Privacy Policy

CLYNK Privacy Policy

LAST UPDATED: February 24, 2026

PLEASE READ THIS PRIVACY POLICY CAREFULLY

This Privacy Policy describes how Count & Crush, LLC d/b/a CLYNK and its affiliates and subsidiaries (collectively, ’CLYNK,’ ’we,’ ’us,’ and ’our’) collects, processes, and shares your personal information, and the choices that are available to you with respect to your personal information.’ This Privacy Policy applies to the personal information we collect whenever you interact with us, whether those interactions are online ’ for example, when you use any of our websites, including www.clynk.com and ct.clynk.com (referred to individually and collectively as the ’Website’), use our mobile application (the ’App’), or use our kiosks or other CLYNK hardware or software, in each case, only to the extent the Website, App, or hardware or software link or point to this Privacy Policy (all of the foregoing referred to collectively herein as the ’Platform’), or when you communicate with us via email, click on our digital advertisements, or scan our QR codes. This Privacy Policy also applies to the personal information we collect offline, for example, when you communicate with our customer service teams by phone or postal mail, and that we obtain from third-party sources. In this Privacy Policy, we refer to the services we provide both online and offline as ’Services’. If you do not agree with this Privacy Policy, please do not use our Platform or Services.

We may revise this Privacy Policy periodically, and in such a case we will revise the date at the top of this Privacy Policy accordingly. Changes to this Privacy Policy are effective at the time they are published, and therefore we encourage you to review this Privacy Policy from time to time. Additionally, this Privacy Policy may be supplemented or amended from time to time by other notices posted elsewhere, including on specific pages of our Website, in our App, at our kiosks and facilities, or in our published materials.

1. Personal Information We Collect

The personal information we collect depends on how you interact with us, and may include some or all of the following categories of information:

• Contact Information and Other Identifiers: We will collect your name and contact information, including your postal address, telephone number, and email address, as well as your vehicle license plate number, if you provide it to us, including when you create an account on our Platform.
• Device Information: When you visit our Platform, interact with our digital advertisements or scan our QR codes, or open our emails, we may learn information about your browser or device (e.g., name or type, version, settings, etc.), IP address, unique online identifiers (e.g., MAC address, mobile device identifiers, etc.), internet service provider, the name and version of your operating system, referring and exit pages, and the date and time of your visit.
• Usage Data: We may collect information about your interactions with our Platform, digital advertisements, QR codes, and emails, including the pages you visit, links or buttons you click, the search terms you enter, and similar information.
• Location Data: We may infer your non-precise geographic location from your device’s IP address or similar device information collected when you visit our Platform, interact with our digital advertisements, scan our QR codes, or open our emails.’ We may also collect precise geolocation information; for more information about our collection of precise geolocation information, please see the How We Collect Your Personal Information > Mobile Location Information section below.
• Financial Account Information and Payment Details: We collect your financial account information and other payment details when you provide them as part of our Services.
• Transactional and Commercial Data: We keep track of your transactional history with us, including the types and quantity of bottles and cans you return to us and the amount of associated redemption payments, and the organizations to which you choose to direct your deposit proceeds (if any).’ We may also collect other commercial information about products or services that you have used, purchased, or considered.
• Records of Communications: If you call or email our customer service representatives (or other agents or representatives of CLYNK) or reach out to us via a social media platform, we may keep records of those conversations including any information you have provided to us in connection with such conversations.
• Submitted Content: We collect any content you submit to us, including via the Website, the App, our social media pages, email, or postal mail, such as photos, videos, testimonials, and feedback.
• Demographic Information: We may collect demographic details about you such as your age, including your month and year of birth.
• Account Credentials: If you register an account on our Platform, we collect your account credentials, including your account log-in name and password.
• Video Recordings: We use video cameras (i.e., CCTV) in and around our redemption facilities for security purposes and to prevent fraud, theft, and vandalism.
• Inferences: We may draw inferences about any of the information above that may relate to your preferences, characteristics, or other matters.

CLYNK may also de-identify or aggregate the above information, at which time it is no longer ’personal information.’’ We will not reidentify or attempt to reidentify such information unless permitted by applicable law.

2. How We Collect Your Personal Information

We may collect the information described above from various sources, including directly from you, from third parties we partner with, and through cookies or other automated means.

• Directly from You:We collect information directly from you when you provide it to us, including when you create a CLYNK account; redeem your bottles and cans; contact us with questions or comments via email, phone, postal mail, or on our social media pages; fill out and submit any webforms on our Platform, or otherwise upload Submitted Content to our Platform (or submit it via email, postal mail, or social media); enter our contests, sweepstakes, or other promotions; or respond to a survey or other request for feedback.
• Automatically from Your Device or Browser: Certain information (e.g., Device Information and Usage Data) may be automatically collected from your device or browser when you interact with our Platform, open our emails, or click on our digital advertisements or scan our QR codes.
• CLYNK Kiosks: We may collect your personal information via technology we use in our facilities, including, for example, our in-store cameras for security and operational purposes. These cameras may capture images of you as part of check out, to help deter theft, or improve store design to better serve our customers.
• From Third-Party Service Providers and Business Partners: Third parties, including data analytics companies, IT service providers,’ marketing companies, commercial data providers, shipping and delivery companies, email service providers, and companies that assist with the operation and functionality of our Platform and our business more generally, may share information they have collected from or about you with us. We may also obtain personal information about you from third-party commercial data providers.
• Using Cookies and Similar Technologies: CLYNK uses cookies (small files stored on your device or browser),’ and other similar technologies to automatically collect information when you visit our Platform or interact with our emails, including, for example, Device Information, Usage Data, and Location Data. Through the use of cookies and similar technologies, we may link information about your interactions with our Platform, emails, digital advertisements, and QR codes over time, like which pages you visit, which links or buttons you click, and how long you stay on each page.
• Mobile Location Information:’ If you use a mobile device, with your consent, your device may share location information (when you enable location services) with our Platform. For example, either precise or imprecise geolocation information (e.g., a GPS signal) can be used to help you find nearby CLYNK facilities, and our use of your device’s Bluetooth signal (or other similar technologies) will permit CLYNK to recognize the location of your mobile device near our facilities. To manage your device’s location settings, go to the Your Privacy Choices section of this Privacy Policy.

’ Cameras: As noted above, we use cameras in and around our facilities for fraud detection, theft prevention and security.

’ Information from Other Sources: We may collect information about you from other sources, including from publicly available sources and from third-party commercial data providers, to enhance our existing customer database and improve the accuracy of our records.

3. How We Use Your Personal Information

How we use the personal information we collect depends on how you interact with us, and may include the following purposes:

• Perform Redemption Services: We use your personal information to perform our redemption services, including, for example, to process your bottles and cans, add redemption funds to your CLYNK account, and donate your redemption funds to the organization of your choice.

• CLYNK Accounts: We use your personal information to operate CLYNK accounts, including by making certain services available and offering rewards or special promotions to our account users.
• Communications: We use your personal information to communicate with you, including to respond to your customer service inquiries and other requests for information, and to ask for feedback through surveys, testimonials, or other messages.
• Advertising and Marketing: We may use your personal information to advertise and market our Services online, via email and direct mail, and through other communication channels, including through partnerships with social media platforms and internet search engines.

Feedback and Reviews.’If you choose to provide feedback, testimonials, or other materials to us, we may use such content and materials for advertising and marketing purposes and to help us improve our Services, and to develop new products and services.’

• Understanding Our Customers and Improving our Platform and Services: We may use your personal information to analyze your activity with us (including your interactions with our Platform, emails, digital advertisements, or other forms of communication). For example, we may keep track of the pages of our Website that you visit, or the manner in which you use the App or our kiosks, in order to determine whether to make changes to our Platform or Services, or develop new Services. We may also use your information and the information of other customers (including information about the bottles and cans redeemed) to help us analyze trends, purchasing patterns and preferences, and demographics. We may create and publish industry or market reports or other products (e.g., reports that analyze consumer consumption trends) using this information, but such reports will include only de-identified or aggregated information.
• Personalization and Recommendations: We may use your personal information to personalize your experience when using our Platform and make recommendations about products and promotions that we believe you may be interested in.
• Promotions: We may use your personal information to run contests, sweepstakes, or other promotions.
• Security: We use your personal information to protect CLYNK, our business partners, and our customers from fraud, security threats, and other illegal or harmful activity.
• Legal Obligations: We use your personal information to comply with legal and regulatory requirements, including those of our customers and business partners, and to respond to requests from courts or other governmental or regulatory authorities.

4. How We Share Personal Information with Third Parties

We may share information with third parties for certain purposes. For example, we may share information with:

• Service Providers: We partner with third-party service providers (which may include CLYNK affiliate companies) to assist with many aspects of our business, including payment processing, IT and cloud services, analyzing our Platform users’ interests and activities and consumer trends, marketing services, providing certain functionalities on our Platform, helping us communicate with our customers, and operating our business more generally, and we may share your personal information with these service providers in connection with the provision of their services.’
• Business Partners: We may disclose your personal information to businesses that we have partnered with to jointly offer a product, service, or promotion (e.g., a grocery or department store or redemption center where our kiosks and facilities are located). We disclose such information for regulatory reporting purposes or with your consent (e.g., ’if you agree to link your CLYNK account with a loyalty or rewards program of a CLYNK business partner). We may also share your personal information with business partners, such as market research and information companies, that are interested in understanding consumers’ purchasing patterns and preferences and that may create datasets, perform market research, or create business intelligence or information products that analyze and monitor consumer trends, or with business partners that wish to market their own or other businesses’ products and services to you. The use and sharing of your information by our business partners is not governed by this Privacy Policy but by their own respective privacy policies.’

• Successors: We may transfer your information in connection with the potential or actual sale, lease, license, assignment, acquisition, merger, reorganization or change of control of CLYNK, in whole or in part, or as part of a bankruptcy proceeding.

• Other Third Parties: We will disclose information about you to third parties, including to government bodies or law enforcement agencies, when we believe it to be necessary for compliance with the law or regulatory requirements, or to protect CLYNK, our customers, our employees, or the public more generally.’ For example we may disclose specific personal information if we reasonably believe it is necessary to: (i) comply with regulatory reporting requirements applicable to CLYNK or its customers; (ii) investigate any suspected fraud or misuse of the Platform; (iii) protect or defend the rights, property, or interests of CLYNK, our employees, our customers, or the rights, property, or interests of our business partners or service providers; or (iv) protect the personal safety of our employees, customers, or the public.
• At Your Request: We will disclose information about you to other third parties at your direction or with your consent.

5. Your Privacy Choices

• User requests:You can contact us at any time via email at [email protected] to request we do any of the following: (i) delete all or some of your personal information; (ii) change, update, or correct your personal information; (iii) restrict how we use all or some of your personal information; (iv) access your personal information and, where applicable and feasible, request to receive that personal information in a commonly used electronic format (or ask for this information to be provided in that format to a third party); or (v) disclose what personal information we collect, use, or disclose. You may also request that we stop sharing your personal information with third parties for certain purposes. We will consider and respond to any such requests promptly, and otherwise in accordance with applicable laws.
• Emails: You can unsubscribe from our marketing emails by clicking the unsubscribe link in the footer of such email.
• Direct Mail:You canrequest that we remove you from our direct mail mailing list by emailing us at [email protected].
• Cookies:

Browser and Industry Opt-Outs.You may opt out of certain third-party cookies by following your browser’s instructions. Please note that if you opt out of our cookies, you may experience some inconvenience in your use of the Website.

’ ’Do Not Track’ Signals: Do Not Track (’DNT’) is a privacy preference that you can set in your web browsers, which allows you to opt out of tracking by websites and online services. Like many websites, we do not currently respond to ’Do Not Track’ browser settings or signals. For more information about DNT, please see www.eff.org/issues/do-not-track.

6. Your Privacy Rights

Depending on your location and applicable laws and regulations, you may also have data privacy rights regarding CLYNK’s processing of your personal information. Based on the legal requirements applicable to your jurisdiction, and subject to any legal restrictions or exceptions, you may have the choices and rights described below.

• Right to Access.You may request access to the personal information we hold about you. This may include the right to be informed about the categories and specific pieces of personal information we have collected, the sources from which we collected it, the purposes for collecting it, and the third parties with whom we have shared it.
• Right to Correct. You may request that we correct any inaccurate personal information relating to you without undue delay. In this context, taking into account the purposes of the processing, you may also have the right to request the completion of incomplete personal information.
• Right to Delete. You may request the deletion of your personal information, subject to certain exceptions. In certain circumstances, it may not be possible for us to accept your request, for example, when the processing is necessary to comply with a legal obligation, or if the processing is necessary for the performance of a contract.
• Right to Portability. You may request that we provide you with a copy of your personal information in a structured, commonly used, and machine-readable format. You also have the right to request that we transfer this information to another data controller, where technically feasible.
• Right to Opt Out of Sale.You may direct us not to sell your personal information with third parties. CLYNK does not sell personal information as this term is defined under applicable privacy laws. Therefore, we do not offer such a right.
• Right to Opt Out ofTargeted Advertising.You may request that we not disclose, disseminate, or transfer your personal information to a third party for targeted advertising (also known as ’cross-context behavioral advertising’). CLYNK does not disclose personal information for cross-contextual behavioral advertising purposes. Therefore, we do not offer such a right.
• Right to Restriction of Processing. You may request that we restrict processing of your personal information. In certain circumstances, it may not be possible for us to accept your request, for example, when the processing is necessary to comply with a legal obligation, or if we can demonstrate compelling legitimate grounds otherwise.
• Right to Opt Out of Certain Data Processing. You may withdraw your consent that you have previously provided for CLYNK’s collection, use or disclosure of your personal information, subject to reasonable notice and any contractual or legal exceptions. Note that this will not affect the lawfulness of our processing of your personal information based on consent before its withdrawal.
• Right to Opt Out of Automated Individual Decision-Making. You may have the right to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. Note that this right shall not apply if such a decision is necessary as part of a contract we have with or want to conclude with you, we have your consent, or we are permitted by law to engage in such automated decision making. In these cases, we will implement measures to safeguard your rights and freedoms and legitimate interests, and you may contest the decision by contacting us as set forth below.
• Right Against Discrimination. You have the right not to be discriminated against for exercising any of your data protection rights. This means that we will not deny you goods or services, charge you different prices or rates, or provide you with a different level or quality of goods or services based solely on your exercise of these rights.
• Right to Appeal.Depending on your residency, you may have the right to appeal if we decline to act regarding your privacy request. To do so, please follow the instructions for exercising your privacy rights below, or use the contact information provided in this Privacy Policy.

Residents of California may also have additional rights pertaining to their personal information, as described in the “California Privacy Rights’ section below.

7. Exercising Your Privacy Rights

To exercise any of the rights outlined above, please contact us using the contact information provided below.

To ensure the security and confidentiality of your personal information, we have established verification measures that must be completed prior to fulfilling certain requests to exercise your privacy rights. These measures may involve confirming your identity through a series of questions or requiring documentation that substantiates your identity or authority to make the request. Should we be unable to verify your identity or authority adequately, we reserve the right to decline the request and will provide an explanation for our decision. Upon receiving a verified request to exercise your data rights, we will acknowledge receipt of the request. We will aim to respond substantively to your request within time permitted under the applicable law. If we require more time to process your request, we will inform you of the reason and extend the period by the notified number of days.

Please note that not all requests will be granted. Certain legal exceptions may apply, such as if we are unable to verify your identity, or if there are legal or contractual reasons that prevent us from fulfilling a deletion request. Regardless of the outcome, you will receive a written response that either details the actions we took or explains why no action was possible. If you are dissatisfied with our initial response, you may seek further review. To initiate an appeal, please contact us within 30 days of receiving our initial response using the method provided in the response. You should include a copy of your original request, our response, and a detailed explanation of why you are seeking reconsideration. You may also attach any additional supporting information and documents that you believe are relevant. We will review your appeal and provide a final determination within 60 days.

8. Children

We do not knowingly or purposefully request or collect personal information from any person under the age of 13. If you believe that your child under the age of 13 has submitted personal information to CLYNK, please contact us at [email protected].

9. Security

Although we use reasonable safeguards to protect your personal information, we cannot guarantee the security of information provided over the Internet or stored in our databases. Your transmissions are, therefore, at your own risk. You can help protect your information by selecting strong, unique passwords for your account on CLYNK Website and any associated email addresses.

10. Retention

We will retain your personal information for the length of time needed to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. To determine the appropriate retention period for personal information, we consider (i) the amount, nature, and sensitivity of the personal information; (ii) the potential risk of harm from unauthorized use or disclosure of your personal information; (iii) the purposes for which we process your personal information and whether we can achieve those purposes through other means; and (iv) the applicable legal requirements related to our processing activities. Additionally, we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

11. Links to Other Websites; Social Media Platforms

Our Website and App may, from time to time, contain links to websites and applications owned and operated by third parties (’Third-Party Platforms’). We encourage you to review the privacy policies of such Third-Party Platforms so that you understand how those websites and applications collect, use, and share your information. We are not responsible for the privacy policies or other content on Third-Party Platforms.

If you engage or communicate with CLYNK on a social media platform (e.g., Instagram, Facebook, Pinterest, TikTok, etc.), we may contact you via direct message or use other social media tools to interact with you. In these instances, your communications and interactions with us are governed by this Privacy Policy as well as the privacy policy of the social media platform you use.

12. California Privacy Rights

This section is tailored to meet the specific requirements imposed by California law. While this section outlines state-specific rights for California residents, the preceding sections of this Privacy Policy also apply to them.

(a) Additional
Notice to California Residents

California law requires us to disclose the following additional information with respect to our privacy practices. If you are a California resident, this section applies to you in addition to the rest of the Privacy Policy.

Description of Information Practices Regarding CCPA-Defined Categories of Personal Information
Category	Examples	Collected	Disclosed for a Business Purpose	Shared for Cross-Context Behavioral Advertising
Identifiers	A real name, alias, postal address, unique personal identifier (e.g., employee ID), online identifier, Internet Protocol address, email address, driver’s license number, vehicle license plate number, passport number or other similar identifiers.	✔	✔
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code ’ 1798.80(e))	A name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	✔	✔
Protected classification characteristics under California or federal law	Age (40 years or older), citizenship, marital status.	✔	✔
Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	✔	✔
Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Internet or other similar network activity	Browsing history, information on a consumer’s interaction with a website, application, or advertisement.	✔	✔
Geolocation data	Physical location or movement.	✔	✔
Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	✔	✔
Professional or employment-related information	Current or past job history or performance evaluations.
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	✔	✔
Sensitive Information	Government identifiers (social security, driver’s license, state identification card, or passport number); complete account access credentials (usernames, account numbers, or card numbers combined with required access/security code or password); precise geolocation; racial or ethnic origin; mail, email, or text message contents; genetic data; data concerning health, sex life or sexual orientation.	✔	✔

For a comprehensive understanding of the types of personal information we collect, the sources from which we collect it, and the purposes for which we use it, please refer to the ’Personal Information We Collect’ and ’How We Use Your Personal Information’ sections of this Privacy Policy.

(b) California-Specific
Privacy Rights

California law grants specific rights to California consumers regarding their personal information. Note that these may be duplicative of the rights described above in ’Your Privacy Rights’. They are as follows:

• Right to Know. You can request, up to two times each year, that we disclose the categories and/or specific pieces of personal information that we collect, use, disclose, and may sell, the sources from which we collected it, the purposes for collecting, selling, or sharing it, as applicable, and the categories of third parties to whom we have disclosed it.
• Right to Correction of Personal Information. You have the right to have inaccurate personal information corrected.
• Right to Deletion of Personal Information. You can ask us to delete the personal information that we have collected from you, subject to certain exceptions such as to complete a transaction for you, to exercise our rights, or to comply with a legal obligation.
• Right to Opt Out of Sales of Personal Information. You have the right opt out of the sale of your personal information to third parties. In the preceding twelve (12) months, CLYNK has not ’sold’ personal information as this term is defined in the CCPA. Therefore, we do not offer such a right.
• Right to Opt Out of Sharing of Personal Information. The CCPA defines ’sharing’ as disclosing or making a consumer’s personal information available to a third party for cross-context behavioral advertising. In the preceding twelve (12) months, CLYNK has not ’shared’ personal information as this term is defined in the CCPA. Therefore, we do not offer such a right.
• Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to direct us to limit our use of your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer.’ CLYNK does not use sensitive personal information beyond the CCPA’s permissible purposes.’
• Right against Discrimination. You are entitled to exercise the rights described above free from retaliation as prohibited by the CCPA.
• Right to Appeal. If we deny your request to exercise a right, you have the right to appeal our decision.

To exercise your California privacy rights,pleaseuse the contact methods described below. We may request specific information from you to help us confirm your identity and your rights. We will respond to your request within a reasonable period (if properly submitted) and in accordance with applicable law. If we need more time to verify your identity, process and respond to your request, we will notify you of that fact along with the reason for the delay. If we decline to act regarding your request, we will inform you of our decision and the reason for it, and, if applicable, with instructions on how you may appeal our decision.

You have the option to designate an authorized agent to submit requests on your behalf for exercising your data rights. An authorized agent can be either a person or a business entity that you have formally authorized to act on your behalf.

To use an authorized agent:

1. Signed Authorization: You must provide the authorized agent with a signed written authorization to act on your behalf. This document should clearly indicate that you grant them the authority to submit requests for you.
2. Agent Submission: The authorized agent can then submit a request via the methods outlined above. The agent should attach a copy of the written authorization you provided.
3. Identity Verification: We may contact you directly to confirm that you have authorized the agent to act on your behalf. This is a security measure designed to protect your personal information.

Please note that we reserve the right to deny requests from agents who do not provide proof of authorization or if we cannot verify the agent’s identity.

13. Contact Us

We welcome your comments and questions. Please contact us by email at [email protected], by phone at 1-888-991-1535, or by mail at the following address:

Count & Crush, LLC d/b/a CLYNK

Phone: 888-991-1535
Email:  [email protected]
Mail:    Count & Crush, LLC d/b/a CLYNK
             100 Waterman Drive, Suite 301
             South Portland, Maine 04106