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Privacy Notice FOR EDO interactive, INC. services

EFFECTIVE: July 21, 2019

This Privacy Notice applies to this website and to other websites, applications, services and mobile applications on or in which this Privacy Notice is posted or referenced (collectively, the "edo Services"). The edo Services are owned and/or operated by edo Interactive, Inc. ("edo," "we", "our" or "us"). We hope that this Privacy Notice helps clarify how we collect and process your information.

This Privacy Notice describes:

·        The information we collect on or through the edo Services and how we collect it.

·        How we use and process the information we collect.

Please review this Privacy Notice carefully. When you submit information to or through the edo Services, you consent to the collection and processing of information as described in this Privacy Notice.

If you have not done so already, please also review our Terms of Service) ("Terms"). The Terms contain provisions that limit our liability to you and require you to resolve any dispute with us through final and binding arbitration on an individual basis and not as part of any class or representative action.

IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY NOTICE, THEN PLEASE DO NOT USE THE EDO SERVICES.

1.      CHANGES TO THIS PRIVACY NOTICE

The Effective Date of this Privacy Notice is set forth at the top of this webpage. Whenever possible, we will provide you with advance written notice of our changes. We will not make retroactive changes that reduce your privacy rights unless we are legally required to do so. Your continued use of the edo Services after the Effective Date constitutes your acceptance of the amended Privacy Notice. The amended Privacy Notice supersedes all previous versions.

2.      INFORMATION WE COLLECT

"Personal Information" means information associated with or used to identify a specific person. Personal Information includes: (1) contact data (such as your e-mail address, telephone number and employer); (2) demographic data (and your zip code); and (3) certain Usage Data, such as the IP address. If you communicate with us by, for example, e-mail or letter, any information provided in such communication may be collected as Personal Information.

"General Information" is information about an individual's online activity that, by itself, cannot be used to identify him or her, such as browser type, operating system and the dates/times of Services access.

Personal Information and General Information may be linked together. Different types of General Information also may be linked together and, once linked, may identify an individual person.

3.      HOW WE COLLECT INFORMATION

We collect information that you provide to us and from your use of the edo Services. The information that we collect and how we process it depends on how you use and access the edo Services. Some information is collected through use of cookies and similar tools (see section 5 below).

a.      Information that You Provide to edo: You may provide us with your Personal Information when you contact us for help or information, create an account to use one of the edo Services or otherwise voluntarily supply your Personal Information to us. We may collect information, some of which may be Personal Information, as otherwise described to you at the point of collection or pursuant to your consent.

b.      Information that We Collect When You Use the edo Services: When you use the edo Services, we may automatically collect Information about how you interact with the edo Services, such as (i) IP address; (ii) domain server; (iii) type of device(s) used to access the edo Services; (iv) web browser(s) used to access the edo Services; (v) statistics and information associated with the interaction between your browser or device and the edo Services; and (vi) referring webpage or other source through which you accessed the edo Services (collectively "Usage Data"). Depending on applicable law, some Usage Data may be Personal Information.

c.      Information from Other Sources: Third parties that assist us with our business operations also collect information (including Personal Information and Usage Data) from you and share it with us. For example, we may receive "tokenized" information (i.e., payment card information that was replaced with a unique identifier or token) about your credit card transaction history when you take advantage of certain offers.

4.      HOW WE PROCESS INFORMATION

a.      How We Use Information

We use the information that we collect or that you provide to us to operate, maintain and enhance the edo Services, including:

a.      To present the edo Services to you and to customize, improve and develop content and functionality that helps us better serve your needs;

b.      For customer service and to troubleshoot problems;

c.      To facilitate communication between edo and you;

d.      To prevent and detect fraud and other prohibited or illegal activities and investigate security breaches;

e.      To send emails and other communications that display content that we think will interest you, such as news about our products, services and promotions;

f.       To generate statistical information about how users interact with the edo Services and conduct analyses to support, improve and enhance the edo Services;

g.      To carry out our obligations and protect our rights arising from any contracts entered into between you and us, including our Terms of Service;

h.      To protect the safety and security of users of the edo Services;

i.        To send you important administrative information regarding the edo Services, such as changes to this Privacy Notice or our other policies; and

j.        To fulfill any other purpose for which you provide Information to us or to which you consent.

We and our business partners also may combine different types of information collected from or about you through various sources, including Personal Information, and use the combined information for the purposes described in this Privacy Notice.

How We Share and Disclose Information

Unless you have consented, we will not share or disclose your Personal Information other than as described in this Privacy Notice. We may share and disclose information:

 .       With our affiliates and strategic business partners;

a.      With third party service providers retained to perform functions on our behalf, such as web hosting and data analyses companies, that have access to Personal Information needed to perform their functions;

b.      To enforce our agreements with users or other third parties;

c.      To protect the safety and security of users;

d.      With companies with which we plan to merge or an acquirer of all or substantially all of edo's assets (we will continue to process information consistent with this Privacy Notice and, when possible, will provide you with notice before Personal Information is transferred or becomes subject to a different privacy policy);

e.      To comply with a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process; and

f.       If we believe you have violated or are violating our Terms of Service or in order to protect or defend edo's rights or property, even without a subpoena, warrant or other court order.

Tracking Tools and "Do Not Track" Information

Cookies & Other Tracking Tools: "Tracking Tools" means technology that collects information about your use of the edo Services, such as cookies and web beacons.

How We Respond to Browser "Do Not Track" Signals: Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a "Do Not Track" (DNT) or similar feature that signals to websites that a visitor does not want to have his/her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain Personal Information about the browser's user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, we and many website operators do not respond to DNT signals. For more information about DNT signals, visit http://allaboutdnt.com.

Data Retention

We will hold your personal information on our systems for as long as is necessary to perform the relevant processing activity, or as long as is set out in any relevant contract you hold with us. This is a case by case determination that depends on things like the nature of the data, why it is collected, why it is processed, and relevant legal or operation retention needs. For example, we may retain your data for as long as you hold a rewards account so that we may process and fulfill your future award transactions. We may also be legally required to hold some types of information to fulfil our statutory obligations. We

review our retention periods for personal information on a regular basis. When the relevant processing activity has been completed, we may destroy your data, or alternatively anonymize the data in such a way that you are not personally identifiable, either directly or indirectly

INFORMATION PROTECTION

The security of your information is our top priority. We use physical, electronic, and procedural safeguards that comply with federal and international standards to protect and limit access to your personal information. Augeo also actively monitors our systems and your account for suspicious or fraudulent activity.

Managing Employee Conduct

Augeo has an absolute commitment to integrity, our related values and ethical standards, and the associated business conduct we expect from all our employees. These standards include specific guidelines about how employees must safeguard confidential information, including our customers’ data.

Regulatory Compliance

Augeo maintains compliance with all required data protection regulations that apply to the information systems and data we collect. Augeo regularly validates its security, operational, and business practices, both internally and through third party audits.

Online Security

Augeo uses at minimum 128-Bit Encryption each time you access your account(s) and perform transactions on our portals. Look for website to start with https:// or have a lock symbol.

Augeo regularly tests the web security of our sites and products.

Fraud Monitoring

Augeo continuously monitors the registration, login, and activities of accounts to detect fraudulent or unauthorized use of your account.

What Can You Do To Help?

· Help protect yourself by keeping your operating system, browser, and anti-virus software up-to-date so you'll have the latest security enhancements.

· Regularly monitor your account for suspicious activity.

· Watch out for phishing emails. Use caution when opening links or attachments in emails that you are not expecting.

· Used strong passphrases and change them frequently.

· Use safe practices when on social media.

Please note that information you send to us electronically may not be secure when it is transmitted to us, depending on the systems and communication channels you use. We recommend that you do not use unsecure channels to communicate confidential information to us.

LINKED SERVICES

This Privacy Notice applies solely to information collected by or through the edo Services. As noted in the Terms, the edo Services may contain links to third-party websites and services, including social media (collectively, "Linked Services"). Linked Services are not under the control of edo and edo is not responsible for Linked Services. The inclusion of a link does not imply endorsement by edo of the Linked Services or any association with the operators of the Linked Services. edo does not investigate, verify or monitor the Linked Services. We provide links to Linked Sites for your convenience only. You access Linked Services at your own risk. We encourage you to read about the privacy practices of any website that you access.

EDO SERVICES ARE NOT FOR USE BY CHILDREN

We do not knowingly collect information from minors. To use the edo Services, you must be the age of legal majority in your place of residence. By using the edo Services, you hereby represent that you are at least the age of legal majority in your place of residence. All information provided to edo is treated as if provided by an adult.

If we learn that a minor has submitted information about himself/herself to us, we delete it as soon as possible. If you believe that we have collected Personal Information from a minor, please contact us at privacy@augeomarketing.com.

Transferring Your Information

Because Edo is a US-based company, your information may be collected and processed in the United States. If you live or are travelling outside the US and access our online websites or platforms, any information that you provide or that we collect may be transferred to our systems in the US. However, if we transfer your information in this way, we will put in place appropriate protection to make sure your personal data remains adequately protected and is treated in line with this Policy.

California privacy law

Under California law, website operators must offer you the option to opt out of disclosure of Personal Information to third parties for their direct marketing purposes. A website operator also is required to disclose to its California customers, upon request, the identity of any third parties to whom the business has disclosed Personal Information within the previous calendar year, along with the type of Personal Information disclosed, for the third parties' direct marketing purposes. If you are a California resident and would like to make such a request, please submit your request in writing to: edo Interactive, Attn. Legal Department, 278 Franklin Road, Suite 320, Brentwood, TN 37027. Please note that under California law, businesses are only required to respond to a customer request once during any calendar year.

Under California Civil Code Section 1789.3, we are required to provide California residents with the following specific consumer rights information:

 .The edo Services are owned and/or operated in the United States by edo Interactive, Inc., 278 Franklin Road, Suite 320, Brentwood, TN 37027

                     i.          Unless otherwise expressly stated, the edo Services are provided without charge.

                    ii.          To file a complaint regarding any of the edo Services or to receive further information regarding use of the edo Services, please send a letter to edo Interactive, Inc., Attn. Legal Department, 278 Franklin Road, Suite 320, Brentwood, TN 37027 (with "California Resident Request" as the reference line). You also may contact the Complaint Assistance Unit of the Division of Consumer Services of California's Department of Consumer Affairs in writing at 400 R Street, Suite 1080, Sacramento, California 95814 or by telephone at 916.445.1254 or 800.952.5210.

Legal

Data protection law in Europe requires a “lawful basis” for collecting and retaining personal information from residents of the European Economic Area. Our lawful bases include:

· Performing the contract we have with you: In certain circumstances, we need your personal data to comply with our contractual obligation to deliver our services, and assist with any questions you may have.

· Legal compliance: Sometimes the law says we need to collect and use your data.

· Legitimate interests: This is a term in data protection law that allows us to process your personal information if we have a fair reason to use your data, and only if we do so in ways which do not hurt your interests and rights. We sometimes require your data to pursue our legitimate interests in running our business, including to process your redemption and purchase transactions, maintain your account, prevent fraud, quality assurance, and for marketing purposes, as long as our use of your data does not materially impact your rights, freedom or interests. This allows us to improve and develop the quality of the online experience we offer all our users.

Know Your Options

Users or website visitors residing in certain countries, such as those in the EU, are afforded certain rights regarding their personal information. Except where an exception or exemption applies, these rights may include the ability to access, correct, and request deletion of your personal information. While these rights are not globally applicable, our customers are entitled to access the personal information that we hold, if any, concerning them.

Keeping your account information up-to-date is very important. You may review or update certain account information by logging in and accessing your profile, depending on the Augeo product or service portal used. If you cannot change the incorrect information online, or you prefer to request changes offline, please contact us as described below. Please note that we may retain and process certain information as required by law or as necessary for our legitimate business purposes.

Augeo has appointed a Data Protection Officer (DPO) who is responsible for monitoring and ensuring compliance with this Privacy Policy, acting as a point of contact for data protection queries, managing Augeo’s response to privacy-related incidents, and updating this Policy as necessary. If you have any questions about your rights related to information Augeo possesses, or if you have any privacy questions or concerns about how Augeo processes your personal data, please contact our DPO by emailing privacy@augeomarketing.com.

If you have contacted Augeo and have further questions about how to protect yourself, or if you have any concerns about how Augeo handles or processes your personal information, you may contact the data protection authority for your area:

· U.S. Residents: Visit the Federal Trade Commission Consumer Information website at www.ftc.gov. · E.U. Residents: Visit the European Commission website at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm, and find the data protection authority for your country.

QUESTIONS?

If you have questions about this Privacy Notice or to request corrections, amendments or deletions to any Personal Information that you have provided through the edo Services, contact us at privacy@augeomarketing.com. edo will use reasonable efforts to supply you with requested Personal Information and correct any factual inaccuracy or delete your Personal Information from our databases. To honor your request, we will need the exact information you wish to correct, amend or delete.