This privacy policy was last modified on 11/11/2013.

We recognize the importance of protecting your privacy and we work hard to safeguard your personal information. Our Privacy Policy is designed to assist you in understanding how we collect, use and store the information you provide to us when using any of our Services. Our Privacy Policy explains:

• What information we collect
• How we use, disclose, share and protect collected information
• How you can control, access and update any of your personal information

Please take a moment to review and become comfortable with our policy, key definitions are in Appendix 1 to assist you with your review.

Information We Collect

In general, we collect information to allow you to utilize, as well as to enhance your experience with, any of our Services.

We collect Personal Information that you submit to us voluntarily. When you personalize your profile and use the features of our Services, we will collect any information you voluntarily provide, and we may also request optional information to further enhance your use of our Services. We also collect transaction information about you, such as purchase and incentive activity, as well as, financial information as needed to process payments for items that you buy. We may be required to collect additional data at the direction of the third party that has contracted us to facilitate the processing of some payment transactions. You agree to provide accurate and complete information when providing this requested information. When you contact FreedomPay, we may keep a record of your communication to help solve any issues you might be facing. In some cases, if you decline to share requested information with us, we may not be able to provide you with certain Services.

We may obtain Personal Information about you from other sources, third parties or other companies we have contracted with or partnered with to provide our Services. At times, we may obtain information from third party verification services and credit bureaus.

When you use our Services, we use technology to automatically collect non-personally identifiable information. When you utilize our sites, our servers automatically record certain information that your web browser sends whenever you visit any website. These server logs may include information such as your IP address, browser type, URLs, pages viewed, and other such information. It is essential to track how our website is used, and we (or our service providers) may place cookies on your computer or device. Log file information is automatically reported by your browser each time you access a web page. This information is collected on an aggregate basis without any association to your personal information so that your identity remains anonymous. This type of information is collected to tailor the experience with our Services to meet your special interests and needs.

How We Share the Information We Collect

We may share or permit access to personal information with persons we employ directly or as contractors or agents, partners, or affiliates at our direction, for purposes of administering our Services, processing information, marketing our Service and providing customer support. We share personal information with certain third parties such as banks, processors, card networks, phone centers and other suppliers and vendors in order to provide the Services and to help us process the Services you request. FreedomPay may require such third parties to maintain confidentiality of your personal information. Note: FreedomPay supports the Cruise Card product on behalf of BCU and will only share data with BCU in an effort to provide support for the product and BCU members and in accordance with applicable law

FreedomPay provides certain personal information of customers to a Merchant or Sponsor, but only to the extent you have purchased or redeemed a FreedomPay incentive offered by Merchant or Sponsor third parties as is required to perform Services.

If you choose to enter any contest, sweepstakes or other promotion offered via Services, your personal information may be shared to third parties in order to administer such promotion. Also, by entering a promotion, you are agreeing to the official rules that govern that promotion, which may contain specific requirements of you, except where prohibited by law, allowing the sponsor(s) of the promotion to use your personal information in advertising or marketing associated with the promotion.

We release account and other personal information when we believe release is appropriate to comply with the law; protect the rights, property or safety of FreedomPay, our users or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction. Certain federal, state and local laws or government regulations may require us to disclose non-public personal information about you to respond to court orders or legal investigations. Note that this does not include selling, renting, sharing, or otherwise disclosing personally identifiable information from customers for commercial purposes in violation of the commitments set forth in this Privacy Policy.

We may also aggregate and disclose this aggregated information that is not personally identifiable. Generally, this aggregated information is used in statistical analysis.

In the event that FreedomPay or substantially all of its assets goes through with a business transaction such as a merger, acquisition by a third party or a seal of all or a portion of our assets, your personal information may be one of the transferred assets.

We will ask for your consent before using information for a purpose other than those that are set out in this Privacy Policy.

Protecting Your Information

All collected data is stored in a third-party hosted environment audited to and compliant with relevant governing policies, such as; PCI DSS Level 1 as required by the Payment Card Industry. Our policies and procedures to maintain the physical and electronic security of our software, services and your personal information have been implemented in accordance with US state and federal law and regulations. Our measures satisfy the requirements of the appropriate governing policy with respect to the access and use of data on our system.

FreedomPay employs software designed to protect your information against unauthorized third party access. We encrypt many of our Services using an industry standard Secure Sockets Layer (SSL).

Communications you may have with us via email or U.S. Mail may not be secure unless we advise you that security measures are in place prior to your sending information. Therefore, if you choose to communicate with us through these means, you are assuming the risk of doing so and we request that you do not send or post sensitive information through these means.

It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when finished using a shared computer.

Providing Notice

We have a privacy breach notification policy in order to deliver notices in a timely and legal fashion. We are prepared to manage a notification process internally, however, if needed we are prepared to engage third parties as necessary to assist with a notification process. Our program includes a clear escalation path, based on the type or severity, or both, of the incident, up to executive management, and as needed, legal counsel. Our program sets forth a process for contacting law enforcement, regulatory, or other authorities when necessary. Program training for new hires and team members, and awareness training for general staff, is conducted annually, when a significant change in the program is implemented, and will be conducted if any major incident occurs. To report any complaints or disputes, please contact support at support@freedompay.com or toll-free at 1.866.399.2544.

Choices Regarding Your Personal Information

You have a right to access your personal information to change, update, and review the information that FreedomPay holds. You have the right to correct, amend, or delete that information when it is inaccurate (except when the burden or expense of providing access would be disproportionate to the risks to your privacy, or when the rights of other persons would be violated). It is your responsibility to update personal information as necessary by logging in to the member site, or by contacting us directly at support@freedompay.com or toll-free at 1.866.399.2544.

We offer you choices regarding the collection, use, and sharing of your Personal Information. You have a right at any time to stop us from contacting you for marketing purposes. When you receive promotional communications from us, you may indicate a preference to stop receiving further promotional communications from us and you will have the opportunity to "opt-out" by following the unsubscribe instructions provided in the promotional e-mail you receive or by contacting us directly at support@freedompay.com or toll-free 1.866.399.2544.

Data Retention

All information collected, passive and personally identifiable is used only for the purposes identified in this Privacy Policy and retained for no longer than necessary to fulfill the stated purposes, or for a period specifically required by law or regulation. Information that has reached expiration is disposed of in a manner that prevents loss, theft, misuse, or unauthorized access as per Company policies.

Application

This Privacy Policy applies to all of the Services offered by FreedomPay.

Links to Other Sites

Our Website may contain links to other sites. We are not responsible for the content, products or services offered or the privacy and security practices employed by these other sites. When you leave our site please review the privacy statements of each Website that collects personally identifiable information.

Conditions of Use, Notices and Revisions

Accessing or using any Services constitutes acceptance of this Privacy policy. If this Privacy Policy conflicts with your third party Member Agreement , the terms of your Member Agreement takes precedence. Your continued use of the Services following the posting of changes to this policy will signify that you accept these changes.

Children under the age of 13 are not permitted to use Services and we do not intentionally collect or maintain Personal Information from those who are under 13 years old. Protecting the privacy of children is very important to us. We recommend that children between the ages of 13 and 18 obtain their parent's permission before submitting information over the Internet. By using Services, you are representing that you are at least 18 years old, or that you are at least 13 years old and have a parent's or guardian's permission to use Services.

We reserve the right to revise this Privacy Policy occasionally at our discretion, and if we do we will change revision date on this page. We will post notifications of revised versions of our policy on our website, and revised policies will be immediately effective. Please check our Web site frequently to see recent changes. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account.

Contact Us

If you have questions or concerns about our Privacy Policy, please contact us at support@freedompay.com or contact us at 1.866.399.2544 and we will try to resolve it. We can also be contacted from our website by visiting the below URL and filling out the contact form: http://corporate.freedompay.com/about-us/contact-us

Appendix 1: KEY Definitions

Cookies are alphanumeric identifiers that we transfer to your computer's hard drive through your Web browser to enable our systems to recognize your browser and to provide such features as tracking your preferences, delivery of content specific to your interests, and for other similar purposes. The Help portion of the tool bar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. However, we recommend that you leave them turned on as certain features may not function properly if cookies are disabled.

Services - All of FreedomPay's online and mobile services, any content or information therein, the www.freedompay.com and the www.vibenow.com websites, any sub-domains, our software, applications and services.

Personal Information - Information about you that is personally identifiable, such as your name, email address, credit card, user ID, password, etc.; data that can be linked to a specific individual.

IP Address - An Internet Protocol Address is a number that is automatically assigned to your computer when you use the Internet, similar to a physical home address, an IP address tracks where you are virtually on the Internet.

Log Files - Log Files include, but may not be limited to, data recorded automatically by our system(s) when providing you with any of our Services. Most of our 'log files' include information about traffic to our web sites (e.g. which pages were accessed, at which time, and from which IP Address), mobile application(s) usage (e.g. device information, time service was accessed, etc.), and payment transactions commit by you through our system.