vouchers;
* Gift Cards;
* Tickets;
* security messages;
* password resets;
* Event changes;
* refund information;
* payment information; and
* support communications.
These communications are not treated as optional marketing merely because they are delivered by email or another electronic method.
11.2 Marketing Communications
Coupian may send marketing communications where you have opted in or where otherwise permitted by applicable law.
Marketing communications may include:
* neighborhood offers;
* merchant recommendations;
* Event recommendations;
* The Buzz newsletters;
* launch announcements; and
* promotional campaigns.
You may unsubscribe using the method provided in a marketing message.
Coupian maintains suppression information so that an unsubscribe request can continue to be honored.
11.3 Post-Event Messages
Coupian may send an Event attendee a promotional follow-up concerning the Organizer's future Events.
The Platform is designed to send this type of post-Event communication only to people whose Tickets were actually scanned as attended and subject to applicable marketing preferences and unsubscribe controls.
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12. PUSH NOTIFICATIONS
If you choose to enable push notifications, Coupian may receive and maintain a browser or device subscription endpoint and related technical information necessary to deliver the notifications.
Push notifications are optional.
You may disable them through your browser, device, or available Coupian settings.
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13. REVIEWS AND USER CONTENT
If Coupian allows you to submit reviews, ratings, photographs, comments, or similar content, we collect the information you choose to submit.
Reviews may be associated with your Coupian Account or other information necessary to operate the review system.
Coupian may also maintain:
* moderation status;
* reports concerning a review;
* Merchant responses or disputes;
* internal moderation information; and
* records concerning enforcement decisions.
Information you intentionally publish as a review may become visible to other Platform users.
Do not include private information in content that you intend to publish publicly.
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14. THE BUZZ
Coupian publishes editorial content through The Buzz.
We may collect:
* article view counts;
* newsletter subscriptions;
* interactions with Buzz content; and
* other ordinary Platform usage information.
Some Buzz content may be created or edited with artificial-intelligence assistance.
The use of AI to assist Coupian's editorial workflow does not by itself mean that a reader's personal information is submitted to an AI provider.
Where a particular editorial workflow involves personal information, that information will be handled in accordance with this Privacy Policy.
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15. REFERRAL INFORMATION
Coupian may maintain referral codes and information identifying which Account referred another Customer.
We use referral information to:
* operate the referral program;
* determine reward eligibility;
* detect duplicate or fraudulent referrals;
* administer promotional credits; and
* investigate abuse.
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16. MERCHANT AND EVENT ORGANIZER INFORMATION
If you operate a business or Event through Coupian, we may collect information including:
* business name;
* business contact information;
* representative information;
* Merchant or Organizer Account information;
* listings;
* Event information;
* transaction records;
* sales;
* payouts;
* commissions;
* refunds;
* disputes;
* reserves;
* settlement information;
* staff Accounts;
* redemption activity;
* Ticket-scanning activity; and
* communications with Coupian.
Payment processors may separately collect identity-verification, business, beneficial-owner, banking, tax, or other know-your-customer information required to establish or maintain payment-processing services.
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17. MERCHANT AND ORGANIZER STAFF
Merchants and Organizers may create or authorize staff Accounts with limited permissions.
Coupian may collect information concerning:
* the staff member;
* assigned permissions;
* login activity;
* Voucher redemptions;
* Ticket scans;
* refunds or other authorized actions;
* location;
* date and time; and
* related audit records.
These records are used to operate the Platform, attribute actions to authorized users, investigate disputes, detect misuse, and maintain security.
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18. COUPIAN ADMINISTRATIVE ACCESS
Authorized Coupian personnel may have elevated administrative access for legitimate business, security, customer-support, fraud-prevention, and operational purposes.
18.1 “View As User”
Coupian maintains an administrative support feature that may allow authorized personnel to temporarily view portions of the Platform from the perspective of a particular user.
This functionality is intended to help diagnose and resolve customer-support or technical problems.
The system is designed with restrictions that include:
* administrative access is logged;
* the session is visibly identified as administrative impersonation;
* the session automatically expires;
* permissions available during impersonation are restricted;
* designated sensitive Account actions are blocked;
* password changes are blocked;
* two-factor authentication changes are blocked;
* checkout is blocked; and
* certain staff Accounts cannot be targeted through the feature.
Use of this functionality is recorded in Coupian's administrative audit systems.
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19. AUDIT LOGS
Coupian maintains administrative audit records concerning actions performed against important Platform records.
Audit information may relate to:
* Accounts;
* Merchants;
* Organizers;
* offers;
* Events;
* refunds;
* transactions; and
* administrative actions.
Audit records are used for:
* security;
* accountability;
* fraud prevention;
* dispute investigation;
* regulatory compliance;
* internal controls; and
* system integrity.
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20. HOW WE USE PERSONAL INFORMATION
We may use information described in this Privacy Policy to:
Provide the Platform
* create and manage Accounts;
* process purchases;
* issue Deal Vouchers;
* issue and administer Gift Cards;
* issue Event Tickets;
* facilitate Ticket transfers;
* redeem Vouchers;
* validate Event admission;
* process refunds;
* provide Merchant and Organizer tools;
* process or facilitate payments;
* administer settlements and payouts; and
* provide customer support.
Personalize and Improve Coupian
* display geographically relevant businesses and Events;
* provide neighborhood discovery;
* understand Platform usage;
* measure offer and article views;
* improve features;
* diagnose technical problems; and
* develop new Platform functionality.
Attribution
* determine whether Coupian's discovery surfaces generated an Event sale;
* administer optional Organizer discovery programs; and
* calculate associated commercial charges.
Communicate
* send transactional messages;
* send security alerts;
* respond to support requests;
* send marketing communications where permitted;
* operate newsletters;
* administer waitlists;
* deliver push notifications; and
* provide Event-related communications.
Security and Fraud Prevention
* authenticate users;
* protect Accounts;
* detect fraudulent purchases;
* prevent Ticket duplication;
* prevent Voucher abuse;
* prevent promotional or referral abuse;
* investigate chargebacks and disputes;
* detect automated abuse;
* enforce purchase limits; and
* maintain audit records.
Legal and Business Purposes
* enforce Coupian agreements;
* comply with law;
* respond to lawful governmental requests;
* establish, exercise, or defend legal claims;
* maintain financial and business records;
* protect Coupian, Customers, Merchants, Organizers, and others; and
* conduct or evaluate a corporate transaction.
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21. WHEN WE DISCLOSE INFORMATION
Coupian does not disclose personal information merely because another company requests it.
We may disclose information in the circumstances described below.
21.1 Merchants
We provide participating Merchants information reasonably necessary to:
* fulfill a purchase;
* administer a Deal Voucher;
* verify a redemption;
* provide Customer service; or
* resolve a transaction issue.
Merchants may not use Customer information received from Coupian for independent marketing unless they have separately obtained any consent required for that purpose.
21.2 Event Organizers
We may provide Organizers and authorized Event staff information reasonably necessary to:
* administer an Event;
* maintain attendee or guest lists;
* validate Tickets;
* manage admission;
* provide Event-related customer service; or
* respond to Event issues.
21.3 Service Providers
We use third parties to operate portions of the Platform.
Current providers and categories include:
Stripe
Receives information necessary for:
* payment processing;
* connected accounts;
* Merchant verification;
* payouts;
* refunds; and
* payment disputes.
Square
For Square-connected businesses, receives information necessary for:
* payment processing;
* connected Merchant functionality; and
* related payment services.
Anthropic
Receives information provided to Coupian's AI-assisted customer-support feature, which may include support conversation content and relevant Coupian Account facts, for the purpose of producing AI-assisted support responses.
Resend and/or SMTP Providers
May receive:
* email addresses; and
* message content
for transactional and marketing email delivery.
Supabase
Provides application database and related infrastructure and therefore may process information stored in Coupian's application database.
Vercel
Provides hosting and related web infrastructure and may process request and traffic information necessary to operate the Platform.
Google Wallet
May receive information required to create or maintain eligible digital wallet passes when you choose to use that functionality.
Cloudflare Turnstile
May process challenge, device, browser, network, and related signals for bot detection and abuse prevention.
Firebase
If telephone-verification functionality is enabled, Firebase may receive telephone numbers and related information necessary to provide that functionality.
Web Push Infrastructure
Where you enable push notifications, the applicable web-push infrastructure receives device or browser subscription endpoints necessary to deliver those notifications.
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22. NO SALE OF PERSONAL INFORMATION
Coupian does not currently sell personal information to advertisers or data brokers.
Coupian does not currently sell Customer profiles for behavioral advertising.
Coupian does not currently use third-party advertising technology to track users across unrelated websites for targeted advertising.
Coupian's disclosure of information to payment processors, infrastructure providers, communication providers, Merchants, Organizers, and other service providers described in this Privacy Policy is for Platform operation and related business purposes and is not intended as a sale of personal information.
If Coupian materially changes these practices, Coupian will update this Privacy Policy and provide any notice or choice required by applicable law.
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23. LEGAL DISCLOSURES
We may disclose information where we reasonably believe disclosure is necessary to:
* comply with applicable law;
* respond to a subpoena, court order, warrant, or other lawful process;
* respond to legally valid requests from governmental authorities;
* investigate fraud or unlawful activity;
* protect the security of Coupian;
* protect Customers, Merchants, Organizers, or others;
* enforce Coupian agreements; or
* establish, exercise, or defend legal claims.
Where legally permitted and appropriate, Coupian may seek to narrow requests that appear excessive or improper.
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24. BUSINESS TRANSFERS
Information may be disclosed as part of evaluating or completing:
* a merger;
* acquisition;
* financing;
* reorganization;
* investment;
* bankruptcy;
* sale of assets; or
* transfer of all or part of Coupian's business.
Any successor receiving personal information will remain subject to applicable privacy obligations governing that information.
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25. DATA RETENTION
Coupian retains personal information for no longer than reasonably necessary for the purposes for which it is maintained, taking into account:
* the nature of the information;
* the reason it was collected;
* the duration of the Account or business relationship;
* transaction and financial-record obligations;
* refund and chargeback periods;
* fraud-prevention needs;
* Event and Voucher fulfillment;
* security and audit requirements;
* contractual obligations;
* applicable statutes of limitation;
* legal and regulatory requirements; and
* anticipated or actual disputes.
Different categories of information may therefore be retained for different periods.
For example, transaction, settlement, tax, dispute, and financial records may need to be maintained longer than ordinary browsing or temporary technical information.
Coupian may retain information where reasonably necessary to:
* complete an outstanding transaction;
* prevent fraud;
* resolve a dispute;
* comply with law;
* maintain security records; or
* establish or defend legal claims.
When personal information is no longer reasonably necessary, Coupian will take reasonable steps to delete it, anonymize it, or otherwise dispose of it securely, subject to applicable law and technical limitations.
De-identified or aggregated information that can no longer reasonably be associated with an identifiable individual may be maintained for analytical or business purposes.
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26. INFORMATION SECURITY
Coupian uses administrative, technical, and organizational measures intended to protect personal information from unauthorized access, destruction, alteration, misuse, or disclosure.
Depending on the system, measures may include:
* access controls;
* scoped staff permissions;
* authentication controls;
* two-factor authentication functionality;
* audit logging;
* fraud detection;
* bot protection;
* protected password storage;
* limited administrative impersonation permissions;
* rotating Ticket codes;
* hashed offline Ticket fingerprints; and
* security controls maintained by Coupian's infrastructure and payment providers.
Coupian evaluates security controls in light of the nature of the information and the Platform.
No Internet transmission, database, or security system can be guaranteed to be completely secure.
You are responsible for maintaining the security of your Account credentials and should notify Coupian if you suspect unauthorized access.
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27. YOUR PRIVACY CHOICES
Depending on how you use Coupian, you may have the following choices.
27.1 Account Information
You may update certain Account information through available Account settings.
You may also contact Coupian to request correction of inaccurate Account information.
27.2 Marketing Email
You may unsubscribe from marketing emails using the unsubscribe mechanism in those communications.
Coupian may retain sufficient suppression information to ensure that marketing messages remain disabled.
Unsubscribing from marketing does not prevent necessary transactional or security communications.
27.3 Push Notifications
You may disable push notifications using your browser, device, or applicable Coupian settings.
27.4 Cookies
You may use browser controls to block or delete certain cookies.
Additional choices may be described in Coupian's Cookie Notice or cookie controls.
27.5 Location Information
You may control certain location-related functionality by changing the information supplied to Coupian or using available device, browser, or Account settings.
27.6 Account Deletion
You may request deletion of your Coupian Account by contacting Coupian at [PRIVACY EMAIL / ACCOUNT DELETION METHOD].
Deletion is subject to information Coupian must or is permitted to retain for transactions, fraud prevention, financial records, legal compliance, disputes, security, and other legitimate purposes described in this Privacy Policy.
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28. PRIVACY REQUESTS
Depending on applicable law and your relationship with Coupian, you may request that Coupian:
* provide information about personal information Coupian maintains about you;
* correct inaccurate personal information;
* delete eligible personal information;
* provide a copy of certain information; or
* explain certain uses or disclosures of your information.
To make a request, contact:
[PRIVACY EMAIL]
Coupian may need to verify your identity before completing a privacy request.
Verification may require information reasonably necessary to confirm that the request concerns your information.
Coupian will not discriminate against a person for exercising a privacy right provided by applicable law.
Certain information may be exempt from a request where retention is necessary or permitted for:
* transactions;
* legal compliance;
* fraud prevention;
* security;
* accounting;
* dispute resolution;
* legal claims; or
* another applicable exception.
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29. CHILDREN AND TEENAGERS
Coupian is a general-audience marketplace and is not designed for children under thirteen (13).
Coupian does not knowingly permit a child under thirteen to create a purchasing Account or knowingly collect personal information from a child under thirteen in circumstances requiring parental consent without complying with applicable law.
If Coupian learns that personal information was collected from a child under thirteen in violation of applicable law, Coupian will take appropriate steps to delete or otherwise lawfully handle that information.
A parent or guardian who believes a child under thirteen has provided personal information to Coupian may contact us at:
[PRIVACY EMAIL]
29.1 New York Users Under 18
New York law provides additional protections for personal data of covered users under eighteen years of age.
Where Coupian has actual knowledge that a New York user is under eighteen, Coupian will process that user's personal information in accordance with applicable requirements, including restrictions applicable to processing that is not strictly necessary to provide or maintain a requested service unless legally valid consent or another lawful basis applies.
Coupian's intended launch policy is that an individual must be at least eighteen (18) years old to create a purchasing Account or transact through the Platform.
Age-restricted Events may impose higher age requirements, including twenty-one (21) or older.
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30. THIRD-PARTY LINKS AND SERVICES
The Platform may contain links to websites or services operated by Merchants, Organizers, venues, social networks, payment providers, or other third parties.
This Privacy Policy does not govern information a third party independently collects outside Coupian's Platform.
Review the applicable third party's privacy policy before providing information directly to it.
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31. DIGITAL WALLETS
If you choose to add a Voucher, Ticket, or other eligible pass to a third-party digital wallet such as Google Wallet, information necessary to provide the pass may be transmitted to the wallet provider.
The wallet provider's independent privacy terms apply to its processing of information after the information is provided to that service.
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32. CHANGES TO THIS PRIVACY POLICY
Coupian may update this Privacy Policy from time to time to reflect:
* changes to the Platform;
* new features;
* changes in vendors;
* changes in data practices;
* changes in law; or
* other operational developments.
Coupian will update the Last Updated date when this Privacy Policy changes.
Where required by law, Coupian will provide additional notice or obtain consent before a material change takes effect.
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33. CONTACT COUPIAN
Questions, requests, or concerns about privacy may be sent to:
Coupian [LEGAL ENTITY NAME]
Attn: Privacy
[MAILING ADDRESS]
New York, New York [ZIP CODE]
Email: [PRIVACY EMAIL]
Website: coupian.com
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34. NEW YORK SECURITY AND PRIVACY NOTICE
Coupian maintains security practices intended to protect the confidentiality and integrity of information maintained through the Platform.
Where applicable, Coupian's security program will include administrative, technical, and physical safeguards reasonably appropriate to Coupian's operations and the information maintained.
Coupian will provide notifications concerning qualifying security incidents where required by applicable law.
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35. EFFECTIVE DATE
This Privacy Policy becomes effective on:
August 22, 2026
and applies to Coupian's information practices from that date forward.