• This Privacy Policy Describes:
• The Softcard App
• Personal Information Collected When You Use Softcard Services
• Use of Your Personal Information
• Sharing of Your Personal Information with Third Parties
• Protection of Your Personal Information
• Retention of Your Personal Information
• Updating of Your Personal Information
• Children's Online Privacy
• Changes to this Privacy Policy
• Changes to Corporate Control
• Companies to Which this Privacy Policy Applies
• How to Contact Softcard

The Softcard App

Softcard has developed a mobile payment and commerce platform (the Softcard System) that utilizes smartphone, contactless, and near-field communication (NFC) technology to enable you, among other things, to use your Softcard App to:

• Make purchase transactions using prepaid, credit, debit or other payment products (we refer to this Softcard App use as Payment Activity); and
• Receive certain promotions, programs, offers, coupons, loyalty programs and location-based features from Softcard, your wireless service provider, retailers, food establishments, manufacturers, brands and other third parties and certain location based services (we refer to this Softcard App use as Commerce Activity).

In this Privacy Policy we also use the terms Payment Cards, Participating Issuers and Merchants. Payment Cards are prepaid, credit, debit and other payment products. A Participating Issuer is an issuer of Payment Cards that is participating in the Softcard System. A Merchant is a wireless service provider, retailer, food establishment, other merchant or other third party providing Commerce Services accessible through Softcard.

Personal Information Collected When You Use Softcard Services

We collect Personal Information in a variety of ways, including:

• You provide it to us or we collect it from your mobile device when you:
  • activate the Softcard App;
  • use the Softcard App;
  • participate in Softcard marketing promotions;
  • respond to surveys or questionnaires; or
  • interact with customer care;
• We collect it when you visit the Softcard Website; and
• We obtain it from other sources (i.e., your wireless service provider, third parties), in connection with the operation and marketing of the Softcard App.

We collect the following types of information, including Personal Information:

At Softcard App Activation

• We collect information you provide such as your email address, Softcard Password, Softcard PIN and Security Questions and Answers; and
• We collect information we receive from your mobile device (which we refer to as a Softcard-Enabled Mobile Device) such as your e-mail address, mobile device type, mobile device number and the serial number of the chip in your Softcard-Enabled Mobile Device called the secure element, which is designed to store important data about your Payment Cards.

Payment Activity

• When you choose to load a Payment Card offered by a Participating Issuer on an Softcard-Enabled Mobile Device, we collect the type and brand of Payment Card used (for example, type may include credit, debit or prepaid, and brand may include MasterCard, Visa, American Express, Discover), the Payment Card issuer (for example, the Participating Issuer issuing the Payment Card), and partial Payment Card account numbers;
• When a Payment Card is used, we collect the fact that a particular Payment Card was used, the time and date of the transaction and may collect the identity of the Merchant where the Payment Card was used;
• For prepaid cards, in addition to the above information, we may also collect the card balance; and
• We may receive information about the status of your Payment Card (for example, whether it is suspended or cancelled) or any incentives or rebates you have received from your Payment Card issuer.

Commerce Activity

• When you choose a favorite Participating Merchant or a Participating Issuer, we collect which merchant or issuer you select in order to provide you with offers from that Participating Merchant or Participating Issuer;
• When you choose to add loyalty program information to your Softcard App, we collect information such as the program name, the loyalty program number, loyalty program user ID and password in order to present information such as your account balance from your loyalty program in the App;
• When you choose to provide your zip code or location information in order to see nearby offers and stores or see where to pay with your Softcard App, we collect that information;
• We also keep track of information about which offers you’ve selected and used (for example, if you use an offer, we collect the fact that the offer was presented to the Merchant); and
• If you use a Payment Card and/or a loyalty program in connection with an offer that you present, we will collect the fact that a particular Payment Card and/or loyalty program were used in connection with that particular offer.

Other Use of the App

• We may collect data regarding which features and functionality you access or use within the App. If we combine or link such information with Personal Information, we will treat the combined or linked information as Personal Information under this Privacy Policy; and
• We may offer programs and features that rely on your current location. We will ask for your permission before accessing or using that location information for any specified purpose.

Customer Care

When you call customer care or login to the Softcard Website for customer care, we may collect information, including Personal Information, as follows:

• Information you may provide to us for the administration, maintenance and use of your Softcard Account and the Softcard Services. This information may include name, address, zip code, a new email address, new Softcard password, Security Questions and Answers or any other information you provide;
• Information on whether your Softcar App was suspended or terminated; and
• Information about your interaction with the Softcard App that may help us protect you from fraud and other misconduct or address the issue you contacted us about.

Softcard Website Visits

When you visit the Softcard Website, we may collect information, including Personal Information, as follows:

• Information you provide, such as your name, mailing address, email address, phone number(s) and unique identifiers (such as your user login and password);
• Information you provide, directly or through a third party with whom we work (such as Find.ly), if you apply for a job, such as your résumé, current job and current employer, other employment-related information and information you make available from your social media accounts; and
• Information about your use of our Softcard Website.

We may collect this information either when you provide it directly or through the use of:

• Cookies or similar technologies to identify the computer or device, and to improve the quality of Softcard Services;
• Web-beacons (small graphic images on a Web page or an HTML e-mail that are generally invisible); and
• Software to collect data about your interactions with the Softcard Website, such as the time of your visit and whether you have visited the Softcard Website before.

You can manage cookies by using features and functions available on most Internet browsers. For example, most browsers will allow you to choose what cookies can be placed on your computer and to delete or disable cookies. You can find instructions for managing cookie controls on websites for particular browsers. Please note that disabling cookies may prevent you from using specific features on our Softcard Website.

If we combine or link cookie or web beacon information with Personal Information, we will treat the combined or linked information as Personal Information under this Privacy Policy. Softcard does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to “Do Not Track” signals.

We may advertise our products and services on third party websites. The use of cookies, Web-beacons or similar technologies by such third-parties is subject to their privacy policies – not this Privacy Policy.

Use of Your Personal Information

We use the information we collect, including Personal Information, in a variety of ways. For example, we may use some or all of the information, including Personal Information, we collect to:

• Provide Softcard Services;
• Create your account and respond to your inquires;
• Notify you about Softcard Service announcements, software updates, changes to the Terms of Service or the Privacy Policy, service alerts or other communication messages in connection with the operation of your Softcard App;
• Develop, operate, evaluate and improve Softcard Services, and to perform data analysis and research for those purposes;
• Market Softcard Services including promotions, sweepstakes, programs and other offers;
• Investigate, prevent or take action regarding violations of the Terms of Service or other acceptable use policies provided to you from time to time;
• Help ensure security and quality control, and for troubleshooting purposes;
• Comply with legal or regulatory requirements;
• Respond to regulatory authorities and auditors;
• Respond to a subpoena, court order or to establish our legal rights and defend against legal claims or other legal obligations;
• Protect against or prevent fraud/identity theft or other illegal activities;
• Manage risk; and
• Otherwise operate our business as permitted by law.

We may also use Aggregated Information and Anonymous Information for various purposes such as:

• To perform data analysis and research for the purpose of developing, maintaining and improving Softcard Services;
• To evaluate the helpfulness of Softcard messaging;
• To assess the effectiveness of offers provided by Softcard on behalf of Participating Merchants and other third parties; and
• To market and advertise Softcard products and services.

If you submit a job application or résumé or send a request via the Website, we use Personal Information to:

• Communicate with you and, subject to applicable law, to make current hiring decisions;
• To make future hiring decisions (applicant information is retained for purposes of future job openings unless an applicant indicates otherwise); and
• To comply with legal obligations, including regarding hiring and workforce diversity.

Sharing of Personal Information with Third Parties

We share information we collect, including Personal Information, with third parties who assist us in providing services and performing the activities described under the “Use of your Personal Information” heading above.

Whenever we share with third parties who perform services for us or on our behalf, we require them to agree to maintain appropriate safeguards designed to protect the security and the confidentiality of the Personal Information that we provide to them. We also limit their use of the Personal Information to performing the services requested, and limit the circumstances in which they may share the Personal Information with others.

We also may share your information, including Personal Information, with certain third parties as necessary to:

• Comply with legal or regulatory requirements;
• Respond to a subpoena, court order or to establish our legal rights and defend against legal claims or other legal obligations;
• Protect against or prevent fraud/identity theft or other illegal activities;
• Manage risk; and
• Otherwise operate our business as permitted by law.

We will not share your Personal Information with third parties for their own direct marketing purposes without giving you an opportunity to restrict such sharing.

We may share Aggregated Information and Anonymous Information with third parties for various purposes such as:

• To enable third parties to perform data analysis and research for the purpose of developing, maintaining and improving Softcard Services;
• To evaluate the helpfulness of Softcard messaging;
• To assess the effectiveness of offers provided by Softcard on behalf of Participating Merchants and other third parties;
• Otherwise operate our business as permitted by law; and
• To market and advertise third party products and services.

Information, including any Personal Information you provide to third parties in connection with your use of the Softcard App (for example, information you provide directly to Participating Issuers or Merchants), or when you travel to third party websites using links that appear on the Softcard Website, is not covered by this Privacy Policy.

Again, we encourage you to review the privacy policies of any third party to whom you provide information to understand what information will be collected and how it will be used or disclosed to others.

Protection of Your Personal Information

We maintain physical, electronic and administrative safeguards to protect your Personal Information against unauthorized access or use. Our information security procedures are assessed by internal and external professionals. We update and enhance our safeguards to the extent we determine it is warranted and feasible. We limit access to Personal Information to those employees and agents that we believe reasonably need such information for their particular role in providing Softcard Services, operating the Softcard System and otherwise operating the business. Our employees are subject to a corporate code of ethics and other policies that require them to protect the confidentiality of Personal Information of Users and Visitors. Violations may subject employees to disciplinary action, up to and including termination.

Please note that no data transmission or storage can be guaranteed to be 100% secure. We want you to feel confident using the Softcard System, but we cannot ensure or warrant the security of any information you transmit to us.

Retention of Personal Information

We retain Personal Information to provide Softcard Services, operate the Softcard System and to develop, enhance, maintain and augment Softcard Services. We will retain Personal Information for as long as we have a business need, or for any time period as applicable laws, regulations, or government orders require. When we dispose of Personal Information, we use reasonable procedures to erase or render it unreadable (for example, shredding documents and wiping electronic media). We may retain Aggregated Information and Anonymous Information for as long as we have a business need.

Updating of Your Personal Information

You can access and update your Softcard Account information in the Softcard App Settings, or by logging into our Website.

Children's Online Privacy

We do not knowingly collect Personal Information from children under the age of 13 unless we first obtain permission from the child’s parent or legal guardian. If we learn that we have inadvertently collected the Personal Information of a child under the age of 13 we will take steps to delete the Personal Information. You should be aware that Softcard Services used by families may be used by minors without our knowledge. Any Personal Information collected as a result of such usage will be associated with an adult User or Visitor of the Softcard Services, and will be treated accordingly under this Privacy Policy.

Changes to this Privacy Policy

We reserve the right to change this Privacy Policy, and any of the practices described in the Privacy Policy, at any time. If we change the Privacy Policy, we will post the most current version on our Website. If you are a User, we also will notify you of the change by Electronic Communications as defined in Section 7 of the Softcard Terms of Service.

Changes to Corporate Control

We may use and share your Personal Information, Aggregated Information and Anonymous Information with third parties in connection with a reorganization, sale, merger, or transfer of all or a portion of a business or operating unit.

Companies to Which this Privacy Policy Applies

This Privacy Policy applies to JVL Ventures, LLC, d/b/a Softcard (formerly known as Isis).

How To Contact Softcard

If you have any questions regarding this Privacy Policy, please contact us at: [email protected]. For all other questions, please call your wireless service provider.

---

Last Updated October 14, 2014