Privacy Statement

This statement is effective as of 8/21/06.

Information Collection and Use

Registration

In order to enroll in a rewards program, you must first complete the registration form and create a user name and password. During registration you are required to provide contact information (such as name and email address). You may be required to submit financial information such as a credit card number and expiry date. We use this information to provide targeted offers from clients programs in which you have enrolled.

You have the option to provide demographic information (such as age range and gender) to us; we encourage you to submit this information so we can provide you a more personalized experience on our site.

Once registered, you will receive a welcome email and optionally targeted offers.

Loyalty Lab, Inc. manages the information collected on retailer.instorecard.com and derivative sites operated jointly by Loyalty Lab and its participating retailers. Loyalty Lab collects personally identifiable information from our users at several different points on our website. If, at any time, a participating retailer ceases to use Loyalty Lab 's services, the portion of active consumer data uniquely collected on their behalf will be removed from Loyalty Lab's systems.

Surveys or Contests

We may occasionally provide you the opportunity to participate in contests or surveys on our site. If you participate, we will request certain personally identifiable information from you. Participation in these surveys or contests is completely voluntary and you therefore have a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and shipping address), and demographic information (such as zip code).

We use this information to notify contest winners and award prizes.

The clients offering each program utilize our system in order to conduct these surveys or contests; we will not share the personally identifiable information you provide through a contest or survey with third parties other than the retailer for whom we are managing the rewards program unless we give you prior notice and choice.

Refer-A-Friend

If you choose to use our referral service to tell a friend about the rewards program, we will ask you for your friend's name and email address. We will automatically send your friend a one-time email inviting him or her to visit the site. Loyalty Lab Inc. generally uses this information for sending this one-time email and tracking the success of our referral program.

Your friend may use the unsubscribe link included in the referral email to request that we remove this information from our database.

Uses of Information

We use the information you submit to us in order to track your participation in the retailer's loyalty program, create targeted offers, and generate your awards. Additionally, we aggregate the behavior of users in all loyalty programs we manage for different retailers and create summary statistical analysis that we offer to participating retailers as a premium service.

Communications from the Site

Special Offers and Updates

We will occasionally send you information on products, services, special deals, promotions on behalf of the retailer in whose loyalty program you are currently enrolled.

Out of respect for your privacy, we present the option not to receive these types of communications. You may opt-out of these mailings by stopping your participation in the rewards program.

Service-related Announcements

We will send you service-related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email.

Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.

Customer Service

Based upon the personally identifiable information you provide us, we will send you a welcoming email to verify your username and password. We will also communicate with you in response to your inquiries, to provide the services you request, and to manage your account. Our communications will generally be limited to email only.

Profile

We store information that we collect through cookies, log files, and email-embedded clear gifs to create a 'profile' of your preferences. We tie your personally identifiable information, and your purchasing history, to information in the profile, in order to provide tailored promotions and marketing offers and to improve the content of the site for you.

We share your profile together with your personally identifiable information with the retailer whose loyalty program you are registered for. Otherwise, we do not share your profile with other third parties.

Supplementation of Information

Enhancement of Profile Information

We purchase marketing data from third parties and add it to our existing user database, to create better offers in which we think you would be interested. To enrich our Profiles of individual customers, we tie this information to the personally identifiable information they have provided to us.

Information Sharing and Disclosure

Aggregate Information (non-personally identifiable)

We share aggregated demographic information about our user base with our participating retailers. This information does not identify individual users.

We do not link aggregate user data with personally identifiable information.

Personally identifiable information

We share Personally Identifiable Information with participating retailers as part of their loyalty program. The information is used to analyze the success of each program.

Legal Disclaimer

We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our Web site

Choice/Opt-out

We provide you the opportunity to 'opt-out' of having your personally identifiable information used for certain purposes, when we ask for this information. You may opt out in the following ways:

Change your profile settings in customer application or use the unsubscribe link provided in emails to opt out of marketing email communications. You can also inactivate your account using customer application to opt out of the loyalty program.

Log Files

As is true of most Web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, referring/exit pages, date/time stamp, and clickstream data.

We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users' movements around the site and to gather demographic information about our user base as a whole.

We do not link this automatically-collected data to personally identifiable information.

Cookies

A cookie is a small text file that is stored on a user's computer for record-keeping purposes. We use cookies on this site.

We use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. We use session cookies to identify you while you logged in to your account. We use persistent cookies to retain definitions that affect your account's 'look and feel'. Neither cookie contains any personally identifiable information.

If you reject cookies, you may still use our site, but your enjoyment of our site will be degraded.

Clear Gifs

We use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If you no longer wish to receive these emails, please see 'Choice and Opt-out'.

Links to Other Sites

This Web site contains links to other sites that are not owned or controlled by Loyalty Lab Inc. Please be aware that we, Loyalty Lab Inc., are not responsible for the privacy practices of such other sites.

We encourage you to be aware when you leave our site and to read the privacy statements of each and every Web site that collects personally identifiable information.

This privacy statement applies only to information collected by this Web site.

Co-branded sites

Loyalty Lab Inc. creates a product that supports a retailer's loyalty program. All our sites are branded by retailers utilizing our services. Please be aware that although the site is branded by a particular retailer, submitted information is collected by Loyalty Lab Inc. and shared with the retailer.

Access to Personally Identifiable Information

If your personally identifiable information changes, or if you no longer desire our service, you may correct, update, delete or deactivate it by making the change on our member information page or by contacting us by at the contact information listed below.

Security

The security of your personal information is important to us. When you enter sensitive information (such as credit card number and/or social security number) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). We enforce the use of 128-bit encryption, and do not support 'fallback' methods for browsers that do not support this level of encryption.

We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

Loyalty Lab Inc. has been certified by Visa as part of Visa's Cardholder Information Security Program (CISP).

If you have any questions about security on our Web site, you can send an email to us at privacy@loyaltylab.com.

Business Transitions

In the event Loyalty Lab Inc. goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your personally identifiable information will likely be among the assets transferred. You will be notified via email or prominent notice on our Web site for 30 days of any such change in ownership or control of your personal information.

Changes in this Privacy Statement

If we decide to change our privacy policy, we will post those changes to this privacy statement, the homepage, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

We reserve the right to modify this privacy statement at any time, so please review it frequently.

Contact Us

If you have any questions or suggestions regarding our privacy policy, please contact us at:

Email: privacy@loyaltylab.com

Post: Loyalty Lab Inc., 575 Market Street, 14th Floor, San Francisco CA 94105

Telephone: (415) 659-8270