This policy explains how the GoLocal Inc., the creators of Treat, ("Treat," "we," or "us") collects, uses, shares, and keeps secure your information, including your nonpublic personal information. This policy applies to all the information we collect from you and about you, including the information we collect when you sign up for Treat, when you use Treat, and any information we collect from sources other than you.

You should review this Privacy Policy each time you use our website. From time to time we may update our Privacy Policy. For details on when and how we will inform you about any updates, as well as information on your choices when we make updates, please carefully review the section below called Changes To Our Privacy Policy.

By using our website, and any related products and services (the "Treat Services"), you are agreeing to this Privacy Policy. If you do not agree to these terms, you may not enroll in or use the Treat Services.

Pursuant to this Privacy Policy, you direct the Issuing Bank of your Treat MasterCard Prepaid Gift Card and Treat Cardholder Account, to share your transactional data with Treat, and you direct Treat to share your data with its users, vendors, partners, and affiliates at its discretion.

Personal Information You Provide To Us Directly

1.1 When you sign up for the Treat Services, we may be required by federal law to collect "nonpublic personal information" to verify your identity. We also collect various types of information to establish and maintain your account. As a result, we may collect your name, email address, phone number, permanent address and/or mailing address, date of birth, credit card number, debit card number, and your social security number.

As a result of completing a transaction using the Treat Services, we also independently collect information such as the time, dollar amount, location, and other details about the parties involved in the transaction. We also collect audio, photos, text, videos, or any other information you upload and/or send through the Treat Services.

Information We Collect Through The Treat Services

1.2 When you use the Treat Services we collect information from your computer or mobile device, such as the unique identification number, the model, operating system and version, your browser type and version, the presence of any device, operating system, or browser add-ons, the times you access the Treat Services, the portions of the Treat Services you use, the locations from where you access the Treat Services (attributed based on your IP address, the page you visited before navigating to the Treat Services, and your mobile device's location services), and your stored contacts.

Use Of Cookies and Other Technologies

1.3 We also use various technologies to collect and store information related to your use of the Treat Services. We may collect and store information locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches. We also may use cookies and other device identifiers like web beacons. A cookie is a text file that our website transfers to your device's hard drive for record-keeping purposes and to enhance the quality of your visit to our website. We use both "session" cookies, which last only until you close your browser, and "persistent" cookies, which last until you or your browser delete them. The cookie assigns a random, unique number to your device. Cookies, among other things, record your login information and "clickstream" information (data reporting the URLs or names of the pages on our site that you have visited). We use cookies and other technologies to personalize the Treat Services for you and to collect information about usage of the Treat Services. Under the section below entitled "Your Choices," you can learn about how you may disable or alter our usage cookies.

Treat supports Do Not Track. Although you may have Do Not Track enabled in your browser, Treat may still set cookies to reduce fraud and help you use the Treat Services.

Information From Third Parties

1.4 As a result of your accessing your Treat Cardholder Account through the Treat Services, the Issuer collects information such as the time, dollar amount, location, and the identity of the other party involved in the transaction. By using the Treat Services, you direct the Issuer to share all such information with us.

When using the Treat Services, you may have the option to provide us with information from third parties, such as Facebook, Twitter, and Google. We may also acquire information about you from third parties in order to verify your identity, process your transactions, detect and prevent fraud, or other similar purposes.

Information From Children

1.5 We do not knowingly solicit or collect information from any individuals under the age of 13, or about individuals under the age of

2.1 Treat uses your information to provide and improve the Treat Services, including for the purposes of:

1. Providing you with customer support when things go wrong
2. Helping to provide you the services you want, including processing and tracking your transactions for you
3. Answering the questions you may have for us
4. Monitoring and analyzing how you and other users use the Treat Services
5. Improving and building features and services you or other users may want
6. Minimizing fraud and abuse of the Treat Services
7. Communicating with you about changes in the Treat Services, the status and security of your account and data, and administrative information
8. Other reasonable uses related to providing, maintaining, and improving the Treat Services.
9. Directly marketing to you products and features from Treat
10. Providing you with offers and deals from third parties
11. Performing internal marketing analytics
12. Providing you with gifts as part of your using the Treat Services
13. Connecting you with other users, including those you have stored as contacts in your mobile device, those we reasonably believe you may know, and those you are connected to in other networks
14. Connecting you with commercial users whom we believe you may be interested in
15. Providing you with the opportunity and means to enter into contests such as sweepstakes and raffles
16. Discovering your tastes so that our promotions and marketing are more tailored to you

2.3 Treat is an American company based in California, incorporated in Delaware. By accessing or using the Treat Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S.

3.1 When you sign up for the Treat Services, you are directing Treat to share information with third parties as outlined below. The information that Treat shares includes both the information that Treat collects from you directly and the information that Treat collects from third parties.

3.2 We may provide your information to Third Parties for business and legal purposes, including for the purposes of:

1. Providing and improving the Treat Services as described above
2. Meeting the requirements of any applicable law, regulation or legal process, including complying with orders from courts of law, regulatory agencies, and law enforcement
3. Investigating fraud inside and outside the Treat Services
4. Broader business dealings such as mergers, asset sales, financings, and acquisitions
5. Reporting to credit bureaus

3.3 We may also provide your information to third parties for promotional and marketing purposes, including for the purposes of:

1. Helping you find people you may know, even if you are not yet connected through the Treat Services, and helping those people find you
2. Helping you find merchants you may be interested in, and helping Treat Merchants find you

3.4 For the third-party promotional and marketing purposes outlined directly above, Treat will never share your last name, phone number, email address, street address, credit card information, debit card information, or your social security number for the promotional and marketing uses as outlined above, unless you direct us to do so. For those same purposes, we may share your first name, any content you upload, such as profile pictures, text, and picture messages, birth date, and details on where you have shopped, including the amount, location, time, and other party involved in your transactions, but not the actual goods or services you purchased, with other Treat users, including merchants. If we do share such information with a merchant, the merchant will be a Treat Merchant, meaning it will be registered with Treat in a process similar to a user. We may also share your last name with users who are already in your phone book, already friends with you on Facebook, or reasonably likely to be connected to you. We may share aggregated or de-identified information, which cannot reasonably be used to identify you.

4.1 We have designed policies and procedures to protect both your confidentiality and the security of your information, including your nonpublic personal information. We store and process your personal information using third party servers located in secure data centers in the United States. These centers are protected by physical, electronic, and procedural safeguards in compliance with applicable federal and state regulations. Additionally, Treat uses firewalls and data encryption. We also enforce tight restrictions on physical access to our office and files and limit digital access to sensitive data in order to ensure that only those employees who require the access to fulfill their job responsibilities actually have it.

4.2 Despite Treat's efforts to keep your information secure, we cannot guarantee the security of your information. As a result, we strongly encourage you to take action to protect your personal data and any device you use to access the Treat Services. In the unlikely event that we come to learn that either our system or your account specifically has suffered a security breach, we may attempt to notify you electronically so that you can take appropriate protective steps, by email, text message, phone call, a notice on the Treat website, or any other way, depending on the requirements of applicable law. Links To Other Sites

4.3 We are not responsible for the privacy practices of any third parties or the content of sites that are linked from the Treat Services and we strongly encourage you to read the applicable privacy policies and terms and conditions of such parties or websites.

5.1 Treat may collect information regarding your location. You may be able to control how your browser interacts with cookies and the location information that is shared with us. However, if you remove stored cookies or block them from being set, you may affect the availability and functionality of the Treat Services.

Opting Out Of This Policy

5.3 If you no longer wish to use the Treat Services and would like to delete or deactivate your Treat account, please contact us. We are required by law to retain your information, and may also do so for legitimate business purposes, but we will not share or use your information for promotional and marketing purposes after you have deleted or deactivated your account.

As stated above, your usage of the Treat Services is contingent on your expressly opting in to this Privacy Policy. If you change your mind after agreeing and wish to opt out at a later date, you must contact us to cancel your Treat Account. You can do so by sending an email to [email protected]. If you cancel your Treat Account, we will not use or share your information for marketing or promotional purposes, except in an anonymized or de-identified form. However, please be aware that even if you do cancel your Treat Account we must still retain your information as required by law and we may retain it for legitimate business purposes, including internal analytics.

Changes To Our Privacy Policy

5.4 As we continue to improve our products and services, we may update our Privacy Policy. If we make changes to this policy, we will update the effective date at the top of this document. A change in the effective date will serve as your notice that the policy has changed. If we make a substantial change to the policy, we will send you an email notification, provide you an alert to your mobile device or computer, or both. If you choose to continue using Treat's products and services after receiving such notification, you agree to the revised privacy policy. You should review this Privacy Policy each time you use our mobile or website, as you will be bound by any changes once they are. Finally, we will provide previous Privacy Policies on our website, so you can see the changes we made.

FREQUENTLY ASKED QUESTIONS

Who Can See My Personal Information?

6.1 Treat keeps secure and private all of your personal information except your first name, any content you upload, such as profile pictures, text, and picture messages, birthdate, and details on gift cards you've purchased and received and where you have shopped, including the amount, location, time, and other party involved in your transactions, but not the actual goods or services you purchased. By default, we only share your last name with your friends and friends of your friends.

Why Does Treat Share My Information?

6.2 We primarily share your information so that you can find your friends, and they can find you. As our products and services change over time, sharing data between users will lead to an increase in value on the platform. As an example, we will help connect you with trusted Treat Merchants if they are making an offer or providing a deal that we think will appeal to you based on your preferences and previous transactions.

What Can I Do To Protect My Information?

6.3 Although Treat works very hard to keep all of its users' information secure, a chain is only as strong as its weakest link. By changing your passcode, PIN, and/or pattern frequently, you can reduce the risk of someone gaining access to your information. Similarly, keeping a strong email password and updating it from time to time will help prevent someone from gaining access to your account. Finally, we may, from time to time, provide links or portals to other websites or applications. Always be aware when you are leaving the Treat Services and entering another website or application, and be sure to review the relevant privacy policies of the other websites or applications.

Contact Treat

7.1 To reach Treat by phone or e-mail, please use the following phone number and e-mail address:

Phone: 855-636-7959
E-mail: [email protected]