NEUTIN REWARDS PRIVACY POLICY

**THE FOLLOWING CONTAINS IMPORTANT LEGAL TERMS.
IT IS YOUR RESPONSIBILITY TO READ THE BELOW AGREEMENT CAREFULLY**

Neutin Rewards Terms of Service

This Neutin Gifted Rewards® (“Rewards Program”) Terms of Service (the “Terms”) sets out Finance Guru LLC’s (“Finance Guru”, “We”, “Us”, “Our”) terms relative to the Rewards Program for the authorized Member (“You”, “Your”, or “Members” generally).  By participating in the Rewards Program, You agree to be bound by these Terms.

BY CLICKING THE “AGREE” BUTTON, YOU (A) ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTAND THESE TERMS AND (B) ACCEPT THESE TERMS. IF YOU DO NOT AGREE TO THESE TERMS, DO NOT USE THE REWARDS PROGRAM.

The Rewards Program

a. Offers Provided through Our Merchant Partners

Our Rewards Program offers You access and use of the Neutin Gifted Rewards® catalogue containing money saving offers or incentives (collectively the “Offers”), which are made available through Our network of Merchant partners (“Merchants”).  These may include savings coupons, vouchers or other cost saving opportunities made available to You.  You will be able to search for Offers based on Merchant, product categories, and other criteria that may be made available.   To facilitate Your access to the Rewards Program, You authorize Us to use various third-party partners (“Third-Party Partners”) for the purpose of delivering services to You, which may include the sharing of Your data and other details relating to Your Membership.  Examples may include partners that are processing payments, call centers to provide Member support or engage in marketing communications, or investigating disputes.

Offers generally will be valid only for those Merchants issuing the Offer and may have terms and conditions that Merchants will specify.  Examples of this may be limitations as to when, how, and who can redeem an Offer.  Terms by Merchants will governing all requirements to redeem the Offer.  Offers also will generally be valid for period and may have additional restrictions that Merchants impose and will be limited to one Offer per Member and may not be combined with another Offer at a single transaction.

b. How to Use the Rewards Program

You may access the Rewards Program through our secure mobile application (the “Application”) or through our website (the “Website”), with log-in credentials provided to You.  You may not share the log in credentials with any other person or entity.  Merchants may allow the Offers or Incentives to be redeemed through printable coupons or through codes that may be displayed on the Application or entered at a Merchant’s point of sale. It is Your responsibility to present the Offer to a Merchant to redeem the savings therewith.

As a Member, You agree to use the Rewards Program only in the United States and for only lawful purposes.  You further agree to not breach the terms of this Agreement or any applicable law, to not allow any other person (other than your immediate nuclear family) or entity to use Your Membership, to not use Your Membership for any commercial or business purpose, and to not use Your Membership in connection with any fraudulent, unethical, negligent or illegal purpose or manner.

c. Membership Eligibility

To be eligible for a Membership, You must be a lawful resident of the United States, be over the age of 18, and have legal capacity to enter into this Agreement.

d. Contacting You

During the course of Your Membership, We may need to contact You through email, SMS or by phone about managing your Membership or other aspects of the Rewards Program.  You understand that message and data rates may apply to these communications.  We require Your valid e-mail and current phone number to contact You.  If We cannot contact You, We reserve the right to terminate your Membership at any time.

e. Linking Your Card(s)

To participate in the Rewards Program, You will be required to maintain at least one payment card registered with Us.  If your linked card expires or otherwise is no longer valid, You are responsible for updating Your account with a valid card to maintain your Membership.

While You are a Member in the Rewards Program, You authorize Us to debit your linked card for your Cost of Membership (Section II below).  You further understand and agree that certain Transactional Data (defined in the Privacy Policy) may be generated and shared with Us as part of your Membership.  Transactional Data shall be owed by Us and may be used for any legal or other business objectives We may have subject to the terms of the Privacy Policy.

II. The Cost of Membership; Your Billing Obligations

a. Membership Fee

Membership in the Rewards Program is made available on Monthly, Quarterly, or Annual Terms (the “Term”).  Memberships will automatically renew for successive Terms of the same length as the Member’s Term (the “Renewal Term(s)”) unless You submit a Request to cancel or modify your Membership Term on the Application or the Website, or by contacting Us through neutininfo@neutin.com or by calling 1 888 995 0263.   Memberships may not automatically renew if You fail to pay the Membership Fee or otherwise breach this Agreement.

Membership Fees are as follows: Monthly: $14.99; Quarterly: $39.99; or Annual: $149.99.  All Membership Fees will be charged to your Linked Card in their entirety when a Membership Term commences.  Thereafter, Membership Fees shall be due and billed on the date upon which your Term expires, with a notice being sent to You fourteen (14) calendar days before your Membership Term is set to renew.  If You do not make your payment of Membership Fees when they it is due, your Membership will continue for ten (10) calendar days while We attempt to secure payment from You.  During the ten (10) days after Your payment is not made, We may attempt to charge Your card again.  If those attempts are not successful, and You do not renew, Your Membership will be terminated at the conclusion of the active Term.

We reserve the right to modify any Membership Fees at any time, with any change being effective, with prior notice to You via email, at Your next Term.  Membership Fees may only be paid through a Member’s linked card, and no payments in cash, personal or cashier’s check or through any other method will be accepted.

Membership Terms will be tracked by the date upon which You become a Member, such that someone who becomes a monthly Member on April 10th, will have their monthly Membership run until May 10th; someone who becomes a quarterly Member on August 15th will have their quarterly Membership continue until November 15th.

b. Billing Process

We will contact You no less than fourteen (14) calendar days before your Membership Term is set to renew.  You understand and authorize Us to automatically debit your linked card your Membership Fee when we provide You notice of your term renewal when it is due, which shall at no time be less than fourteen (14) calendar days before Term renews.  Debits to Your linked card will appear as ‘NEUTIN GIFTED REWARDS’ on your billing statement.

c. Your Right to Cancel or Suspend Your Membership; Refunds

You may cancel Your Membership at any time before the start of Your Renewal Term by submitting a request on the Application or Website, or by contacting Us through neutininfo@neutin.comMembership Terms once initiated shall be non-refundable.  Refunds will not be issued for Membership months during which the Membership was available to You.

III. License

a. Subject to Your compliance with these Terms, the User Agreement and the Privacy Policy, We grant You, during the Term of Your Membership, a limited, non-exclusive, and nontransferable limited license to: participate in the Rewards Program, as well as download, install, and use the Application for your personal, non-commercial use on a single mobile device owned or otherwise controlled by You strictly in accordance with these Terms, the User Agreement and the Privacy Policy.

b. Accessing the Rewards Program and Account Security

We reserve the right to withdraw or amend the Rewards Program, and any service or material we provide on the Application or Website, in our sole discretion without notice. We will not be liable if for any reason all or any part of the Application or Website is unavailable at any time or for any period. From time to time, we may restrict access to some parts of the Website, or the entire Application or Website, to users, including registered users.  You are responsible for both:

• Making all arrangements necessary for you to have access to the Application or Website.

• Ensuring that all persons who access the Website through your internet connection are aware of these Terms of Use and comply with them.

c. Security

i. To access the Application or Website or some of the resources it offers, You may be asked to provide certain registration details or other information. It is a condition of your use of the Website that all the information You provide on the Website is correct, current, and complete. You agree that all information You provide to register with this Website or otherwise, including, but not limited to, through the use of any interactive features on the Website, is governed by Our Privacy Policy, and You consent to all actions we take with respect to Your information consistent with our Privacy Policy.

ii. If You choose, or are provided with, a user name, password, or any other piece of information as part of our security procedures, You must treat such information as confidential, and you must not disclose it to any other person or entity. You also acknowledge that Your account is personal to You and agree not to provide any other person with access to this Application or Website or portions of it using Your user name, password, or other security information. You agree to notify us immediately of any unauthorized access to or use of your user name or password or any other breach of security. You also agree to ensure that you exit from your account at the end of each session. You should use particular caution when accessing Your account from a public or shared computer so that others are not able to view or record Your password or other personal information.

iii. We have the right to disable any user name, password, or other identifier, whether chosen by You or provided by Us, at any time in our sole discretion for any or no reason, including if, in our opinion, you have violated any provision of these Terms of Use.

IV. Changes to these Terms of Service

We may revise and update these Terms from time to time in our sole discretion. All changes are effective immediately when we post them.  Your continued use of the Rewards Program following the posting of revised Terms of Use means that you accept and agree to the changes. You are expected to check this page from time to time so you are aware of any changes, as they are binding on you.

V. Acceptable Use by You

a. You understand that Your activity in using the Rewards Program may be monitored and that You have no expectation of privacy in relation to activities You conduct through Your Membership.

b. You may not use Your Membership to:

i. Participate, facilitate, or otherwise carry out, directly or indirectly, any fraudulent transactions, or otherwise violate the terms of this Agreement or violate any applicable laws;

ii. Re-market, re-distribute or represent the Offers, Rewards Program or any aspect of Your Membership in furtherance of any commercial purpose, including re-marketing the Offers or Rewards Program in any other commercial venture whatsoever;

iii. Distribute information that infringes our or any third party’s copyright, patent, trademark, trade secret or other proprietary rights;

iv. Distribute information that violates any law, statute, ordinance or regulation;

v. Distribute information that is trade libelous, unlawfully threatening, unlawfully harassing, defamatory, obscene, explicit or vulgar, or otherwise injurious to us or third parties or that infringes on our or any third party’s rights of publicity or privacy;

vi. Distribute, through any form of conduct, knowingly or unknowingly, any data, information or other material that contains any viruses, worms, Trojan horses, trap doors, back doors, easter eggs, time bombs, cancelbots or other code or computer programming routines that contain contaminating or destructive properties or that are intended to damage, detrimentally interfere with, surreptitiously intercept or expropriate any system, data or personal information; or

vii. Distribute information containing or constituting chain letters, mass mailings, political campaigning, or any form of “spam.”

VI. Prohibited Uses and Acceptable Use by You:

a. You may use the Rewards Program, Application or Website only for lawful purposes and in accordance with these Terms of Use. You agree not to use the Rewards Program, Application or Website:

i. In any way that violates any applicable federal, state, local, or international law or regulation (including, without limitation, any laws regarding the export of data or software to and from the US or other countries).

ii. For the purpose of exploiting, harming, or attempting to exploit or harm minors in any way by exposing them to inappropriate content, asking for personally identifiable information, or otherwise.

iii. To send, knowingly receive, upload, download, use, or re-use any material that does not comply with the Terms of Use.

iv. To transmit, or procure the sending of, any advertising or promotional material, including any “junk mail,” “chain letter,” “spam,” or any other similar solicitation.

v. To impersonate or attempt to impersonate Us, another user, or any other person or entity associated with any of the foregoing.

vi. To engage in any other conduct that restricts or inhibits anyone’s use or enjoyment of the Rewards Program, Application or Website, or which, as determined by us, may harm Us or users of the Rewards Program, Application or Website, or expose them to liability.

b. Additionally, you agree not to:

i. Use the Rewards Program, Application or Website in any manner that could disable, overburden, damage, or impair the site or interfere with any other party’s use of the Website, including their ability to engage in real time activities through the Rewards Program, Application or Website.

ii. Use any robot, spider, or other automatic device, process, or means to access the Rewards Program, Application or Website for any purpose, including monitoring or copying any of the material on the Website.

iii. Use any manual process to monitor or copy any of the material on the Rewards Program, Application or Website, or for any other purpose not expressly authorized in these Terms of Use, without our prior written consent.

iv. Use any device, software, or routine that interferes with the proper working of the Rewards Program, Application or Website.

v. Introduce any viruses, Trojan horses, worms, logic bombs, or other material that is malicious or technologically harmful.

vi. Attempt to gain unauthorized access to, interfere with, damage, or disrupt any parts of the Rewards Program, Application or Website, the server on which the Rewards Program, Application or Website is stored, or any server, computer, or database connected to the Rewards Program, Application or Website.

vii. Attack the Rewards Program, Application or Website via a denial-of-service attack or a distributed denial-of-service attack.

viii. Otherwise attempt to interfere with the proper working of the Website.

VII. User Agreement and Privacy Policy.

a. These Terms are issued to You pursuant to the User Agreement and Privacy Policy, which are incorporated herein by reference. All capitalized terms herein have the same meaning as set forth in the User Agreement.

VIII. Contacting Us

a. You may contact Us through neutininfo@neutin.com or by calling 1 888 995 0263 or through mailing us at 525 W. Monroe, Suite 900, Chicago, Illinois.

 

Neutin Rewards Privacy Policy

This Neutin Gifted Rewards® (“Rewards Program”) Privacy Policy (the “Policy”) sets out Finance Guru LLC’s (“Finance Guru”, “We”, “Us”, “Our”) Privacy Policy relative to the Rewards Program for the authorized Member (“You”, “Your”, or “Members” generally).  By participating in the Rewards Program, You agree to be bound by this Policy.

BY CLICKING THE “AGREE” BUTTON, YOU (A) ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTAND THIS POLICY AND (B) ACCEPT THIS POLICY. IF YOU DO NOT AGREE TO THIS POLICY, DO NOT USE THE REWARDS PROGRAM.

I. Our Privacy Policy and Your Data Rights

a. Your Data Privacy Rights

We are dedicated to respecting and protecting Your privacy rights.  This portion of the Agreement details what data We collect, how We collect and use it, and what rights You have relative to any data that You are entitled to receive.  While this provision is specific to Your Data Privacy Rights in connection with the Rewards Program, Our general Privacy Policy is also available here.  Data We collect enables us to customize Rewards Programs We offer You, and to generally improve Our services for Our Members.

b. Information We Collect.

i. Personal Information You Provide Us, and about Our Members Generally.

“Personal Information” can encompass information that identifies, relates to, describes is capable of being associated with, or could reasonably linked, directly or indirectly, to a particular individual or household. This may also include login information, such as username and password, for the Application or Website, as well as 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 the Application or Website. Personal Information does not include publicly available information, de-identified information, or aggregated information that does not identify a particular individual or household.   Personal Information may be shared with Us and Our Third-Party Partners or Merchants to provide you services as a Member of the Rewards Program.  We use Personal Information for a variety of purposes, including delivering the Rewards Program to our Members, optimizing the Rewards Program, enhancing security and generally in furtherance of our other business objectives.

ii. Transactional Data generated from Your transactions.

“Transactional Data” is generated by Your purchases or activity through Us, which is delivered to us from your financial institution(s), and is necessary to provide You services under the Rewards Program.  This may include geographical information that details where You search for Offers or where You may redeem Offers from the Merchants.  This data is used to confirm Your purchases, to provide the same to Merchants (for example the date and amount of your purchase and the last four digits of your card so the Merchant can verify your purchase), and to investigate disputes, prevent fraud and otherwise target certain Offers to You.  We also use this data to conduct analysis for the improvement and optimization of the Rewards Program and provide information in order to respond to a request from government authority or a payment organization involved in a transaction with You or a Merchant.

iii. Aggregate Analytical Data

We may also use data that We collect on an aggregate and 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.  This data may be used by Us to (i) provide, support, improve, enhance and operate the Rewards Program and its availability; (ii) develop new features, products and services; (iii) compile statistical reports and record insights into usage patterns; and (iv) perform Our obligations under this Agreement.

iv. Other Data

We, our Third Party Partners, 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.   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.

v. Your Authorization to Us to Use Your Data

As a Member, You authorize Us to use, share, exchange, and generally analyze the Personal Information, Transactional Data, Aggregate Analytical Data, and Other Data described above for Our internal business purposes, or to share the same with any of our or Merchants and Third-Party Partners.

vi. How We Collect Data

1. Through any information You provide to Us, for instance in the creation of Your Membership, in the submission of an inquiry or through redeeming Offers, or otherwise in Your communicating with us for any purpose.

2. Through transaction information, such as Transactional Data or Aggregate Analytical Data, when you purchase products or services: For example, if You make purchases with Your linked credit card, We may use Your credit card information for shipping, billing, and credit card validation purposes.

3. Information We may receive from Your financial institution, such as payment card data and other transactional information.

4. Information about Your activity through our Application or Website, including Your device information, such as your IP address, the type of device or browser You use, and Your actions on Our Application or Website, or Your geographic location when You use the Rewards Program.

vii. Data Residency and Retention

Because We are based in the United States and our Rewards Program is only intended for residents of the United States, any data We collect and maintain will reside within the United States.  However we may have a Third Party Partner that resides overseas and You authorize us to share said data with any overseas Third Party Partner.  We will retain any data during the Term of Your Membership and for five (5) years thereafter, unless we receive a request from You to return the data that You are entitled to receive, or unless otherwise required to remove the data by law.

c. Your Data Rights

i. Data Privacy laws, such as the California Consumer Privacy Act, may provide You with rights regarding Your Personal Information. When a verified request is submitted through our designated Request Form (see below), You have the right to know the categories and specific pieces of Personal Information that We possess pertaining to You.

ii. You have the right to request that we disclose certain information to You about our collection and use of Your Personal Information over the 12 months preceding the date of Your verified request. We will make all reasonable efforts to retain Personal Information no longer than necessary, which typically will be less than 12 months.

iii. You have the right to request that we delete any of your Personal Information that we collected from You and retained, subject to certain exceptions. An exception would apply if any of the following occur: (i) the request would violate evidentiary privilege; (ii) Your information is necessary to comply with any court order, law, or legal process, including responding to any government or regulatory request; (iii) Your information is necessary to complete the transaction for which the Personal Information was collected; (iv) You previously made two (2) requests within a twelve (12) month window.  Once we receive and confirm your verifiable Consumer request and an exception does not apply, we will delete (and direct our service providers to delete) Your Personal Information from our records.

d. Submitting A Data Request to Us

i. You may submit a data request to access, correct, or delete any personal information that you have provided to Us by Contacting Our Data Manager through any one of the following methods:

1. Emailing: privacy@financeguru.com;

2. Calling 1 888 995 0263; or

3. Submitting the request through the use of Our Online Form.

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.

ii. To protect Your privacy and security, We may take reasonable steps to verify Your identity before granting access to, correcting, or deleting data. To be actionable and verified, a request must:  Provide sufficient information that allows Us to reasonably verify you are the person who is the subject of the data request, or an authorized representative, and describe your request with sufficient detail that allows Us to properly understand and respond to it.  We cannot respond to Your request if We cannot verify Your identity or authority to make the request and confirm the Personal Information relates to You.  You are not required to create an account to submit a request.

iii. We will generally respond to your request for information within forty-five (45) days, unless a longer response time is necessary, in which case, You will be advised accordingly. Once we receive Your request and verify Your identity, and confirm that no legal exception applies to Your request, our Data Manager, within the timelines required under the data privacy laws, will disclose to You:

1. The categories of Personal Information we received about You;

2. The categories of sources from which we received the Personal Information;

3. Our business purpose for receiving the Personal Information;

4. The categories of third parties (if any) with whom We share the Personal Information;

5. The specific pieces of Personal Information We received.

e. Data Security

The security of Your information is our highest priority. We use physical, electronic, and procedural safeguards that comply with federal and international standards to protect and limit access to Your personal information. We also actively monitor Our systems and your account for suspicious or fraudulent activity. The use of, and access to, your Personal Information by us is restricted to employees and subcontractors who need to know that information to provide services to our business partners.

f. Your Opt Out Rights and Rights to Not Sell Your Personal Information

Although it is Our policy and business practice to never sell your Personal Information, You are given the right to opt-out of allowing Us to sell your Personal Information in the future.  In order to send a request preventing the selling of Your Personal Information, please click below and submit our Online Form.  Alternatively, you may also contact Our Data Manager by calling 1 888 995 0263 or emailing privacy@financeguru.com.

g. Children Under the Age of 18

Our Rewards Program is not intended for children under 18 years of age, and we do not knowingly collect personal information from children under 18. If we learn we have collected or received personal information from a child under 16 without parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy@financeguru.com.

h .Changes to Our Privacy Policy

We reserve the right to amend this privacy policy at Our discretion and at any time, without any prior notice. When We make changes to this notice, we will post the updated notice and email You with the updated policy. Your use of Our Rewards Program following the posting of changes constitutes your acceptance of such changes.

II. Our Contacting You about the Rewards Program or Other Marketing Offers

a. Your Authorization for Us to Contact You

You understand and agree that We have the right to contact You about Your Membership and any other marketing Offers that We may offer.  By entering this Agreement, and by initialing below, You consent to being called, emailed, or receiving SMS texts from Us about any marketing offers We may offer You during the Term of your Membership and for thirty (30) days thereafter.   This may include automated dialers, prerecorded messages, artificial voice or automatic texting systems.  This consent is not required to complete any purchase.  Message and data rates may apply to any communication.  This authorization will apply notwithstanding any prior placement on a do-no-call registry.

b. Your Preferences As to How and When We Contact You; Right to Opt Out of Marketing Communications

i. You may opt out of receiving any marketing communications from Us. This will not include opting out of non-marketing communications related to Your Membership so long as Your Membership is in its Term or Renewal Term.

ii. To Submit a request to Opt Out of Marketing Communications, please use our Online Form, or You may contact our Data Manager by calling 1 888 995 0263 or emailing privacy@financeguru.com.

III. User Agreement and Terms of Service.

This Policy is issued to You pursuant to the User Agreement and Terms of Service, which are incorporated herein by reference.  All capitalized terms herein have the same meaning as set forth in the User Agreement.

IV. Contacting Us

You may contact Us through neutininfo@neutin.com or by calling 1 888 995 0263 or through mailing us at 525 W. Monroe, Suite 900, Chicago, Illinois.