INDIGO PAYMENTS, INC. PRIVACY POLICY

This Privacy Policy is designed to inform users of the policies and procedures of Indigo Payments, Inc. (“Indigo”, “we”, “our” or “us”) on the collection, use and disclosure of your information on my.IndigoCCR.com (the “Website”) and the services, features, content or applications we offer through our products directly to you (collectively with the Website, Retailer point-of-sale integrated platforms and features defined below, the “Service”). We receive information about you from various sources, including: (i) through your user account including when you register for the Website and/or the Service (your “Account”); (ii) your use of the Services through the Retailer point-of-sale integrated platforms (“POS”); and (iii) when you engage in loyalty programs (“Programs”) offered by Indigo retail partners (each a “Retailer”) in connection with the Service. When you use the Service, you are consenting to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Privacy Policy. BY ACCESSING OR USING THE SERVICE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND AND AGREE TO BE BOUND BY THIS PRIVACY POLICY AND STORE REWARDS TERMS AND CONDITIONS. IF YOU DO NOT AGREE TO THESE TERMS, DO NOT USE THE SERVICE.

Important Indigo Privacy Guideline

At Indigo we recognize the importance of your personal privacy. Except as disclosed in this Privacy Policy or as otherwise authorized by you, we will never share your email address, telephone number, or mailing address with a third party for their marketing purposes.

What information do we collect?

The information we gather enables us to personalize, improve and continue to operate the Service. In connection with certain aspects of the Service, we may request, collect and/or display some of your Personal Information (as defined below). We collect the following types of information from our users:

Personal Information: Indigo collects some Personal Information (as defined below) in connection with the Service. When you sign up to create an Account, sign in using the Website, provide your phone number or other information at a Retailer location, redeem rewards with a Indigo Retailer or otherwise engage in a Program, submit content to Indigo, complete a survey, send us feedback, request information about the Service, or signup for special offers from third parties, Indigo may collect personally identifiable information from you or receive such information from a Retailer, including, for example, your email address, first and last name, mailing address, telephone number, and other information that personally identifies you (collectively, “Personal Information”). You do not have to provide Personal Information to Indigo or a Retailer, but you may not be able to take advantage of some or all the features of the Service if you do not. You acknowledge that this information may be personal to you, and by creating an account on the Service and providing Personal Information to us and or the Retailer, you allow us (and others to the extent permitted under this Privacy Policy) to use your Personal Information in the manner set forth under this Privacy Policy. We may use your contact information to send you information about our Service. You may unsubscribe from our marketing messages through your Account settings, although we, nonetheless, reserve the right to contact you when we believe it is necessary, such as for Account recovery purposes.
Tracking Information and other Non-Personally Identifiable Information: Indigo, Retailer and our third party service providers may use tracking technologies, such as cookies, web beacons, pixel tags and clear GIFs, to collect data related to usage of the Service, the Programs, and web and email marketing conducted by or on behalf of Indigo. Such data may include, without limitation, the latitude and longitude (i.e., lat/long) coordinates of your device, the region where your device is located, geo-IP data, the address of the websites you visited before and after you visited the Service, the type of browser you are using, your Internet Protocol (IP) address, what pages in the Service you visit and what links you clicked on (collectively, “Tracking Information”). In order to collect Tracking Information and to make your use of the Service more efficient, we may store cookies on your computer. Indigo, Retailer and our third party contractors who are engaged to provide services on behalf of Indigo (“Contractors”) may also use tracking technologies that are placed on websites, on the Service or in email communications to collect information about actions that users take when they interact with the Service or such email communications. We may use the Tracking Information and other Non-Personally Identifiable Information (as defined below) for the purposes described in this Privacy Policy, such as to serve targeted advertising content to you. We do not knowingly use tracking technologies to automatically retrieve Personal Information from you without your knowledge. However, some Tracking Information may include data, such as IP address data or the identifiers associated with your device that are unique to your computer or device (e.g., IDFA for iOS and Android ID for Android). You may be able to modify your browser or device settings to alter which tracking technologies are permitted when you use the Service, but this may affect the performance of the Service. Please be advised that certain third parties that are beyond the scope of this Privacy Policy, such as advertisers, may collect Tracking Information in connection with the Service. Indigo is not responsible for the acts or omissions of such third parties.
In addition to Tracking Information, we may also have access to certain other types of non-personally identifiable information. For example, when you use or register for the Service, you may provide or we may through Retailers or otherwise have access to, demographic information, information relating to gender, marital status, date of birth, purchase history, store visits, lifestyle, preferences and interests, the offers you view and redeem, your use of the Service, interactions with Retailers, business partners, and service providers and other categories of information that do not specifically identify you (collectively, with the Tracking Information, “Non-Personally Identifiable Information”).
Interest-Based Advertising: We may ourselves, or with third party vendors, use information we collect in connection with Retailer, or vendor information to deliver targeted advertising to you across websites and mobile applications. Cookies and other similar technologies described above may be used in this process. For example, if you are searching for information on or have purchased a particular product, we or our vendor may cause an advertisement to appear on other websites or applications you view with information on that product. This form of advertising, sometimes called “behavioral advertising” or “interest-based advertising” is based on anonymous or de-identified information. To be clear, de-identified information may include hashed email addresses or other unique identifiers that no longer personally identify you. As a result, we and our vendor know your interests, but do not personally identify you in connection with the delivery of that specific ad. We believe that such advertising is helpful because you will see advertisements that are relevant to your interests. However, if you would like to opt-out of these interest-based advertisements, please follow the opt-out process described below under “Opt-Out.”
Contest and Sweepstakes: We may, from time to time, offer surveys, contests, sweepstakes, or other promotions through our Website, Retailer websites, or through our other forms of communications with you (collectively, the “Promotions”). Participating in our Promotions is completely voluntary. Information requested for entry may include personal contact information such as your name, address, date of birth, phone number, email address username, and similar details. We use the information you provide to administer our Promotions and otherwise in accordance with this Privacy Policy. We may also, unless prohibited by the applicable Promotion’s rules or law, use the information provided to communicate with you, or other people you select, about our Service. We may share this information with our affiliates, Retailers, and other organizations or service providers in line with this Privacy Policy and the rules for the Promotion.
Indigo usage of the Information received/collected
Personal Information: We will use your Personal Information as described below:
• To operate and deliver the Service to you;
• To allow Retailers to accept Indigo as a Program identifier and to otherwise participate in and benefit from the Service;
• To allow you to redeem rewards,
• To deliver Program and Promotions information to you (as applicable),
• To market the Service and other products or services (including Retailer products or services) that may be of interest to you,
• To improve our products and services, and for the internal operational and administrative purposes of the Service,
• To investigate suspected fraud, harassment or otherwise enforce compliance with our Terms of Use and applicable law (e.g., developing tools and algorithms that help us prevent violations),
• To send you system alert messages including, for example, to inform you of temporary or permanent changes to our Services, planned outages, new features, version updates, releases, abuse warnings, and changes to our Privacy Policy.

Please note that if you specifically consent to additional uses of your Personal Information, either at the time the Personal Information is collected from you or through some other form of consent from you or notification to you, we may use your Personal Information in a manner consistent with that consent. Finally, we reserve the right to supplement your personal information with information we gather from other sources which may include information we gather from online and offline sources.

Aggregate Information: We will also use Personal Information and Tracking Information, and other information (including by combining information from online and offline third party sources) to create aggregated data for analytical and other purposes. This aggregate statistical information does not contain any information in a form that specifically identifies you. It is used in a variety of ways, including to allow us to understand our customer base and to better serve our market.
Non-Personally Identifiable Information: Indigo may use Tracking Information and other Non-Personally Identifiable Information in connection with the Service, including: to administer the Service, to understand how well our Service is working, to market the Service and other products and services (including the products and services of Retailers that may be in your area), to serve targeted advertising content to you, to develop aggregate, statistical information on usage of the Service and to generally improve the Service. For example, this information allows us to determine which features visitors like best to help us improve our Service, personalize your user experience, target marketing efforts, and measure overall effectiveness.
Email Communications: If you create an account and provide your email address, we will send you administrative and promotional emails. If you wish to opt out of promotional emails, you may do so by following the “unsubscribe” instructions in the email, or by editing your account settings. All users receive administrative emails. If you wish to opt out of administrative emails, you must delete your account entirely and cease use of the Service.
Text Message/SMS Communications: When you create an account and provide your telephone number, Indigo may send you administrative text messages.
If you opt in to a Retailer Reward Program, Retailers may communicate transaction information concerning the Reward Program and communicate promotional opportunities from time-to-time. You may choose communication preferences in the Account Information section of your Rewards Program Account. You can choose to accept email, SMS, both or none.

Messaging Policy for SMS – Participating carriers include: AT&T, Boost Mobile, T-Mobile, Metro PCS, Verizon Wireless, Sprint, U.S. Cellular, Nextel & Virgin Mobile. Carriers are not liable for delayed or undelivered messages. Retailer and Indigo are not liable for delayed or undelivered messages.
As always, message and data rates may apply for any messages sent to you from us and to us from you. You will receive messages based on Reward Program transactions as they occur and promotional communications no more than weekly. If you have any questions about your text plan or data plan, it is best to contact your wireless provider.
T-Mobile is not liable for delayed or undelivered messages.
You can cancel the SMS service at any time. Just text “STOP” to 47807. After you send the SMS message “STOP” to us, we will send you an SMS message to confirm that you have been unsubscribed. After this, you will no longer receive SMS messages from us. If at any time you forget what keywords are supported, just text “HELP” to 47807. After you send the SMS message “HELP” to us, we will respond with instructions on how to use our service as well as how to unsubscribe. You may also contact Indigo support at: +1 (833) 420-7374.

What information do we share with third parties?
Personal Information: Indigo may disclose your Personal Information to third parties in the following circumstances and other circumstances described in this Privacy Policy:
1. if you use the Service, we may disclose your Personal Information to the associated Retailer (e.g., Retailers associated with the Store Rewards Programs you join) to facilitate the operation of the Programs and for other purposes dictated by the Retailer, including marketing the products and services of the Retailer;
2. to Contractors who are performing marketing/advertising services, sending emails, push notifications, or SMS or other messages on our behalf, delivering goods, administering promotions, analyzing data and usage of the Service, processing credit card payments, operating the Service or providing support and maintenance services for the Service, or providing customer service. We use reasonable efforts to enter into agreements with all Contractors that require Contractors to use any unaggregated Personal Information they receive only to perform services for us; and
3. when we have your consent to otherwise share the information.
Non-Personally Identifiable Information: We may disclose Tracking Information and other Non-Personally Identifiable Information to third party advertisers and advertising agencies, Retailers, Contractors, and other parties in order for Indigo and such third parties to analyze the performance of the Service and the behavior of users, to operate and improve the Service, to serve targeted advertising content to users, and to target offers to users through the Service. We may also disclose, use or publish this information for other business purposes such as promoting the Service.
Aggregate Information: Because the aggregate information we collect does not specifically identify you, it may be shared with any number of parties. For example, we may disclose anonymous, aggregated information to third parties such as potential business partners, Retailers, advertisers, and funding sources, in order to describe our business and operations.
Network Operators: Use of the Service may involve use of the services of third party telecommunications carriers and service providers (such as the services of the carrier that provides cell phone service to you). Such carriers and service providers are not Indigo contractors, and any information that a carrier collects in connection with your use of the Service is not subject to this Privacy Policy. Indigo is not responsible for the acts or omissions of telecommunications carriers or service providers.
Additional Disclosures: Notwithstanding anything to the contrary in this Privacy Policy, Indigo reserves the right to use or disclose Personal Information and any other information Indigo collects in connection with the Service (a) to any successor to Indigo’s business, including as a result of any merger, acquisition, asset sale or similar transaction, (b) to any corporate affiliate of Indigo whose privacy practices are substantially similar to ours, (c) to any law enforcement, judicial authority, or governmental or regulatory authority, to the extent required by law or legal process, or (d) if in Indigo’s reasonable discretion, such use or disclosure is necessary to enforce or protect Indigo’s legal rights or to protect third parties.
Protection for Children of Age under 16:
Indigo does not knowingly collect or maintain Personal Information from persons under 16 years of age, and no part of the Service is directed at persons under 16. If you are under 16 years of age, then you may not use the Service. If Indigo learns that Personal Information of persons less than 16 years of age has been collected, then Indigo will take the appropriate steps to delete this information. To make such a request, please contact us at support@IndigoCCR.com.

Is Information About Me Secure?
We seek to protect Account information to help ensure that it is kept private; however, we cannot guarantee the security of any Account information or Personal Information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.
We otherwise store all of our information, including your IP address information, using industry-standard techniques. We do not guarantee or warrant that such techniques will prevent unauthorized access to information about you that we store, including Personal Information.

How Long Do We Retain Your Information?
We will retain your information for as long as your account or inquiry is active or as needed to provide you with the Services and for a reasonable time thereafter in accordance with our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your Personal Information, we may continue to retain and use aggregate or anonymous data previously collected and/or anonymize or aggregate your Personal Information. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties. If you wish to cancel your account or request that we no longer use your information to provide you the Services, please contact us at support@IndigoCCR.com.

What Information of Mine Can I Access?
If you are a registered user, you can access your Personal Information and certain other information associated with your Account by logging into the Service. Registered and unregistered users can access and delete cookies through their web browser settings.

How Can I Delete My Account?
Should you ever decide to delete your Account, you may do so by emailing support@IndigoCCR.com. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account, although we may retain archival copies of your Account information in a manner consistent with our retention policy described above. Please note that we are not responsible for removing your Personal Information from the lists of any third party who has previously been provided your information in accordance with this Privacy Policy or your consent, such as a Retailer. You should contact such third parties directly. Any public activity on your Account prior to deletion will remain stored on our servers and will remain accessible to the public.

Opt-Out Process:
If you do not want your Personal Information shared with any third party who may use such information for direct marketing purposes, then you may opt out of such disclosures by sending an email to us at support@IndigoCCR.com. Please note that if you opt out in this manner, certain aspects of the Service may no longer be available to you.

Email Communications. As noted above, if you wish to opt out of promotional emails, you may do so by following the “unsubscribe” instructions in the email, or by editing your account settings. All users receive administrative emails. If you wish to opt out of administrative emails, you must delete your account entirely and cease use of the Service.

Text Messages/SMS Messages. As noted above, if you create an account and provide your telephone number, we may send you administrative text messages. If you wish to opt out of such text messages, you may do so by following the “opt-out” instructions in the text message, or by editing your account settings.

Tracking Technologies. You may opt out of or restrict the placement and/or use of tracking technologies on your device or remove them from your browser by adjusting your browser or device settings. Please note that cookie-based opt-outs are not effective on many mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings. For example, the “Privacy” settings of an iOS device will allow you to “Limit Ad Tracking” and reset your mobile device’s “Advertising Identifier.” Please refer to instructions provided by the manufacturer of your device to learn how to adjust your mobile device settings.

You may also adjust the settings on your mobile device to allow or restrict the sharing of location information. For example, the “location” permissions on your mobile device may allow you to elect whether to never share location information with Indigo, to share location information only while you are using the Smartphone App (e.g., to help you find nearby offers), or always share location information even if you are not using the Smartphone App. If you elect to not share your location information, you may be unable to access some features of our Services that are designed for mobile devices. Also, in the event that you prevent the sharing of location information, we may still estimate your general location based on the IP address you use to access our Services.

Interest Based Advertising. The online advertising industry also provides websites from which you may opt out of receiving targeted ads/interest-based advertising from us and our data partners and our other advertising partners that participate in self-regulatory programs. We endeavor to comply with the DAA’s Self-Regulatory Principles for Online Behavioral Advertising. The DAA’s opt out tool can be found at http://www.aboutads.info/choices/. The Network Advertising Initiative’s (NAI)_opt out tool can be found at http://www.networkadvertising.org/choices/.

To be clear, the opt-out from targeted ads must be performed on each device and browser that you wish to have opted-out. For example, if you have opted out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt out on each device.

Do Not Track:
Please note that we do not respond to or honor “do not track” (a/k/a/ DNT) signals or similar mechanisms transmitted by web browsers.

Social Network Features and Connections: If you use features on or associated with the Service that interface with or otherwise interact with social network sites like Facebook, Instagram and Twitter (“Social Network Connections”), you grant Indigo permission to access all of the elements of your social network profile information that you have made available to be shared and you consent to our use and disclosure of such information and any other information obtained from Social Network Connections, including in combination with any other information you may have provided to us in connection with the Service, in accordance with this Privacy Policy. Please refer to the privacy settings of the social media platform or application to determine how you may adjust our permissions and manage the interactivity between Indigo and your social media account. Please note that we do not control such Social Network Connections and are not liable for the manner in which they operate. While we may provide you with the ability to use such Social Network Connections in connection with the Service, we are doing so merely as an accommodation and, like you, are relying upon those third party services to operate properly and fairly.
Communications with Us or Through the Service: Any communication or material you transmit to us by email or otherwise, including any data, questions, comments, suggestions, or the like is, and will be treated as, nonconfidential and nonproprietary. Except to the extent expressly covered by this policy, anything you transmit or post may be used by us for any purpose, including but not limited to, reproduction, disclosure, transmission, publication, broadcast and posting. Furthermore, you expressly agree that we are free to use any ideas, concepts, know-how, or techniques contained in any communication you send to us without compensation and for any purpose whatsoever, including but not limited to, developing, manufacturing and marketing products and services using such information.
You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum such as an in-person panel or survey, may be viewed and used by anyone without restriction. Notwithstanding anything in this Privacy Policy, you understand that by using such services you assume the risk that the Personal Information and other information provided by you in connection with such publicly available areas may be viewed and used by anyone for any number of purposes.

California Privacy: Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of Personal Information, such as name, email address and mailing address and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes and (b) the names and addresses of all such third parties. To request the above information, please contact us by email through support@IndigoCCR.com.
United States of America: By using the Services, you freely and specifically give us your consent to export your Personal Information to the USA and to store and use it in the USA as specified in this Privacy Policy. You understand that data stored in the USA may be subject to lawful requests by the courts or law enforcement authorities in the USA.
Amendment to the Privacy Policy.
We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes in the way we collect or use information, we will notify you by posting an announcement on the Service or sending you an email. A user is bound by any changes to the Privacy Policy when he or she uses the Service after such changes have been first posted.
If you have any questions or concerns regarding privacy using the Service, please call us 833-420-7374, send us a detailed message to support@IndigoCCR.com or Indigo Payments, Inc., Glenridge Highlands, 5555 Glenridge Connector, Suite 200, Atlanta, Georgia, 30342. We will make every effort to resolve your concerns.

Effective Date of this Privacy Policy: January 20, 2021