Privacy Policy

Last Updated 06/11/2025

We at Virtual Incentives (“Virtual Incentives,” “we,” “us,” or “our”) respect your concerns about privacy and value the
relationship we have with our website visitors and ViNOW users (“you”). This privacy policy (“Privacy Policy”) describes
the types of personal information we may collect through our website available at <https://www.virtualincentives.com/>,
our ViNOW portal available at <now.virtualincentives.com>, and your communications with us via email, telephone,
social media, or any other means; how we may use that information; and with whom we may share it. Our Privacy Policy
also describes the measures we take to protect the security of personal information. In addition, we describe the
choices you have about how we collect and use the information you provide to us. We also tell you how you can reach
us to update certain information you’ve given us, ask us not to send you future marketing communications, or answer
any questions you may have about our privacy practices. Please note this Privacy Policy does not apply to the
collection, use, storage and disclosure of personal information obtained in connection with the provision of our
cardholder services to our customers, which is subject to agreements between us and our customers.

Updates to This Privacy Policy

We may update or change this Privacy Policy from time to time. We will notify you of any material changes by posting a
prominent notice on our website or indicating at the top of this Privacy Policy when it was most recently updated. Any
changes will be effective on the effective date specified on the revised Privacy Policy.

Information We Collect and How We Use It

You may choose to provide personal information (such as your name, address, telephone number and email address)
on our website or our ViNOW Portal, or when you communicate with us via email, telephone, or social media. Here are
the ways you may provide information, the types of information you may submit, and how we may use, disclose or
otherwise process such information:

Creating An Account

● To take full advantage of all our website offerings, you may choose to create an account on our ViNOW
Portal. To create an account, we ask you to submit certain information (such as your contact information and
credit card number) so we can communicate with you and provide you with the products you order. When you
create an account on our ViNOW Portal, we request your email address so we can communicate with you by
email. For example, we will use your email address to send you your login, which will allow you to access your
account online.

Purchases

● If you’ve created an account on our ViNOW Portal, you may buy our products or services online. We use the
contact and payment information you provide when you set up an online account so we can send you the
items you ordered or provide the services you’ve requested. We may use service providers to help us fulfill
your order. We share information about you with these service providers only for this purpose.

Contact Us

● You may choose to contact us through our website, email, telephone number, or any other way provided. If
you email us through the “Contact Us” link on this site, we may ask you for information such as your name and
email address so we can respond to your questions and comments. We may also collect the following
information: your other contact information, such as your phone number and postal address; the content of
your communication and the technical details of the communication itself, such as with whom you correspond
at our end and the date and time; and publicly available information about you. You may choose to provide
additional information as well. We use the information you provide to respond to your inquiries.

Visiting Our Website

● Whenever you use our website, we collect the following information: technical information associated with the
device you use, such as the device type and model, system language, browser type, geographical location,
and operating system; and technical identifiers that identify the device you use, such as IP address, IDFA
(identifier for advertisers) and other unique identifiers.

Cookies

● When you visit our website or our ViNOW Portal, either may store or retrieve information on your device,
mostly in the form of cookies. A cookie is a small file of letters and numbers that is stored on your browser or
the hard drive of your computer. These cookies are necessary for our website or ViNOW portal to function
and cannot be switched off. They are usually only set in response to actions made by you that amount to a
request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your
browser to block or alert you about these cookies, but if certain cookies are disabled, some parts of the
website or the ViNOW portal may not function properly. These cookies do not store or involve the processing
of your personal information.
● Our website includes social media features such as the Meta “Like” button. These features may collect your IP
address and which page you are visiting on our site and may also set a cookie to enable the features to
function properly. Social media features are either hosted by a third party or hosted directly on our website.
Your interactions with these features are governed by the privacy policy of the company providing them, and
we recommend that you carefully read any third-party company’s privacy policy.
● We use cookies in the manner and for the purposes described in our cookie banner. To view or change your
settings, click here.

If you provide personal information about another individual to us, it is your responsibility to obtain the consent of that
individual to enable us to collect, use and disclose his or her information as described in this Privacy Policy.

Information We Share

We do not sell, rent, trade or otherwise disclose personal information about you, except as described within this
Privacy Policy. We share information provided by you with service providers we have retained to perform services on
our behalf. These service providers are not authorized by us to use or disclose your information except as necessary to
perform services on our behalf such as payment processing, biometric authentication provider, data storage, website
analytics, shipping services, and email services, or for compliance with legal requirements. Please note we rely on third
parties to follow certain of your actions on our website or our ViNOW Portal in order to better understand how Virtual
Incentives is used. We also may share information about you with other members of our corporate family. In addition,
we may disclose information about you (i) if we are required to do so by law or legal process, (ii) in response to a
request from law enforcement authorities or other government officials, (iii) when we believe disclosure is necessary or
appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual
illegal activity, or (iv) to exercise our legal rights or defend against legal claims.

We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of
our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to try to direct the
transferee to use personal information you have provided through this website in a manner that is consistent with this
Privacy Policy.

Location and transfers

Your personal information may be stored in and processed outside your country of residence, in any country where we
have facilities or in which we engage third party service providers, notably in the United States.

As a result, your personal information may be transferred to jurisdictions outside your country, state or province of
residence, which may have different privacy laws than in your country, state or province of residence. While suchinformation is outside the jurisdiction where you reside, it is subject to the laws of the jurisdiction in which it is located,
and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other
jurisdiction, pursuant to the laws of such jurisdiction.

However, our practices regarding your personal information will at all times continue to be governed by this Privacy
Policy and, if applicable, we will comply with the applicable privacy laws requirements providing adequate protection
for the transfer of personal information outside of your jurisdiction of residence, such as entering into contractual
agreements.

Testimonials

With your consent, we may post your testimonial, along with your name. If you want your testimonial removed, please
contact us using the contact information below.

Children’s Information

Our website is not directed to or intended to be used by anyone that has not reach the age of consent, as applicable in
the jurisdiction in which you reside. We do not knowingly collect personal information from anyone that does not have
the required age to consent pursuant to applicable laws. If you do not have the age to consent, please do not use our
website or send any personal information about yourself to us. If we learn that we have collected personal information
from a child that did not have the required age to consent, we will delete that information promptly. If you are a parent
or guardian and you know that your child has provided us with personal information without your permission, please
contact us using the contact information in the “Contact information” section.

Links to Other Sites

We may provide links to other websites for your convenience and information. These sites operate independently from
our site and are not under our control. These sites may have their own privacy policies in place, which we strongly
suggest you review if you visit any linked websites. We are not responsible for the content of these sites, any products
or services that may be offered through these sites, or any other use of these sites.

Information Security

We maintain administrative, technical and physical safeguards designed to protect against unauthorized disclosure,
use, alteration or destruction of the personal information we have about you. When you provide sensitive information
such as credit card information to make a purchase, we use the industry standard for Internet security to help protect
the information you provide. Please see our Security Statement for more about our commitment to security. However,
you should note that perfect security does not exist on the Internet. As such, please ensure you keep your account
credentials like your username and password secure, and do not share them with anyone.

If you have reasons to believe that your interaction with us is no longer secure (for example, if you feel that the security
of any information that you provided to us has been compromised), please contact us immediately using the contact
information in the “Contact information” section below.

Retention

We will retain your information, as needed for the purposes for which we have collected it in accordance with this
Privacy Policy (including but not limited to as long as your account is active, to provide you with services and operate
our business) …, or as otherwise required or permitted by law. Please contact us by using the contact information
below if you wish to cancel your account or request that we no longer use your information to provide you with
services. To be clear, we will retain and use your information as necessary to comply with our legal obligations, resolve
disputes, exercise our rights and enforce our agreements.

Your Choices
Marketing Emails

● You may unsubscribe from our marketing or promotional emails. To do so, please use the unsubscribe
mechanism offered in our marketing emails or other communications as applicable, or contact us using the
contact information below. Please note you may continue to receive transactional or account-related emails.

Your Rights regarding your Information

● If you would like to update your contact information or limit use or disclosure of your personal information,
please contact us using the contact information below. We expect you, from time to time, to provide us with
updates to your personal information, as required.
● You may have the right to access, correct, update, or delete your personal information if your personal
information changes, or if you no longer desire our services. You may do so by making any changes on our
member information page or by contacting us using the contact information below.
● Your request should clearly state which right you wish to exercise and, if required, the reasons or proof for it.
It should also be dated and signed and accompanied by a digitally scanned copy of your valid identity card
proving your identity.

Cardholder Services

● If you are a user of the cardholder services we provide to you on behalf of our customers, we refer you to the
privacy policies of our customers for more information about your rights and how to exercise them.
Your California Privacy Rights
● California Civil Code Section §1798.83 permits California residents to request certain information regarding
our disclosure of personal information to third parties for their direct marketing purposes. Please note we do
not sell or share personal information to third parties for their direct marketing purposes.

Do Not Track Signals

● We do not currently respond to web browser “do not track” signals or other mechanisms that provide a
method to opt out of the collection of information across websites or other online services.

Your European Union Data Protection Rights

● If you are a resident of one of the member states of the European Economic Area, European Union (“EU”) law
provides you with additional rights regarding our use of your personal data. To learn more about your EU data
protection rights, visit our Data Protection Notice (EU Relevance) attached here.

Your Canadian Data Privacy Rights

● If you are a resident of a Canadian province, depending of the province in which you reside, you may have
additional rights regarding our use of your personal data, including:

o the right to be informed about what personal information we have about you and how we process
your personal information;
o the right to access your personal information as processed by us and, if you believe that any
information relating to you is incorrect, obsolete or incomplete, to request its correction or updating;
o Depending on your location, you may have the right to withdraw your consent to our use and
communication of your personal information;
o the right to request to cease the dissemination or to request the de-indexation of, your personal
information;
o the right to request its portability, i.e. that the personal information you have provided to us be
returned to you or transferred to the person of your choice, in a structured, commonly used and
machine-readable format; and where applicable, the right to submit observation in case of a decision based exclusively on an
automated processing.

If you have a question or want to exercise the above rights, please contact our Privacy Officer at the contact
information in the “Contact Us” section. We may ask you for identification to verify your identity.

Contact Information

● If you have any questions, complaints or comments about this Privacy Policy, or if you would like us to update
certain information you have provided to us, exercise your rights, or update your communication preferences,
contact our Privacy Officer at:

Privacy Officer
Virtual Incentives
PO Box 35, Cold Spring, NY 10516-0035
+1-646-736-1910
Privacy@VirtualIncentives.com