Last Revised July 26, 2021

Introduction:

This Privacy Policy (the “Policy”) applies to the Pintuna Platform (comprised of software applications, mobile applications and the website located at https://www.pintuna.com (the “Site”)) developed, owned and operated by Pintuna Inc. (“Pintuna,” “we,” “us,” or “our”). The Policy applies any time you deal with us, whether in person, by phone, by mail or email, or through the Pintuna Platform. The only exception to this is if different practices are provided by us and state that they apply instead of this Policy.

This Policy explains:

• how we collect, use, and share information from or about you;

• your choices about our use of your personal information; and

• how you can access and update your information on the Pintuna Platform.

The services (“Services”) we may provide to you as a user of the Pintuna Platform once you establish an account with us on the Site (“Pintuna Account”) and as a holder of prepaid gift cards issued by our merchant customers and associated gift card accounts are designed to provide you with certain online features and functionality with respect to the accounts you have opened with the merchants who have issued you one or more prepaid gift cards, including access to your prepaid gift card account information, certain account management functions and other services offered by Pintuna through the Pintuna Platform. Sometimes, we may appear on a site owned by a third party or a co-branded site (like a Pintuna web page or handle on a social media site) or link to a third party site. When we do, that third party’s privacy policies and terms of use, not ours, will apply unless we advise you otherwise. Also, some of Pintuna’s technology services for merchants issuing prepaid gift cards (“Merchant Services”) are offered through such merchants’ own websites, social media sites and blogs. In those cases, the privacy policies of such third parties (including prepaid gift card issuing merchants) will govern their use of your data.

Types of Information We Collect

Personally Identifiable Information (“PII”). PII means information or a combination of information that can be used to identify, contact, or locate a specific person. We may collect the following types of PII from you:

• Contact information, such as name, email address, mailing address, phone number;

• Payment and account information, such as prepaid gift card information, account number, or billing address;

• Device geolocation (geographical location);

• Unique identifiers such as user name, account number, or password; and,

• Preference information such as product wish lists, order history, or marketing preferences.

Sometimes, we may combine PII you provide with information about you from third-party sources. For example, we may confirm your address with the postal service. We will treat the combined information in accordance with the terms of this Policy.

Other Information (“OI”). OI is any information other than PII that does not reveal your identity or directly relate to a person. We may collect the following OI from you:

• Information about you or your business such as company name, company size, or business type;

• Demographic information, such as age, gender, interests and ZIP code;

• Device and other tracking information, such as browser information, device identifiers, operating system, or information gained from cookies, pixels or other tracking technologies.

OI may also include PII we have de-identified or aggregated to the point where it no longer identifies a particular individual. If we ever combine OI with any PII, we treat it as PII is treated under this Policy. In some jurisdictions, some OI may be considered PII by law. In those cases, we will treat the information as PII is treated under this Policy.

How We Collect Personally Identifiable Information

We collect PII when you provide it to us. This can occur when you fill out applications, create accounts on the Pintuna Platform, perform transactions with your merchant-issued prepaid gift card account, complete purchases, take surveys, or fill in various online fields on the Site. We also collect PII when you contact us with inquiries, customer support requests, or other applications.

We may also collect the PII of third parties when you provide it to us. We store this information for the sole purpose of completing the transaction you authorized and to provide the Services. If you provide PII of a friend or family member and they want us to delete this information, they should contact us at support@pintuna.com. We may not always be able to remove their PII. We will let them know if we cannot do so and why.

We do not allow other parties to collect PII about your online activities over time and across different websites when you use our website or services.

How We Use Personally Identifiable Information We Collect

We may use PII we collect for the following purposes:

• to provide you with the Services, including without limitation, in connection with the management of your prepaid gift card accounts; • to verify your identity and/or location in order to allow access to your accounts, conduct online transactions, and secure your PII; • to send you important information, such as changes to terms, conditions, and policies and/or other administrative information; • to respond to your inquiries and fulfill your requests; • to track referrals from partner and affiliate websites; • to personalize your experience on a Site by presenting content or offers tailored to you; • to send you marketing communications you have signed up for or that we believe may be of interest to you; • to allow you to use various Site features; • to assist in verifying your identity and account status when we deal with you through our social media pages; we may combine this information with information we already have; • for business purposes related to the Merchant Services we provide, including data analysis, audits, developing and improving products and services, enhancing the Site, identifying usage trends and determining the effectiveness of promotional campaigns; and • for risk control, fraud detection and prevention, and compliance with laws and regulations.

Please note that some features or tools of the Pintuna require that you provide PII in order to use them whereas other features or tools do not. You may request that certain information that you enter into the Site or on mobile applications, if any, be stored for future access and use. You have the option not to save the information.

Blogs: The Site may offer publicly accessible blogs. Any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at support@pintuna.com. We may not always be able to remove your personal information. We will let you know if we cannot do so and why.

Newsletters: If you subscribe to our newsletters, we will use your name and email address to send them to you. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or accessing the email preferences in your account.

Testimonials: We display personal testimonials of satisfied customers on some of the Site. With your consent, we may use your testimonial and your name. If you wish to update or delete your testimonial, you can contact us at support@pintuna.com.

Geolocation: We may collect your location-based information to help you locate a store offering our products and services in your area. We will only share this information with our mapping provider for the sole purpose of providing you this service.

We may collect location-based information for fraud prevention purposes.

You may opt out of location-based services at any time by changing the settings on your device. If you do, you might not be able to use certain features, especially when we use location-based information to prevent fraud.

How We Share Personally Identifiable Information We Collect

We will share your PII with third parties only in the ways that are described in this Policy. We do not sell PII to third parties.

Affiliates: To the extent permitted by law, we may provide information about your transactions and experiences with other affiliated Pintuna entities.

Merchants: We provide your PII to the merchants who have issued your prepaid gift cards and with whom you maintain gift card accounts.

Service providers: We may provide your PII to companies that provide services to help us with our business activities, such as maintaining the Pintuna Platform or offering customer service. These companies are authorized to use your PII only as necessary to provide these services.

Referral partners: We may offer referral-based commission systems through third party partners through which publisher websites may refer users to the Site. The third party partner will be identified when you sign up for such partners’ services or products. Data generated from the commission system, which may include PII and OI, will be owned and controlled by both Pintuna and the third party partner. This Policy will govern Pintuna’s use of the data. The third party’s privacy policy will govern its use of the data. When you sign up as a publisher, we will link to the third party’s privacy policy and ask you to agree to it.

Additional Disclosure: We may also disclose your PII:

• As permitted or required by law, such as to comply with a subpoena, or similar legal process;

• When we believe in good faith that disclosure is necessary to protect our rights and the rights of our customer merchants which have issued prepaid gift cards, protect your safety or the safety of others, investigate fraud, or respond to a government request;

• If Pintuna is involved in a merger, acquisition, or sale of all or a portion of its assets. You will be notified by email and/or by a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your PII;

• to any other third party with your prior consent.

How We Collect And Use Other Information

We and certain third-party service providers with whom we have agreements may collect OI in a variety of ways, including:

Log files: Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version, and internet browser type and version. This information is gathered automatically and stored in log files. We may link this data to PII we have collected about you.

Tracking technologies: We and our service providers use cookies, beacons, tags, scripts, and HTML5 local storage. These technologies allow us to collect information such as browser type, time spent on the Site, pages visited, language preferences, and your relationship with us. We can use this information to analyze trends, administer the website, track users’ movements around the website, measure the effectiveness of our communications, tailor our advertising to you, and gather demographic information about our user base as a whole.

You can refuse to accept cookies. Most devices and browsers offer their own privacy settings for cookies and HTML5 local storage. You will need to manage your cookie settings for each device and browser you use. However, if you elect not to accept cookies, your use of the features on the Site may be limited or impaired, and you may not be able to access certain features of the Site at all.

Our third party partners use Local Shared Objects, such as Flash cookies, to embed features on our sites. To manage Flash cookies, please click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html

Security and Retention

The security of your personal information is important to us. We follow generally accepted standards to protect your PII submitted to us, both during transmission and once it is received. If you have any questions about the security of your PII, you can contact us at support@pintuna.com.

In particular, the Site is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to the Site as safe as possible. We use regular malware scanning. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/financial information you supply is encrypted via Secure Socket Layer (SSL) technology.

We will retain your information for as long as your account is active or as needed to provide you Services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, terms of service, terms of use and other policies.

User Access and Choice

Upon request we will provide you with information about whether we hold any of your personal information. You may access, correct, update, amend, remove, ask to have it removed from a public forum, directory or testimonial on the Site or deactivate it by making the change on your account page, emailing us at support@pintuna.com or by contacting us by postal mail at the contact information listed below. We will respond to your request within a reasonable time.

We acknowledge that you have the right to access your personal information. Pintuna may have no direct relationship with some individuals whose personal data it processes. In those situations, an individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct their query to Pintuna’s partner who has the direct relationship (the data controller), such as the merchant who has issued such person’s prepaid gift card. If requested to remove data we will respond within a reasonable timeframe.

“Do Not Track” Preferences

Many browsers provide you an option to request that a web application disable either its tracking and/or cross-site user tracking of an individual user. We do not track your online activities across different Sites, and we only track your activity within a Site to the extent you log into your account. Therefore, our practices remain the same whether or not you enable the “Do Not Track” feature.

Protecting Children’s Privacy Online

Our Sites are not directed to individuals under the age of thirteen (13), and we request that such individuals do not provide PII through the Site. We do not knowingly collect information from children under 13.

Changes to This Policy This Policy is subject to change. Please review it from time to time. If we make changes, we will revise the “Last Revised” date at the top. Any changes will become effective when we post the revised Policy. If we make any material changes we will notify you by email or by means of a notice on the Site prior to the change becoming effective.

Contact Information

Pintuna Inc

1560 Grackle Way,

Sunnyvale, CA 94087

support@pintuna.com

For California Users

Under the California Consumer Privacy Act (CCPA), California residents have certain rights with respect to their Personal Information. Please review this Privacy Policy to understand what information we collect and how we use it. Please note that Pintuna does not sell customer Personal Information to third-parties for money or valuable consideration.

In addition to the rights set forth in this Privacy Policy, residents of the State of California (“California Users”), may request information regarding the types of personal information we share with third parties for direct marketing purposes, and the identities of the third parties with whom we have shared such information during the immediately preceding calendar year. California Users may request further information about our compliance with this law by sending us a message to support@pintuna.com. Please note that we are only required to respond to one request per customer each year concerning this law, and we are not required to respond to requests made by means other than as indicated above.

Under the CCPA, California residents:

• May request the Personal Information Pintuna collects, uses, and discloses about the customer

• May request Pintuna delete the customer’s Personal Information. As noted in this Privacy Policy, Pintuna may retain information as permitted by law.

• May opt-out of sales of Personal Information. As noted, Pintuna does not sell customers’ Personal Information to third-parties in the traditional sense. Pintuna will only use your Personal Information to complete an order you place through its Sites or using its Services.

• May request the categories of Personal Information collected by Pintuna and the sources of the Personal Information collected, including information shared with third-parties for marketing purposes

• May request how the customer’s Personal Information is used and with whom Pintuna shares it

To request any of the foregoing, please contact us at support@pintuna.com. For the safety and security of Pintuna’s customers, Pintuna must verify a customer’s identity prior to honoring any request regarding Personal Information. Pintuna implements a 2-step verification to confirm a customer’s identity regarding any privacy request. Pintuna may also use other methods to verify a customer’s identity prior to responding to any request. If a customer wishes to use an authorized agent to make a request, the authorized agent will need to provide sufficient evidence of authorization, including, but not limited to, written authorization from the customer that the agent may act on the customer’s behalf.

Notice to Vermont Residents

In accordance with Vermont law, we will not disclose information we collect about Vermont residents to unaffiliated companies and will not disclose application and third-party credit-related information about Vermont residents to our affiliated companies except as follows:

• With the authorization or consent of the Vermont resident;

• To companies that perform marketing or other services on our behalf;

• Name, contact and transaction and experience information (such as account balance and payment history) to other companies with which we have joint marketing or servicing • agreements; or

• As permitted by law.

Notice to Nevada Residents

Nevada law requires that we provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; Phone number: 702-486-3132; e-mail: BCPINFO@ag.state.nv.us.

Notice to Users Outside of the United States

This Online Privacy Policy is intended to cover collection of information on the Site from residents of the United States. If you are visiting the Site from outside the United States, please be aware that your information may be transferred to, stored and processed in the United States where our servers are located and our central database is operated. The data protection and laws of the United States and other countries might not be as comprehensive as those in your country. By using our Services, you understand that your information may be transferred to our facilities and those third-parties with whom we share it as described in the Policy above.