Merchant Privacy Policy

Last updated 10/10/2021

Thank you for choosing to be part of our community at SavCoins LLC, doing business as SavCoins (“SavCoins”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at info@SavCoins.com. When you use our mobile application “app” and/or visit our website and/or use our services you trust us with your personal information. We take your privacy very seriously. In this privacy policy, we seek to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Sites and our services. SavCoins Privacy Policy applies to all information collected through our website (SavCoins.com) and our mobile application, or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the “Services”). By using the SavCoins Technology, you agree to be bound by this Privacy Policy and our Terms of Use, as they may be amended from time to time in the future (see “Change to this Privacy Policy” below).

The use of SavCoins Services constitutes your acceptance of this Privacy Policy, and if you do not agree with how we have determined to handle your information, please do not visit or use SavCoins Services. SavCoins Services is only intended for use in the United States and the information you provide will only be stored in the United States.

1. What information do we collect?

Personal information you disclose to us We collect personal information that you voluntarily provide to us when registering for our Services, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Services (such as posting messages, or entering contests, surveys or giveaways) or otherwise contacting us. The personal information we collect depends on the context of your interaction with us and the Services, the choices you make, and the products and features you use. The personal information we collect can include the following:

Publicly Available Personal Information. We may collect first name, last name, date of birth, zip code, legal business name. Personal Information Provided by You. We collect an email address, password you create for your profile, credit card information, bank account and routing number, location and/or other data collected from surveys and other similar data.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information. Location Information

Depending on the SavCoins services that you use, and your app settings or device permissions, we may collect your precise or approximate location information as determined through data such as GPS, IP address, Geofencing, and Wi-Fi.

• If you are a Consumer, SavCoins collects detailed location information when the SavCoins App is running in the foreground (App open and on-screen) or background (App open but not on screen) of your device and where a transaction occurs using the SavCoin App.

• If you are a Merchant, SavCoins will collect detailed location of which store uses the SavCoin App.

Transaction Information

SavCoins collects transaction details related to your use of our services including what retail outlets consumers access, when the App is accessed, frequency of visits to the Merchant’s store, amount deposited, which Employee completed the transaction, and payment method.

Information automatically collected

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services and for our internal analytics and reporting purposes.

• Usage Details. When you access and use the App, we may automatically collect certain details of your access to and use of the App, including traffic data, geo data, logs, and other communication data and the resources that you access and use on or through the App.

• Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.

• Stored Information and Files. The App also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.

• Location Information. This App uses the current location through GPS tracking and/or geofencing but is not storing any of the user’s location on the database unless a transaction has occurred.

• Online Identifiers. We may collect cookie identifiers, or others such as the ones used for analytics and marketing, and other similar data. We may collect geolocation to better serve your experience using the app. Like many businesses, we also collect information through cookies and similar technologies. The technologies we use for automatic information collection may include:

• Cookies or mobile cookies. A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of our App.

• Web Beacons. Pages of the App and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).

Third Party Information Collection

When you use the App or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

• Advertisers, ad networks, and ad servers.

• Analytics companies.

• Your mobile device manufacturer.

• Your mobile service provider.

These third parties may use tracking technologies to collect information about you when you use this app. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see “CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION”.

2. How do we use your information?

We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below. We use the information we collect or receive:

• To facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as your Instagram or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.

• To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (See “What are your privacy rights” below).

• To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.

• Deliver targeted advertising to you. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.

• Request feedback. We may use your information to request feedback to contact you about your use of our Services.

• To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user’s consent.

• To enforce our terms, conditions, and policies for business purposes, legal reasons, and contractual obligations.

• To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the date we hold to determine how to respond.

• To respond to user inquiries/ offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.

• For other Business purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage, trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, products, marketing, and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual users and does not include personal information. We will not use identifiable personal information without your consent.

3. Will your information be shared with anyone?

We may process or share data based on the following legal basis:

• Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.

• Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.

• Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.

• Legal Obligations: We may disclose your information where we are legal required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspect fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved. More specifically, we may need to process your data or share your personal information in the following situations:

• Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data about how you interact with the Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity.

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Services. These companies may use information about your visits to our Website and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.

• Other users. When you share personal information (for example, by posting comments, contributions or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly distributed outside the Services in perpetuity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services and view your profile.

4. Do we use cookies and other tracking technologies?

We may use cookies and similar tracking technologies (such as web beacons and pixels) to access or store information.

5. What is our stance on Third-Party Websites?

The Services may contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the services. You should review the policies of such third parties and contact them directly to respond to your questions.

6. How long do we keep your information?

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

7. Choices about how we use and disclose your information.

We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.

• Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the App may then be inaccessible or not function properly.

• Location Information. You can choose whether or not to allow the App to collect and use real-time information about your device’s location through the device’s privacy settings or if you block the use of location information, some parts of the App may then be inaccessible or not function properly.

• Promotion by the Company. If you do not want us to use your email address to promote our own or third parties’ products or services, you can opt-out by sending an email to info@savcoins.com or unsubscribe from the link on our email. You can also always opt-out by logging into the App and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to info@ savcoins.com.

• Targeted Advertising by the Company. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by emailing us at info @savcoins.com, and/or if available clicking unsubscribe on the link on the email of advertisement. You can also always adjust your user advertising preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to info @savcoins.com.

• Disclosure of Your Information for Third-Party Advertising and Marketing. If you do not want us to share your personal information with unaffiliated or non-agent third parties for advertising and marketing purposes, you can opt-out by info @savcoins.com, and/or if available clicking unsubscribe on the link on the email of advertisement. You can also always opt-out by logging into the App and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to info@savcoins.com. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (”NAI”) on the NAI’s website.

8. Do we collect information from minors?

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at info@savcoins.com. The App is not directed to children under the age of 13. We adhere to the Children’s Online Privacy Protection Act (COPPA) and will not knowingly collect Personal Information from any child under the age of 13. We ask that minors (under the age of 13) not use the App. If a child under the age of 13 has provided us with Personal Information, a parent or guardian of that child may contact us and request that such information be deleted from our records.

9. Important Notices to Non-U.S. Residents

The App and its servers are operated in the United States. If you are located outside of the United States, please be aware that your Information, including your Personal Information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use the App, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States and elsewhere. If you have questions or comments about your privacy rights, you may email us at info@savcoins.com

10. Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can log into your account settings and update your user account or email us at info@savcoins.com.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements. Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt-out of interest-based advertising by advertisers on our Services visit htttp://www.aboutads.info. Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list- however, we will still need to send you service-related emails that are necessary for the administration and use of your account.

11. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

12. Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions and background checks including your driver’s license or social security number will be encrypted using SSL technology. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the App like message boards. The information you share in public areas may be viewed by any user of the App. Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

13. California Residents

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties with which we shared personal information in immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

(a) Disclosure of Personal Information We Collect About You. You have the right to know:

• The categories of personal information we have collected about you;

• The categories of sources from which the personal information is collected;

• Our business or commercial purpose for collecting or selling personal information;

• The categories of third parties with whom we share personal information, if any; and

• The specific pieces of personal information we have collected about you.

Please note that we are not required to:

• Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;

• Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or

• Provide the personal information to you more than twice in a 12-month period.

(b) Disclosure of Personal Information Sold or Used for a Business Purpose. In connection with any personal information, we may sell or disclose to a third party for a business purpose, you have the right to know:

• The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and • The categories of personal information that we disclosed about you for a business purpose.

(c) Right to Deletion. Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

• Delete your personal information from our records; and

• Direct any service providers to delete your personal information from their records.

Please note that we may not delete your personal information if it is necessary to:

• Complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;

• Debug to identify and repair errors that impair existing intended functionality;

• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; • Comply with the California Electronic Communications Privacy Act;

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;

• Enable solely internal uses that are reasonably aligned with your expectations based on the your relationship with us;

• Comply with an existing legal obligation; or

• Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information. (d) Protection Against Discrimination. You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:

• Deny goods or services to you;

• Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;

• Provide a different level or quality of goods or services to you; or

• Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to us by your personal information.

14. Updates to this Policy

When needed, we may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

15. How to Contact Us about this policy?

If you have questions or comments about our privacy policy, you may email us at savcoinsllc@gmail.com.