Augeo privacy policy

Augeo Affinity Marketing, Inc. and all its affiliated companies, including Augeo Affinity Insurance Services, Inc., Couch Braunsdorf Affinity, Inc., Augeo Incent, LLC, Augeo Digital, LLC, Performance Plus Marketing, LLC, Augeo Incentive Logic, LLC, MotivAction LLC, Rapid Reward Fulfillment, LLC, Augeo Structural, Inc., and Augeo Experiences, LLC, Cirkel Innovations LLC, Intride Loyalty, LLC, and NorthLoom Innovations, LLC (collectively "Augeo") are dedicated to respecting and protecting your personal privacy. This privacy policy explains how we collect, share, use, and protect information when you visit or use any Augeo website or online platform (collectively, the "Sites").

Please read this notice carefully to understand what we do, and how we collect, share and protect your personal information. As you review this privacy policy, here are a few general principles to keep in mind:

• Our online services are not intended for children under the age of 13. We do not knowingly collect personal information from, or market our products and services to children under 13. Parents can contact our customer service department to access, change, or delete the personal information that has been submitted by a child. If we become aware that a child under the age of 13 has provided us with personal information, we will delete it.
• As a member or user of an Augeo product or service, we will use and share the information that we collect from or about you in accordance with the details below, which provide you with certain choices with respect to the use and sharing of your personal information.

Information we may collect

Personal information

When you visit our Sites, we may collect personal information from or about you when it is entered by you or sent to us, including but not limited to:

• Information you provide to us by completing forms: For example, your name, contact, and address information, and any other information you may provide in the forms on our Sites;
• Information you provide to us by contacting us: Any personal information you may provide to us when you email or call us, such as name, phone number, employer, and any other details you provide in your communications. Augeo may also request your contact information for the purpose of having someone contact you for additional information, or in response to your request for information from us;
• Transaction information when you purchase products or services from us: For example, if you make purchases with your credit card, we may use your credit card information for shipping, billing, and credit card validation purposes;
• Login information, such as username and password, that you may use in connection with our services;
• Information we may receive from your financial institution, such as payment card data and other transactional information;
• Information we may receive from your employer, such as credentials, employer identification information, and other information you have provided to your employer; and
• Information about your activity through our products and services, including your device information, such as your IP address, the type of device or browser you use, and your actions on our Sites.

We may also receive information about your transactions directly from your financial institution in order to process your rewards or redemptions transactions.

Usage and other information

In addition to the personal information described above, we may collect certain information about your use of our online services. For example, we may log the IP address of the device you use to connect to our online service, the type of operating system and browser you use, information about the website you came from, the parts of our online service you access, and the site you visit next. We or our third-party partners may also use cookies, web beacons or other technologies to collect and store other information about your visit to, or use of, our online services. In addition, we may later associate the usage and other information we collect online with personal information about you.

Additional sources of information

Augeo may also collect information about you from additional online and offline sources, including from co-branded partner sites or commercially available third-party sources. We may combine this information with the personal and other information we have collected about you under this Privacy Policy. Please note that these third-party websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Use of information

We use the information discussed above in a number of ways, such as:

• Processing reward or redemption transactions;
• Verifying your identity (such as when you access your account information);
• Preventing fraud and enhancing the security of your account or our online services;
• Responding to your requests and communicating with you;
• Reporting program activities to our client program owners;
• Managing your program preferences;
• Performing analytics concerning your use of our online services, including your responses to our emails and the pages and advertisements you view;
• Providing you tailored content and marketing messages on behalf of our clients and partners;
• Monitoring our Sites' performance;
• Operating, evaluating and improving our business (including developing new products and services, improving existing products and services, performing data analytics, and performing internal functions such as accounting and auditing);
• Evaluating or conducting a corporate transaction, such as a sale, consolidation or merger of Augeo businesses;
• Complying with and enforcing applicable legal requirements, relevant industry standards, contractual obligations and our policies; and
• For any other purposes that we may specifically disclose at the time you provide or we collect your information, in accordance with your direction, request, or consent.

We may also use data that we collect on an aggregate or anonymous basis (such that it does not identify any individual customer, directly or indirectly) for various business purposes, where permissible under applicable laws and regulations.

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.

Sharing of information

Augeo may share the information we collect from and about you with our affiliates and other third parties to bring you a range of quality and reliable products and services designed to meet your needs. For example, we may share your information with:

• Augeo third-party service providers like merchandise reward fulfillment, travel fulfillment and mailing service suppliers;
• Augeo affiliated websites and businesses in an effort to bring you improved service across our family of products and services, when permissible under relevant laws and regulations;
• Other companies to bring you co-branded services, products or programs;
• Third parties or affiliates in connection with a corporate transaction, such as a sale, consolidation or merger of Augeo businesses; and
• Other third parties to comply with legal requirements such as the demands of applicable subpoenas and court orders; to verify or enforce our terms of use, our other rights, or other applicable policies; to address fraud, security or technical issues; to respond to an emergency; or otherwise to protect the rights, property or security of our customers or third parties.

Where appropriate, we will limit sharing of your information in accordance with the choices you have provided us.

We may share anonymous or aggregated information (such that it does not identify any individual customer, directly or indirectly) with third parties to help deliver products, services, and content that are tailored to the users of our online services and for other purposes. Otherwise, Augeo will never sell or rent any of your personal information, and we will never share your personal information publicly without your consent. Augeo also does not disclose sensitive personal information for purposes other than those permitted by applicable law.

In the past year, we have needed to disclose personal identifiers (such as names, phone numbers, postal addresses and email addresses) to our service providers so that we can deliver our products and services. We have also shared information about the Internet and website usage with our service providers and partners in order to provide updates about relevant products and services, to display targeted advertisements, and to maintain the security of information.

Cookies, web beacons, and other tracking technologies

We, our service providers, and other companies we work with may deploy and use cookies, web beacons, and other tracking technologies for various purposes, such as fraud prevention, monitoring our advertising, and assessing our marketing campaign performance. Some of these tracking tools may detect characteristics or settings of the specific device you use to access our online services.

"Cookies" are small amounts of data a website can send to a visitor's web browser. They are often stored on the device you are using to help track your areas of interest. Cookies may also enable us, our service providers or other companies we work with to analyze your use of our online services over time to customize your experience. Most web browsers allow you to adjust your browser settings to decline or delete cookies, but doing so may degrade your experience with our online services.

Clear GIFs, pixel tags, web beacons are typically one-pixel, transparent images located on a webpage or in an email or other message. These, or similar technologies may be used on our Sites and in some of our digital communications (such as email or other marketing messages). They may also be used when you are served advertisements or you otherwise interact with advertisements outside of our online services. These are principally used to help recognize users, assess traffic patterns and measure site or campaign engagement. Our Sites do not respond to Do Not Track signals.

Sometimes cookies are placed by us ("first-party cookies") and sometimes they are placed by others ("third-party cookies").

The cookies that we place on your device may include:

• Essential cookies: these cookies are essential for the basic features of our Sites to function, allowing you to navigate and use our Sites. Without these cookies, the services you have asked for could not be provided.
• Analytics cookies: these cookies collect information about how you use our Sites, for example, which pages you go to most often and how visitors navigate the Sites. Much of the information collected by these cookies is aggregated and anonymous, and is only used to improve how our Sites work.
• Functionality cookies: these cookies enhance your browsing experience, allow our Sites to remember the choices you make (such as your user name, language, last action, and search preferences), and provide enhanced, more personal features. Information collected by these cookies may include personal information you have disclosed.
• Marketing cookies:also known as advertising cookies, these cookies are used to deliver advertisements more relevant to you and your interests. They are also used to limit the number of times you see an advertisement on our Sites and help measure the effectiveness of the advertising campaign. In some cases, our partners may use cookies to provide us with information about your interactions with their services. These cookies remember that you have visited a website, and this information is shared with other organizations such as advertisers. All third-party cookies are subject to the third-party service's policies.

Augeo's use of cookies

Augeo uses cookies and related technologies on our Sites to enhance your experience, improve our Sites, and deliver ads that are relevant to you. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.

Specifically, we use a mix of first-party cookies, third-party cookies, and other similar technologies to:

• Recognize you whenever you visit our Sites (this speeds up your access so you do not have to log in each time);
• Support security and authentication features on our Sites;
• Obtain information about your preferences and use of our Sites;
• Carry out research and statistical analysis to help improve our content, products, and services, and to help us better understand our users' requirements;
• Improve the speed and performance of our Sites and services; and
• Make your online experience more enjoyable and efficient and keep our advertising relevant to your interests.

Consent and managing cookies

The first time you visit our Sites, a cookie banner is displayed describing our use of cookies and linking to a cookie management tool. You can either "Reject" all cookies, "Accept" all cookies, or manage individual categories of cookies by clicking the "Preferences" button to display our cookie management tool. You can opt-out of all non-Essential cookies by clicking on the "Reject" button on the cookie banner at the bottom of the site homepage. You may also do the same by clicking on the "Reject all" button in the cookie management tool. By using our Sites, you agree that we can place cookies and similar tracking technologies on your device consistent with your cookie preferences and this Privacy Policy. You have the ability to manage your cookies and similar tracking technologies preference at any time using the "Cookie Preferences" button on the bottom of the homepage.

Your browser may give you the ability to control some types of cookies. If you want to customize the kinds of cookies you can control, you can change your browser settings so that certain types of cookies are not accepted. Please be aware that the cookie selections you make may override your browser or any adblocker settings.

If you turn off any cookies, please be aware that you may lose some of the functionality of our Sites. For more information about cookies and how to disable them please check the following resource: https://www.allaboutcookies.org/

Online advertising

You may see advertisements when you use some of our online services. These advertisements may be for our own products or services, or for products and services offered by third parties. Which advertisements you see is often determined using the information we, our affiliates, service providers, and other companies that we work with have about you, including information about your relationships with us (e.g., types of accounts held, transactional information, location of activity). To that end, where permitted by applicable law, we may share with others the information we collect from and about you.

You can opt-out of online behavioral advertising cookies and similar technologies by using the Digital Advertising Alliance's Consumer Choice Tool available here, or if located in the European Union you can make your choices here. Please note you may continue to receive generic ads regardless of your cookie-related choices.

If you opt-out of these personalized advertising cookies, your opt-out will be specific to the web browser or mobile device from which you accessed the opt-out. If you use multiple devices or browsers, you will need to opt-out each browser or device that you use.

Linking to third-party websites

Augeo may provide links to websites that are owned or operated by other companies ("third-party websites"). When you use a link online to visit a third-party website, you will be subject to that website's privacy and security practices, which may differ from ours. You should familiarize yourself with the privacy policy, terms of use, and security practices of the linked third-party website before providing any information on that website.

Transferring your information

Because Augeo is a US-based company, your information may be collected and processed in the United States. Additionally, as part of the products and services offered to you through our Sites, the information which we collect about you may be transferred to, and stored in, one or more countries other than where you currently reside. For example, this may occur if any of our servers or third-party service providers are located in a country other than yours. These countries may have different data protection laws than your current residence. 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 Privacy Policy.

Augeo participates in the EU-US Data Privacy Framework, the UK Extension to the EU-US Data Privacy Framework, and the Swiss-US Data Privacy Framework (collectively, the "Data Privacy Frameworks") as set forth by the US Department of Commerce regarding the processing of personal information from the European Economic Area, the United Kingdom and Gibraltar, and Switzerland. Augeo's participation in and adherence to the Data Privacy Frameworks and the DPF Principles applies solely to, its U.S. entities. The Data Privacy Frameworks and DPF Principles do not extend to personal information processed by any non-U.S. affiliate. Augeo has further certified that we adhere to the principles of the Data Privacy Frameworks. Click https://www.dataprivacyframework.gov/ to learn more about the Data Privacy Frameworks. If there is any conflict between the terms in this Privacy Policy and the Data Privacy Frameworks principles, the principles shall govern.

Augeo will only process your personal information in ways that are compatible with the original purpose for which it was collected, or for purposes authorized by you. Before we use your personal information for a purpose that is materially different than the purpose we collected it for or that you authorized, we will provide you with the opportunity to opt out. Augeo maintains reasonable procedures to help ensure that personal information is reliable for its intended use, accurate, complete, and current.

When we collect sensitive personal information, we will obtain your express opt-in consent where the Data Privacy Framework principles require, including if we disclose your sensitive personal information to third parties, or before we use your sensitive personal information for a different purpose than we collected it for or than you later authorized.

If Augeo transfers personal information received under the Data Privacy Frameworks to a third party, the third party's processing of the personal information must also be in compliance with our Data Privacy Frameworks obligations, and we will remain liable under the Data Privacy Frameworks for any failure to do so by the third party, unless we prove we are not responsible for the event giving rise to the damage.

Augeo is subject to the investigatory and enforcement powers of the US Federal Trade Commission. In certain situations, Augeo may be required to disclose the personal information we process under the Data Privacy Frameworks in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Basis for processing - European Union residents

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.
• Consent: We may ask your consent to process your personal information in some situations.
• 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 for delivering our services, fraud prevention, quality assurance, and 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.

Security

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 the website URL to start with https:// or have a lock symbol, such as the one shown below:

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

As another security measure, Augeo enforces session timeouts after several minutes of inactivity on our Sites and products. To ensure your security, in some cases we ask that you re-enter your User ID and password to resume your activity.

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.
• Use 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.

Controlling your personal information

This Privacy Policy describes above how and why Augeo processes and shares your personal information, and the below describes under which circumstances you can limit certain activities. Whenever we process your data for the reasons listed above, we will ensure that we always keep your personal data rights in mind.

Updating your information

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 refer to the "Know Your Rights and Options" section below.

Know your rights and options

Users or website visitors residing in certain states, countries or regions with enhanced data protection laws may be afforded certain additional rights regarding their personal information. Except where an exception or exemption applies, the rights may include those set out below:

• The right to request access to the information we have collected about you, as well as the right to review our data collection and sharing practices related to you. U.S. State laws may give you the right to request that we disclose the personal information we have collected about you over the past 12 months, which we only provide after we receive and validate your request.
• The right to request collection or deletion of your personal information that we hold about you. You have the right to request erasure of your personal information, subject to certain exceptions, such as when we have a legal obligation to retain the data in question. After we receive and validate your request, we will correct or delete your personal information, unless an exception applies.
• The right to request a digital copy of the personal information that we hold about you.
• The right not to be discriminated against due to your exercise of any of the preceding rights. Unless an exception applies, this includes our promise not to: deny you goods or services; charge you different prices or rates for goods or services, including granting discounts or other benefits, or imposing penalties; provide you a different level or quality of goods or services; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
• The right to object to or restrict processing. You have the right to object to or opt out of the processing of your personal data under certain circumstances. You also have the right to request that we restrict processing some types of personal data under certain circumstances.
• The right to withdraw consent. If we have requested your consent in order to process your personal data, you have the right to withdraw your consent for such processing at any time where this right is provided by local law.

While these rights are not globally applicable, all of our customers are entitled to request access to the personal information that we hold about them. To ensure that your personal information is accurate and complete, please contact us through the email address below regarding any errors or updates affecting the personal information that we may hold.

You may request any of the above rights by sending your request to privacy@helloaugeo.com or by calling us at 888-213-3331. Please provide your name, company name (if applicable), phone number, email address, and the scope of your request. You may also designate an authorized agent to exercise certain privacy rights on their behalf and should make any such request by contacting the above email address. To protect your privacy and security, Augeo may take reasonable steps to verify your identity before granting access to, correcting, or deleting data. We will generally respond to your request for information within 45 days, unless a longer response time is necessary, in which case, you will be advised accordingly. Please note that we may retain or process certain information as required by law or as necessary for our legitimate business purposes. If you have an applicable disability, you may also contact us at the above email address to request access to this Privacy Policy in an alternative format. We will reply as quickly as possible and inform you of the steps, if any, that have been or will be taken in order to address your concern or implement the suggestion.

You may also have the right to request that we not disclose their personal information to third parties for interest-based targeted advertising. Please note that Augeo does not engage in the "sale" of your personal information as defined by California law.

You have the right to appeal our refusal to take action on a request relating to the above rights. Appeals can be initiated by email to privacy@helloaugeo.comand marking your request as an "Appeal". We will resolve your appeal within the time frames established by applicable law. If your appeal is denied, we will explain why. If you continue to dispute our decision or would like to file a complaint regarding our handling of your personal information, you may contact the regulator in your jurisdiction that handles privacy complaints, such as your state Attorney General.

If you have a question or complaint about our handling of your personal information under the Data Privacy Frameworks, please contact us at privacy@helloaugeo.com.

Augeo has appointed a Data Protection Officer 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 privacy questions or concerns about how Augeo processes your personal data, please contact us by emailing privacy@helloaugeo.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.
• EU Residents: Visit the European Commission website at https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm, and find the data protection authority for your country.

If you have complaints related to the Data Privacy Frameworks that Augeo cannot resolve directly, we have chosen to cooperate with the International Centre for Dispute Resolution (the "ICDR"). The ICDR is an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://go.adr.org/dpf_irm.html for more information or to file a complaint. The services of the ICDR are provided at no cost to you.

As further explained in the Data Privacy Frameworks principles, binding arbitration is available to address complaints not resolved by other means. More information can be found here: https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction.

Updates to this online privacy policy

We may change this Privacy Policy from time to time. When we do, we will let you know by appropriate means such as by posting the revised policy on this page with a new "Last Updated" date. Any changes to this Privacy Policy will become effective when posted unless indicated otherwise. This Privacy Policy was last updated July 14, 2026.