PRIVACY POLICY

BACKGROUND

Cardeeo, Inc. ("we", "us", "our") provides a digital platform for retailers to mobilize their loyalty programs and for LoyalTree members to access and utilize retail loyalty programs. This Privacy Policy explains how we treat information you provide to us.

ACCEPTANCE OF TERMS

By using our website and/or our application(s) (the "Program"), you consent to the collection and use of your information by us in accordance with this Privacy Policy and further consent to have your personal data transferred to and processed in the United States.

If we change our Privacy Policy, we will post the modified privacy policy on this page and revise the "Last Updated" date above. Policy changes will apply to information collected after the date of the change.

HOW WE TREAT INFORMATION WE RECEIVE FROM YOU

We gather broad demographic information about our members ("Members"), specific information associated with how our Members use the Program features and functionality, and other information you provide to us directly or in connection with your use of the Program. We only collect personally-identifiable information from you if you provide it to us via registering as a Member or participating in or utilizing Program features and functionality. We may automatically record your IP address, use cookies and/or create log files or other functionality to help us recognize you, confirm your registration, track your activities and preferences, and maintain and improve the Program. Third party advertisers may also use cookies to track their advertisements. You can turn off cookies, but if you turn cookies off, you won't have access to certain Program features and some of our services may not function properly.

We use your information to personalize your experience, analyze type and frequency of use and trends, respond to inquiries from you, notify you about new features and special promotions, and support your use of the Program and its functionality. We may collect and report general demographic information about our Members to third parties. The general demographic information will not, however, specifically identify you.

Enrollment into a retail loyalty program through the website and/or application is subject to your direct consent and all personally-identifiable information provided will become available for use by elected, and only elected, retailers subject to their individual Terms of Use and Privacy Policy.

GENERAL

We may release your information when we believe release is appropriate to comply with the law, enforce the Program policies, or protect ours or others' rights, property, or safety. It is our policy to comply with any such requirements, and you agree we shall have no liability for any such disclosure. We may also securely communicate your information to law enforcement agencies solely in connection with, and restricted to, their assistance in preventing or assessing fraudulent and/or unlawful transactions via the Program.

YOUR PRIVACY SETTINGS

When you set up your Program profile, you will have the ability to choose and change your privacy settings. Even though you may opt out of certain Program features or disclosure of your information, we reserve the right to send you notices regarding your account. You can correct or update your Program profile through the application or by logging on and going to www.loyaltree.com.

[Opt-Out: We will not share your personally identifiable information with third parties for their direct marketing purposes unless you agree to such disclosure (via direct agreement to such disclosure or your request to receive information from a third party that is selling goods or services or otherwise participating in an activity in connection with the Program). You can contact us to opt–out of receive marketing communications from third parties, and we will use commercially reasonable efforts to promptly accommodate any requests you make to opt–out of receiving certain communications. Notwithstanding the above, we reserve the right to disclose (on a confidential basis) and/or transfer your personally-identifiable information to our affiliates, or to a third party in connection with the sale of all or substantially all of our stock or assets.]

SECURITY

We follow generally accepted industry security standards to safeguard and help prevent unauthorized access, maintain data security and correctly use personal information. However, no commercial method of information transfer over the Internet or electronic data storage is 100% secure, and we cannot guarantee the absolute security of that information during its transmission or its storage in our systems, and you agree to release us from any liability related in any way to such information. We reserve the right to take any action with respect to your use of the Program, including, but not limited to, termination of your Membership and rights of use. Any user identification names or passwords necessary to access the Program shall be maintained by you as confidential and should not be shared with anyone not authorized to have access to your personally–identifiable information.

THIRD-PARTY LINKS AND THIRD PARTY SOFTWARE

This Privacy Policy applies solely to information collected by our Program. Any third-party links and applications in or on our Program (including, without limitation, all retailer links and applications) are subject to such third party's separate and independent privacy policies and terms of use, and we have no responsibility or liability for the content and activities of such linked sites or applications. Notwithstanding the above, we welcome any feedback about these linked sites and applications. We recommend that you review all applicable third party privacy policies before you disclose personal information.

YOUR CALIFORNIA PRIVACY RIGHTS

Under California's "Shine the Light" law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us, once per calendar year, information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year.

To obtain this information from us, please send an email message to info@cardeeo.com with "Request for California Privacy Information" on the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response. Not all information sharing is covered by the "Shine the Light" requirements so only covered information sharing will be included in our response.

COPPA

Pursuant to the terms of the Children's Online Privacy Protection Act (COPPA), we do not knowingly collect personally-identifiable information from children under the age of thirteen (13). The Program is not directed at children under the age of thirteen (13), and by using the Program and/or registering as a Member, you represent that you are not under the age of thirteen (13). Parents or legal guardians may not agree to the Terms of Use, this Privacy Policy, or the disclosure of such child's personally-identifiable information on such child's behalf.

CONTACT US

Please contact us at info@cardeeo.com if you have questions regarding the Privacy Policy or the Program.

Consent To Processing Of Information In The United States

[Notwithstanding your country of origin, or country, state and/or province of residence, by utilizing the Program and/or directly providing personal information to us, you hereby agree to and acknowledge your understanding of the terms of this Privacy Policy, and consent to have your personal data transferred to and processed in the United States and/or in other jurisdictions as we determine. ]