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    INCENTIVES SOLUTIONS LTD SERVICES PRIVACY POLICY.

    This policy covers the privacy practices that Incentives Solutions Ltd and its subsidiaries and affiliates (“Incentives” or “We”) employ when providing online services and related applications accessible via the Company Web site pursuant to Incentives’ Master Online Subscription Agreement (the “Services”).

    1. Information Collected

    We collect individually-identifiable information (“Personal Information”) from individuals who visit the Company’s Web site (“Web Site Visitors”) and individuals who register to use the Services (“Customers”). When expressing an interest in obtaining additional information about the Services or registering to use the Services, Incentives requires you to provide the Company with personal contact information, such as your full name, company or organization name, address, phone number, and email address (“Required Contact Information”>). When purchasing the Services, Incentives may require you to provide the Company with financial qualification and billing information, such as billing name and address, credit card number, and the number of users that will be using the Services purchased by you (“Billing Information”). We may also ask you to provide, or otherwise allow you to share, additional information, which you may choose to share in your registration for or use of the Services (“Additional Information”). Required Contact Information, Billing Information, and Additional Information about Customers are referred to collectively as “Customer Information”. As long as We provide you with the Services, Incentives may also collect information through the use of commonly- used information-gathering tools, such as cookies and Web beacons (“Web Site Navigational Information”). Web Site Navigational Information includes standard information from your Web browser, your Internet Protocol (“IP”) address, HTTP header information, and the actions you take on the Company’s Web site (such as the Web pages viewed and the links clicked).

    2. Use of Information Collected

    Incentives uses Customer Information to perform the services requested. Incentives may also use Customer Information for marketing purposes. For example, the Company may use information you provide to contact you to further discuss your interest in the Services and to send you information regarding Incentives, its affiliates, and its partners, such as information about promotions or events. Please view the Communications Preferences section of this Privacy Policy to control how your respective Customer Information is used for marketing purposes. Incentives uses Billing Information solely to check your financial qualifications and collect payment for the Services. Incentives uses Web Site Navigational Information to operate and improve the Company’s Web site. The Company may also use Web Site Navigational Information alone or in combination with Customer Information to provide personalized information about the Company and the Services. For additional information about the use of Web Site Navigational Information, please review Section 3 of this Policy. Incentives may use both Customer Information and Web Site Navigational Information to enforce the Company’s Web site policies, or to protect the Company’s rights and intellectual property or the rights of others using the Company’s Web Site or the Services.

    3. Cookies, Analytics/ Log Files

    Incentives uses commonly-used information-gathering tools, such as cookies and Web beacons, to collect information from your computer or mobile device as you navigate the Company’s Web site, interact with e-mails sent by the Company on its own behalf, or use the Services (“Web Site Navigational Information”). This section describes the types of Web Site Navigational Information used on the Company’s Web site and in connection with the Services, and how this information may be used.

    Cookies

    When visiting Incentives Web site or using the Services, We use session “cookies” – a piece of information stored on your computer – to allow the web site or Services to uniquely identify your browser while you are logged in and to enable Incentives to process your online transactions. Session cookies also help us confirm your identity and are required in order to use the Service. We use persistent cookies that only We can read and use, to identify a user as an Incentives’ customer and make it easier for you to log in to the Services. Users who disable their web browsers’ ability to accept cookies will be able to browse our Web site, but will not be able to access or take advantage of the Service.

    Analytics/Log Files

    As is true of most web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site, and to gather demographic information about our user base as a whole. We do not link this automatically-collected data to personal information.

    4. Information Sharing

    Except as described in this policy, Incentives will not give, sell, rent or loan any Customer Information to any third party. Incentives may share Customer Information with: (i) Incentives’ contracted service providers, such as payment processors, so that these service providers can provide services on our behalf; (ii) with Incentives’ service providers to ensure the quality of information provided; (iii) with other members and affiliates of Incentives in order to work with them, or with other companies or business partners to jointly offer products or services. Incentives may use a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use Billing Information except for the sole purpose of credit card processing on Incentives’ behalf. We may also disclose Customer Information to respond to subpoenas, Court orders, or legal process, or to establish or exercise our legal rights and defend against legal claims.

    5. Data Retention

    We retain the information we receive as described in this Privacy Policy above for reasonable duration, for example, as the case may be, for as long as needed to provide our Services, comply with our legal obligations, resolve disputes, establish legal defenses, to conduct audits, pursue legitimate business purposes, and enforce our agreements.

    6. Services Data

    As part of using our Services, Customers may submit electronic data or information to the Services (“Services Data”) which may include Personal Information. The Company generally has no direct relationship with the individuals to whom Services Data may pertain, which we process on the behalf of our Customers. Any uses of Services Data by the Company are done so pursuant to Incentives’ Master Online Subscription Agreement in place between Incentives and the relevant Customer (or his/her organization), which exclusively govern Incentives’ treatment of Services Data and supersede this Privacy Policy in case of conflict, or as required by law. If Personal Information pertaining to you as an individual has been submitted to us by a Customer as Services Data and you wish to exercise any rights you may have to access, correct, amend, or delete such data, you should inquire with the Customer (or his/her organization) directly. If an authorized Customer requests that we remove or update the data in question and the Customer has no ability to do so via use of the Services, we will respond to their request within 30 business days.

    7. Data Security

    Incentives takes precautions, including administrative, technical, and physical measures to help safeguard Customer Information against loss, theft, and misuse as well as unauthorized access, disclosure, alteration, and destruction as set forth in Incentives’ Master Online Subscription Agreement. We shall maintain appropriate safeguards to ensure the confidentiality and security of the Customer Information submitted to us, and promptly inform Customer about any unauthorized or unintentional access to or disclosure of Customer Information. Customer and any of their users are solely responsible for protecting their passwords, limiting access to their computers, and signing out of the Services after their sessions.

    8. Changes to Privacy Policy

    Incentives reserves the right to change this Privacy Policy from time to time. Incentives will provide notification of the material changes to this Privacy Policy through Incentives’ Web site at least thirty (30) business days prior to the change taking effect.

    9. Contacting Us

    Questions regarding this Privacy Statement or the information practices of the Company’s Web sites should be directed to Incentives at legal@incentives-solutions.com or by mailing Incentives Offices.

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