We at TruCentive, Inc. (“TruCentive” or “we”) know you care about how your personal information is used and shared, and we take your privacy seriously. This Privacy Policy (the “Privacy Policy”) covers our treatment of personally identifiable information that we gather when you are accessing or using our website or Services. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you consent that we will collect, use, and share your information in the ways described below. Remember that your use of the Services is at all times subject to the TruCentive Terms of Use, which incorporate this Privacy Policy; any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use: www.TruCentive.com/Terms_of_Use

We respect your privacy

TruCentive, Inc. Privacy Policy

Effective date: January 1, 2019

We at TruCentive, Inc. (“TruCentive” or “we”) know you care about how your personal information is used and shared, and we take your privacy seriously. This Privacy Policy (the “Privacy Policy”) covers our treatment of personally identifiable information that we gather when you are accessing or using our website or Services. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you consent that we will collect, use, and share your information in the ways described below. Remember that your use of the Services is at all times subject to the TruCentive Terms of Use, which incorporate this Privacy Policy; any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use: www.TruCentive.com/Terms_of_Use

1. Information Covered by the Policy. “Personal Information” as used in the policy means any information relating to an identified or identifiable natural person or a combination of information that can be used to identify, contact or locate a specific person. This Privacy Policy does not apply to the practices of companies we don’t own or control, or people that we don’t manage (including Merchants and our licensees who are the Purchasers of the Instruments we deliver); you should look to the privacy policies of those people or entities to learn how they process their Personal Information. We gather various types of Personal Information from our users, as explained in more detail below, and we use this Personal Information internally in connection with our Services, including to personalize, provide, and improve our services, to allow you to set up a user account and profile and to contact you, to fulfill your requests for certain products and services, and to analyze how you use the Services. In certain cases, we may also share some Personal Information with third parties as described below. As noted in the Terms of Use, we do not knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us personal information, please contact us at support@trucentive.com.

2. Collection of Information you Provide to Us. We receive and store any information you knowingly provide to us. This can occur when you fill out applications, create accounts, complete a purchase, add money to your account, take surveys, click links or fill in various online fields on our website. For example, through the registration process and/or through your account settings, we may collect Personal Information such as your name, e-mail address, billing and payment details, phone number and third-party account credentials (for example, your log-in credentials for social networking or other third-party sites). You do not have to provide us with your Personal Information, but if you choose not to disclose certain information we might not be able to provide you with certain services or features. If you provide your third-party account credentials to us or otherwise sign in to the Services through a third-party site or service, you understand some content and/or information in those accounts (“Third-party Account Information”) may be transmitted into your account with us, and that Third-party Account Information transmitted to our Services is covered by this Privacy Policy; for example, your Facebook account information may be imported into your TruCentive account and vice versa.

We may communicate with you if you have provided us the means to do so. For example, if you have given us your e-mail address, we may send you promotional e-mail offers on behalf of our business or other businesses, or e-mail you about your use of the Services. We may also deliver Instruments via other communication methods, including text messages. Subject to the terms of the TruCentive SMS Terms and Conditions (https://trucentive.com/sms_terms_and_conditions), TruCentive may send marketing messages on its own behalf or behalf of other businesses via text message, as well as non-marketing messages via text, for example, to deliver Instruments and messages regarding your use of such Instruments. For additional information about TruCentive’s sending of text messages, and about how you may opt in to receive marketing text messages from our licensees or Merchants in connection with the Services, please see the SMS Terms and Conditions.

Also, we may receive a confirmation when you open an e-mail or receive a text message from us. This confirmation helps us make our communications with you more interesting and improve our services. If you do not want to receive communications from us via e-mail, please indicate your preference by contacting us at support@trucentive.com or by clicking “unsubscribe” at the bottom of any e-mail. If you do not want to receive any further marketing communications from TruCentive or our licensees or Merchants via text message, please follow the directions for opting out within the TruCentive or licensee/Merchant text message, as further described in our SMS Terms and Conditions. You may also respond “STOP” to a non-marketing text message sent by TruCentive, our licensees or Merchants in order to stop receiving such messages.

3. Collection of Information Provided to Us by a Merchant or Friend. Additionally, we may receive information about you from licensees, Merchants and other users of TruCentive via the Services (“Friend-Provided Information”). For example, your employer or friend may provide us with your name and e-mail address and/or text number in order for us to deliver an envelope with an Instrument, e-mail and/or text to you. We use Friend-Provided Information in accordance with this Privacy Policy in the same manner we use Personal Information that a user provides us about himself or herself. If you provide information to TruCentive about your friend or another third party, you represent and warrant that you have all rights to do so and to permit us to contact that friend as set forth in this Privacy Policy, including the right to send him or her e-mails and contact him or her at the addresses you provide to us. If we have received Friend-Provided Information about you, you understand that we will use such information in accordance with this Privacy Policy, our SMS Terms and Conditions and applicable laws in the same manner as if you had provided that information to us yourself, and you hereby consent to any such use.

4. Collection of Information Provided to Us Automatically. Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device, which may include your IP address, device identification, location information, “cookie” information, the type of browser and/or device you’re using to access our Services, the capabilities of the browser and/or device you’re using to access the Services and the page or feature you requested. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features. Our advertising partners may also transmit cookies to your browser or device, when you click on ads that appear on the Services. Also, if you click on a link to a third-party website or service, a third party may also transmit cookies to you. Again, this Privacy Policy does not cover the use of cookies by any third parties, and we aren’t responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services, and those third parties may not honor “Do Not Track” requests you have set using your browser or device.

5. Sharing of Information that has been de-identified. We may de-identify your Personal Information so that you are not identified as an individual and provide that information to our partners. We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services as well as our partner’s services, so that they, too, can provide you with optimal online and in-person experiences. However, we never disclose aggregate usage or de-identified information to a partner in a manner that would identify you as an individual person.

6. Sharing of Information with our Advertisers, Merchant Partners and Licensees. We may allow advertisers and/or merchant partners and licensees (“Advertisers”) to choose the demographic information of users who will see their advertisements and/or promotional offers, and you agree that we may provide any of the information we have collected from you in personally identifiable form to our licensees and to other Advertisers in non-personally identifiable form to an Advertiser, in order for that Advertiser to select the appropriate audience for those advertisements and/or offers. For example, we might use the fact you are located in San Francisco to show you ads or offers for San Francisco businesses, but we will not tell such businesses, other than a licensee on whose behalf we first contacted you, who you are. Or, we might allow Advertisers to display their ads to users with similar usage patterns to yours, but we will not disclose usage information to Advertisers (other than those licensees) except in aggregate form, and not in a manner that would identify you personally. Note that if an advertiser asks us to show an ad to a certain audience or audience segment and you respond to that ad, the advertiser may conclude that you fit the description of the audience they were trying to reach.

We may provide certain Personal Information to our licensees and/or Merchants in connection with redemption of our Instruments and to otherwise allow the Licensees or Merchants to contact you regarding their service offerings, including offering promotions to you. By using the Services, you consent to our sharing such information with our Licensees and Merchants.

We may deliver a file known as a “web beacon” from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Because your web browser must request these advertisements and web beacons from the ad network’s servers, these companies can view, edit, or set their own cookies, just as if you had requested a web page from their site. You may be able to opt out of web beacon tracking conducted by third parties through our Services by adjusting the Do Not Track settings on your browser; please note that we don’t control whether or how these third parties comply with Do Not Track requests.

7. Sharing of Information with our Affiliated Businesses. To the extent permitted by law, we may provide information about your transactions or use of our Services to other affiliated entities, whose use and disclosure of your Personal Information is subject to this Privacy Policy. By using the Services, you consent to our sharing such information with affiliated businesses.

8. Sharing of Information with Agents. We may employ other companies and people to perform tasks on our behalf and need to share your Personal Information with them to provide products or services to you. Unless we tell you differently, these agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us. In addition, we may utilize automated devices and applications from third-party service providers to evaluate use of our services; these analytics providers may use cookies and other technologies to perform their services and may combine the information they collect about you during your use of Services with other information they have collected for their own purpose. This policy does not cover such uses of data by third parties.

9. User Profiles and Submissions. Certain user profile information, including the user’s name, location, e-mail address and picture that such user has uploaded to the Services, may be displayed to other users to facilitate user interaction within the Services or address the user’s request for our services.

10. Transfers of our Business. In the event TruCentive is involved in a merger, acquisition or sale of all or a portion of its assets, we may share and/or transfer Personal Information in connection with such transaction. Also, if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third-party.

11. Protection of the Company and Others. We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with law, a subpoena, court order or government request or to investigate fraud; enforce or apply our Terms of Use and other agreements; or protect the rights, property, or safety of you, the Company, our employees, our users, or others.

12. Security of your Personal Information. Your account is protected by a password for your privacy and security. If you access your account via a third-party site or service, you may have additional or different sign-on protections via that third-party site or service. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account. We endeavor to protect the privacy of your account and other Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

Many browsers provide you an option to request that a web application disable either its tracking and/or cross site user tracking of an individual user. We do not track your online activities across different sites, and we only track your activity within a site to the extent you log into your account. Therefore, our practices remain the same whether or not you do not enable the “Do Not Track” feature. As noted above, however, third parties may not honor “Do Not Track” requests you have set using your browser or device, and we cannot control the actions of those third parties.

13. Accessing and Editing your Personal Information. You may access, and, in some cases, edit or delete the following information you’ve provided to us: name and password; e-mail address; billing and payment details; phone number; location; and social media account information. The information you can view, update, and delete may change as the Services change. When you update information, we may maintain a copy of the unrevised information in our records. Some information may remain in our records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. If you have any questions about viewing or updating information we have on file about you, please contact us at support@trucentive.com.

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information that we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to: support@trucentive.com.

14. Retention Period of your Personal Information. We will retain your information for as long as your account is active or as needed to provide you Services and up to a period of no longer than seven years thereafter. If you delete your account, to the extent permitted by applicable law, we may retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records and enforce our agreements.

15. Changes to this Policy. TruCentive may make changes or amendments to this Privacy Policy from time to time (including, but not limited to, in connection with changes we make to the Services themselves). We will alert users to material changes to this Privacy Policy by placing a notice on www.trucentive.com, by sending you an e-mail, and/or by some other means. Please note that even if you’ve opted not to receive legal notice e-mails from us (or you haven’t provided us with your e-mail address), the legal notices and changes to this Privacy Policy will still govern your use of the Services, and you are still responsible for reading and understanding them. If required by law, we will obtain your consent or give you the opportunity to opt out of such changes. Otherwise, if you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

16. Questions or Concerns. If you have any questions or concerns regarding this Privacy Policy, please send a detailed message to support@trucentive.com, and we will try to resolve your concerns. Please keep in mind that certain Services will not be available if you withdraw your consent or otherwise delete or object to our processing of certain Personal Information. We will respond to your request in accordance with applicable law, and we will inform you if we do not intend to comply with your request.