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Privacy Policy
SWEET PRIVACY POLICY
September, 2019

SocialSweet Inc. dba Sweet ("Sweet". "we", or "us" "Company") respects the privacy rights of its Platform users. The following "Privacy Policy", effective as of the date shown above, describes our information collection, use, sharing and management practices in connection with the Platform, as well as any circumstances under which we may disclose information collected from you and includes by reference Sweet's Platform Terms of Use, available at sweet.io/terms. Unless otherwise defined herein, all defined terms in Sweet's Platform Terms of Use are also incorporated herein by reference.  You are referred to herein as "you," or "your"

GENERAL TERMS
By using the Platform, you acknowledge that you have read, understand and agree to be bound by this Privacy Policy or any future Privacy Policy we post at sweet.io/privacy. If you do not agree to these terms, please delete your Account immediately.

By submitting Personal Information (as defined below) through the Sweet App / Platform, you agree to the terms of this Privacy Policy and you expressly consent to the collection, use and disclosure of your Personal Information in accordance with this Privacy Policy.

INFORMATION YOU PROVIDE TO US
To maximize your user experience, we may ask you to provide information about yourself including information that could be used to personally identify or contact you (such as your name, telephone number, email address, or home address) ("Personal Information").  We may collect Personal Information at various times over the course of your use of the Platform, including but not limited to, when you create an Account, register with a Brand as a fan, post on the Platform or other social media sites, redeem rewards, access content, participate in a survey, promotion or other feature of the Platform, request information, submit comments, or otherwise use the Platform. "Non-Personal Information" means data that is not associated with or linked to your Personal Information; Non-Personal Information does not, by itself, permit the identification of individual persons and, therefore, this policy does not limit or restrict in any way our ability to use or disclose Non-Personal Information. If you do not consent to our unrestricted use of Non-Personal Information, please delete your Account immediately.

The Platform includes functionality for processing redemptions in "Sugar" between Sweet accounts on the Platform.  "Sugar™" is the name of Sweet's loyalty reward unit (point) used to reward Users for (among other things) engaging with the Platform and performing User actions, and used by Users for (among other things) redeeming for Rewards on the Platform. Sugar is akin to "loyalty points" or a "mileage program" where users can earn and redeem Sugar like they would with points or miles, but as stated in Sweet's case it is branded as Sugar to be used on the Sweet platform.

When you make a purchase via a third party form of payment such as a credit card, debit card, Paypal account or other approved payment, you will need to submit your financial and other billing information for secure processing directly to a third party payment service who will be clearly identified to you prior to the transaction.  Sweet will not capture, record or in any way store or process your payment account details for the form of payment used in these transactions.  However, our third-party processor may share non-sensitive financial or billing information (e.g. records and receipts) with us in order for us to verify and complete transactions and track and process payments for any fees collected by such third parties.

INFORMATION RECEIVED FROM THIRD PARTIES
The Platform includes integrations with third party applications, streaming services and social networking sites and we may also make available on the Platform certain interactive services like bulletin boards, chat rooms, blogs, forums, etc. (collectively, "Interactive Services"). Any information that you post or share through these Interactive Services becomes public information and is not subject to the provisions of this Privacy Policy.

You can login with, and post to many of your own social media and other application accounts on third party services through the Platform. To enable Platform features that require access these accounts, you may be asked to provide us your access credentials for that third party service. Sweet may store your access credentials and/or an access token or similar Oauth credentials obtained from the third party service for any such account  (collectively, "Connected Accounts"), so that you are able to access those third party services without entering your access credentials again. You are solely responsible for deciding which of your accounts on third party services you connect to the Platform. If you do not wish to provide Sweet access to any given account, you must cancel the access in your Sweet Account and not reconnect by declining to enter your credentials when prompted.

If you choose to enable any Connected Accounts, you allow us to monitor any Connected Account and collect (or the third party to share) data about you and your activity through using your account credentials which you have provided to Sweet (collectively, "Connected Account Data").  Connected Account Data may include any data made available through the third-party service's application programming interface (API) or publically available on their service, such as your public identity on their service, the content of your social posts, play lists, lists of your friends and followers, "likes", location and other activity and usage data.

The information we collect about you through the Platform may also be supplemented with information from third parties.

In any case where we receive data about you from a third party or through a Connected Account, we will treat any personally identifiable information collected as Personal Information under the terms of this Privacy Policy, unless we have disclosed otherwise.

INFORMATION WE COLLECT AUTOMATICALLY
Whenever you interact with the Platform either on a Sweet owned website or through an integration on a Brand or Affiliate owned website, we and our partner Brands and Affiliates, third-party service providers and advertisers may use various technologies (such as analytics software, device identifiers or a small data file or persistent "cookie" which is transferred to your device or browser for access on future visits to the Platform) that automatically collects information about how you access and use the Platform ("Usage Information"). Usage Information may include your browser or device type, operating system, the page served, the time and location, the preceding page views, and your use of features or applications on the Platform, such as the User Actions you have taken, Brand or Affiliate websites you visit, what content you access via the platform, the amount of time you spend using the Platform, the amount of time you spend engaged with a specific piece of content, On-Platform Purchase history, rewards and redemption history and other similar information.  The use of similar technologies including cookies by third party providers is not subject to this privacy policy.

HOW WE USE INFORMATION WE COLLECT
We use the information we collect from and about you for a variety of business purposes, including to verify that you have completed actions to earn rewards; to personalize and enhance your experience such as tailoring content, recommendations, advertisements or the Reward shopping experience; to provide access to certain features of the Platform; to communicate with you about your account and changes to any of our policies; to comply with various local, state and Federal laws; and to help us understand how we can improve the Platform and other internal business purposes. In addition, we may use your Personal Information for other purposes for which you otherwise provide your consent.

SHARING OF PERSONAL AND NON-PERSONAL INFORMATION
Except as provided in this Privacy Policy, we will not share any of your Personal Information to any third party without your specific consent and will not sell or otherwise provide to any 3rd party your User Data in a form that is directly linked to your Personal Information without your consent.

We may share non-Personal Information, such as aggregate user statistics, demographic information, anonymized Usage Information or Connected Account Data, with third parties (including Brands, Affiliates, and other partners, service providers and advertising partners) without your consent.

We may also share your information as disclosed at the time you provide your information (such as in connection with a specific registration, promotion or User Action), and as otherwise described in this Privacy Policy.  In particular, Brands may create User Actions or Rewards which may require you to submit Personal Information to the Platform which will then be shared with the Brand.  If you do not wish to share the requested information, your remedy is to not take the User Action or get the Reward.

Our platform is designed to help you engage with your favorite Brands and receive rewards for taking User Actions provided by those Brands. An important aspect of the platform is to ensure that actions are taken by real people and thus many features of the Platform require sharing of Personal Information, Usage Data or Connected Account data with a Brand in order to function for that Brand. Thus, you will be unable to use Restricted Areas of Platform functionality deployed on a particular Brand's website unless you explicitly "Follow"or "Join" the brand by clicking the "Join", "Follow" button, or similarly labeled button, on the Brand's hub within the Sweet app, provide your consent and complete the registration process. Such Brands are referred to as "Your Joined Brands". You consent to us sharing your Personal Information shown in your Sweet user profile and future updates to that Profile with all of Your Joined Brands. We may provide to any of Your Joined Brands, any of your un-anonymized User Information collected by Sweet through functionality of the Platform deployed on that Brand's website. Sweet may also provide to any of Your Joined Brands any un-anonymized information, including certain Usage Information and Connected Account Data, necessary for the Brand to verify, execute and/or audit User Actions you take which are rewarded by that specific Brand, whether on or off-the Platform, and Rewards or other features you specifically request from that Brand.  Additionally, Your Joined Brands may have access to un-anonymized Connected Account Data that Sweet, in its sole discretion, deems related to that Brand, and any other transaction data on the Platform related to transactions between you and that Brand. Your Joined Brands will not have access to other un-anonymized User Information or Connected Account Data, including such data for other of Your Joined Brands unless Sweet decides, and you consent, to share this data with the Brand.  We are not responsible for what any of Your Joined Brands do with information we share with them under the provisions of this Privacy Policy and any information disclosed to one of Your Joined Brands may be retained by them and will be subject to each of their own privacy policies.

In addition, we may share your information in the following circumstances:

Third Parties Providing Services On Our Behalf: In order to make various features, services and materials available to you through the Platform, and to respond to your request, User Actions, Reward transactions, and inquiries, we may share your Personal Information with third parties that perform functions on our behalf (or on behalf of our Brands or Affiliates). These may include Brands and their Affiliates, companies or individuals that host or operate the Platform, execute transactions or fulfil orders, analyze data or provide customer service, third-parties services associated with your Connected Accounts, and advertisers.

Your Agreement To Have Your Personal Information Shared: While using the Platform, you may opt-in to the sharing of your information with a third party, including Brands and their Affiliates, or such third parties as social networking sites. If you agree to have your Personal Information shared, your Personal Information will be disclosed to the third party. Any Personal Information you disclose will be subject to the privacy policy of that third party, not Sweet.

Business Transfers. We may share your Personal Information with other entities and affiliates in the family of companies controlled by Sweet for business and operational purposes. As our business evolves, we may purchase or sell assets. If another company acquires our company, business, or our assets, that company may possess the Personal Information, Usage Information and Connected Account Data collected and stored by us and will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy, though we cannot guarantee that the acquiring company will comply. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered one of our assets and as such may be sold or transferred to third parties.

Your Feedback. Any non-personal information you provide to us, either publicly or privately, as feedback or in response to other user's feedback, including, but not limited to, feedback, data, answers, questions, comments, suggestions, plans, ideas or the like (collectively "Feedback"), shall be deemed to be non-confidential and we assume no obligation to protect such Feedback from disclosure.  You understand, acknowledge, and agree that if you submit any such Feedback to us, it shall in no way prevent Sweet, Brands, the Platform and our Affiliates, from using such Feedback for any purpose whatever, and we shall be free to reproduce, use, disclose and distribute such Feedback without restriction.

Legal Disclosure. Under certain circumstances, we may be required to cooperate with legal investigations and/or we may be subject to legal requirements to disclose information collected through the Platform, such as a by court or a governmental agency. Our policy is to provide such cooperation and comply fully with all such legal requirements. We may also disclose Personal Information to investigate any violation or potential violation of the law, this Privacy Policy, or the Sweet Terms and Conditions or to protect or defend the rights or property of Sweet or users of the Platform. If we make a Necessary Disclosure, we will not be responsible for the use of such disclosed Personal Information by the third party to whom the Necessary Disclosure was made. If you do not consent to such Necessary Disclosures, please do not provide us with any Personal Information and delete your Account immediately.

YOUR CHOICE AND ACCESS
E-mail and mobile phone numbers are important communication channels for the Platform.  By creating an Account you consent to receive communications from us and our Brands and Affiliates via phone, e-mail, SMS texts ("External Communications") or by posting notices on the Platform ("Platform Communications") (collectively "Communications"). You may opt-out of any External Communications from the Platform that are not Account or Service related. To do so, either modify your account settings, send us an email at unsubscribe@sweet.io, or follow the removal instructions in the specific communication that you receive. Your opt-out request will be processed within 10 business days of the date on which we receive it. To be removed from Platform Communications or Account and Service related Communications, you may request deletion of your Account and discontinue use of the Services. To delete your Account please submit this request via the Contact Us area and follow the procedures provided. We are not responsible for Communications sent by a Brand or Affiliate except when sent using the Platform.

You may at any time request that we remove a Brand from Your Joined Brands and end sharing of your information with that Brand as described above by modifying your account Settings or sending us an email at unsubscribe@sweet.io. If a Brand is removed from Your Joined Brands, you will no longer be able to access the Platform functionality on that Brand's website or otherwise receive Sugar from that Brand for User Actions.

You may at any time request that we not share your Personal Information with third parties other than Your Joined Brands.

To modify, verify or delete any of your Personal Information that we have collected including the User Profile which is shared with Your Joined Brands, you may edit your account user information or contact us at the above email address.

In accordance with our routine record keeping, we may delete certain records that contain Personal Information you have submitted to us. We are under no obligation to store your Personal Information indefinitely, and we disclaim any liability arising out of, or related to, the destruction of your Personal Information. Please note that it is not always possible to completely remove or delete all of your information from our databases without retaining some residual data because of backups and other reasons.

Finally, please be aware that we do not control any privacy settings and preferences maintained by third parties. If you wish to make changes to those settings and preferences, you must do so through the options provided by the third party.

ADVERTISING/BEHAVIORAL TARGETING; HOW TO OPT OUT
In order to provide more relevant advertisements to you, we may use technology to serve advertisements on the Platform. We may use third parties to serve these advertisements. We may also use third party analytics vendors to evaluate and provide us with information about the use of the Platform. We do not share Personal Information with these providers unless you have expressly authorized us to do so. However, like other advertising service vendors, they may place and access cookies, web beacons, or similar technologies on your device or browser, and they may otherwise collect or have access to information about you, including Usage Information. We and our Brands, Affiliates and partners may target advertisements for products and services in which you might be interested based on your use of the Platform, and visits to other websites. The use of cookies, web beacons, or similar technologies by third party providers is subject to their own privacy policies, not ours.

If we deploy targeted advertising on our Platform and you do not want to receive the benefits of targeted advertising, you may opt out of some network advertising programs that use your information by visiting the NAI Opt-Out Page at http://www.networkadvertising.org. Please note that even if you choose to opt out through the NAI Opt-Out Page, you may still see advertisements while you're browsing online. However, the advertisements you see may be less relevant to you and your interests. Additionally, many network advertising programs allow you to view and manage the interest categories they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. The NAI Opt-Out Page provides a tool that identifies its member companies that have cookies on your browser and provides links to those companies.

SECURITY OF YOUR INFORMATION
Sweet follows industry-standard security measures (e.g. firewalls, encryption tools) on Platform and our technical infrastructure to protect against the loss, misuse and unauthorized alteration of Personal Information in our possession and control.

Please be aware that, although we endeavor to provide security for information in our possession and control, no security system can prevent against all potential security breaches, and we bear no liability for uses or disclosures of Personal Information or Non-Personal Information arising in connection with the theft thereof. Likewise, Platform users are responsible for safeguarding the confidentiality of passwords (including those to access Facebook, Instagram, Spotify and Twitter), and we bear no liability for access to, or use or disclosure of, Personal Information, if such access, use or disclosure arises in connection with the theft or disclosure (whether intentional or negligent) of a password. Please note, however, that we cannot ensure the security of any information you transmit to us or that we store. You use the Platform and provide us with your information at your own risk.

CHILDREN'S PRIVACY.
The Platform is not intended for use by users under the age of 13. Sweet will not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to create an Account on the Platform with or without parental consent. In the event that we learn that we have collected Personal Information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us immediately at privacy@sweet.io.

CONSENT TO PROCESSING AND TRANSFER OF INFORMATION
We operate the Platform in the United States and Brands may be in the United States or other countries. Our use of your information may involve the transmission of data on an international basis. If you are located outside of the United States, please be aware that information we collect may be transferred to and processed in the United States. By using the Platform, or providing us with any information, you consent to the collection, processing, maintenance and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside and/or are a citizen.

Any non-personal content you provide through the Platform by e-mail, including, but not limited to, feedback, data, answers, questions, comments, suggestions, plans, ideas or the like (collectively "Feedback"), shall be deemed to be non-confidential and we assume no obligation to protect such Feedback from disclosure.  You understand, acknowledge, and agree that if you submit any such Feedback to us, it shall in no way prevent Sweet, Brands, the Platform and our Affiliates, from using such Feedback for any purpose whatever, and we shall be free to reproduce, use, disclose and distribute such Feedback without restriction.

CHANGES TO THIS PRIVACY POLICY
Our Service, business and third-party partners are constantly evolving. To that end, we may change, add or delete information on the Platform and/or this Privacy Policy, from time to time without prior notice to you. We will notify you of any material changes by posting the updated Privacy Policy at sweet.io/privacy and in the Platform or by otherwise communicating to you. Any changes will be effective immediately upon the posting of the revised Privacy Policy, and we encourage you to check back regularly for any changes, additions or deletions. Your continued use of the Platform after any modification to this Privacy Policy will constitute your acceptance of such modification.

CONTACT US
Please contact us at privacy@sweet.io if you have any questions or concerns about this Privacy Policy or your experience with the Platform.