PRIVACY POLICY
Last Updated: April 23, 2021

Ten10 LLC (the “Company,” “we,” “us,” “Ten10” and “our”), knows that you care about how your personal information is used and shared, and we take your privacy seriously. Our primary goal is to provide you with exceptional service, and we understand that you may have questions or concerns regarding your personal information and how it will be used. To make this privacy policy easy to find, we make it available from the home page of the Ten10 website at ten10.app (the “website”) and through our mobile applications. You may also contact us with any privacy-related questions you have.

This privacy policy (this “Privacy Policy”) explains how we may collect, store, use, and disclose information when you access or use (1) our website located at www.Ten10.app and all of our other websites to which this Privacy Policy is posted (collectively, the “Website”); (2) our mobile applications to which this Privacy Policy is posted (collectively, the “Application”); and (3) any services, content, and features made available by us through the Website or the Application (together with the Website and the Application, the “Services”).

YOUR ACCEPTANCE OF THIS PRIVACY POLICY
By accessing or using the Services, you consent to our collection, storage, use, and disclosure of your information as described in this Privacy Policy. The provisions contained in this Privacy Policy supersede all prior notices and statements regarding our privacy practices with respect to the Services. If you do not agree to every provision of this Privacy Policy, you may not access or use the Services.

PROTECTING CHILDREN’S PRIVACY
The Services are not directed to children under the age of 13. If we obtain actual knowledge that we have collected personal information from a child under the age of 13, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 13.

TYPES OF INFORMATION WE COLLECT AND HOW WE COLLECT IT
When you access or use the Services, we may collect information that identifies you (“Personal Information”), and we may also collect information that does not identify you (“Anonymous Information”). When Anonymous Information is, directly or indirectly, associated or combined with Personal Information, such Anonymous Information will be considered Personal Information for purposes of this Privacy Policy. In addition, to the extent Internet Protocol (“IP”) addresses or similar identifiers or information are considered personally identifiable information by applicable law, we will treat such identifiers and information as Personal Information under this Privacy Policy.

Information You Provide to Us. In general, you may visit the Website or download the Application without telling us who you are or sharing any Personal Information with us. When you register for an account for the Services (an “Account”), use other aspects of the Services, or communicate with us for customer service or technical support for the Services, we may ask you to provide certain Personal Information, such as your name, email address, postal address, mobile number, and payment account information.

Additionally, if we are required by law to send to you and file certain forms with tax authorities, we may ask you to provide us or our service provider certain personal information, including but not limited to your Taxpayer Identification Number. We may also ask you whether you want to receive text messages relating to the Services. By providing your mobile phone number, you expressly consent to receive text messages from us relating to the Services at that number. Third-party data and message fees may apply. You may decline to provide certain Personal Information to us, but, if you do so, certain features of the Services may not be available to you or the performance of certain features of the Services may be limited or not work at all.

Information Collected from Devices. When you access or use the Services via a computer or mobile device, including, without limitation, a desktop computer, laptop, mobile phone, tablet, or other electronic device (each, a “Device”), we may collect information from your Device, such as your Device type and manufacturer, your Device operating system and version, your mobile carrier, your Device identifiers, your mobile phone number, your IP address, your browser type, your network connection type, information about the webpage that referred you to the Website or that you visited prior to the Website, and your behavior and activity on the Website and the Application.

Financial Information. Ten10 uses highly secure third-party software to connect your bank account as a payment source (making Ten10 similar to a debit card in your phone). Ten10 does not have direct access to your bank routing number or account number.  All transactions are processed through a secure token with encryption for your protection.  No bank account information is ever shared with a business you transact with or any other third party.

In addition, if you download the Application to your mobile Device, we may collect information from your mobile Device about your location while you are accessing or using the Application and while you are not accessing or using the Application. We may use this information to provide targeted offers to you and notify you of nearby third-party locations where you may use the Services. You may opt out of the collection of location data at any time by changing your settings on your mobile Device. However, if you do so, certain features of the Services may not be available to you or the performance of certain features of the Services may be limited or not work at all.

Information Collected by Cookies and Similar Tracking Technologies. When you access or use the Services, we may place small data files on your Device that assign random, unique numbers to your Device to enable us to recognize your Device when you use the Services. These data files may be cookies, pixel tags, other local shared objects, or similar technologies provided by your browser or associated applications (collectively, “Cookies”). We may use Cookies to recognize your Device, manage and store your settings and preferences for the Services, improve the Services, offer targeted products and services to you, and collect and analyze information about your access and use of the Services.

The Cookies we use in connection with the Services may include the following:

• Session Cookies: Session Cookies are temporary Cookies that expire and are automatically erased when you close your browser window. We may use session Cookies to grant you access to content and to enable actions that require you to be logged into your Account to perform.

• Persistent Cookies: Persistent Cookies are Cookies that usually have an expiration date in the distant future and remain in your browser until they expire or you manually delete them. We may use persistent Cookies to better understand usage patterns so we can improve the Services. For example, we may use a persistent Cookie to associate you with your Account or to remember your choices for the Services.

• Third-Party Cookies: We may permit certain third parties to place Cookies (such as Google Analytics) through the Services to provide us with insight about the use of the Services and user demographics. These third parties may use Cookies to collect information about your online activities over time and across different websites when you access or use the Services. For example, we may use Google Analytics to analyze usage patterns for the Website and the Application. Google Analytics may generate a Cookie to capture information about your access and use of the Website and the Application that Google may use to compile reports on activity for us and to provide other related services. Your web browser may automatically send certain information to Google, such as the web address of the page that you are visiting and your IP address. To opt out of Google Analytics in connection with the Services, visit the Google Analytics opt-out page and install the add-on for your browser. For more details on installing and uninstalling the add-on, please see the relevant help resources for your specific browser. We do not control third parties’ use of Cookies or similar tracking technologies. Such use is subject to the respective third parties’ privacy policies.

By accessing or using the Services, you consent to the placement of Cookies on your Devices as described in this Privacy Policy. If you prefer not to receive Cookies through the Services, you may control how your browser responds to Cookies by adjusting the privacy and security settings of your web browser. Unless you set your browser settings to refuse all Cookies, our systems may issue Cookies when you access or use the Services. If you set your browser settings to refuse all Cookies, the performance of certain features of the Services may be limited or not work at all.

In some of our email messages to you, we may use “click-through URLs” linked to content on the Website or the Application. We track click-through data to help us understand and analyze interest in topics and use of the Services.

Do Not Track. Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not use technology that recognizes DNT signals from your web browser.

HOW WE SHARE PERSONAL INFORMATION WITHIN THE TEN10 NETWORK

To process payments on Ten10, we need to share some of your personal information with the busines that you are paying or giving you cash back. Your Facebook photo, contact information, date of sign-up, the number of payments you have received and other verification metrics like social graph activity may be provided to businesses you transact with, on, or through Ten10.

We work with vendors to enable them to accept payments from you using Ten10. In doing so, a vendor may share information about you with us, such as your mobile phone number or Ten10 username, when you attempt to pay that vendor. We use this information to confirm to that vendor that you are a Ten10 customer and that the vendor should enable Ten10 as a form of payment for your purchase.

Regardless, we will not disclose your bank account information to anyone you have paid through Ten10, except with your express permission or if we are required to do so to comply with a subpoena or other legal process.

Information Collected from Other Third Parties. We may collect Personal Information from third-party social networks, subject their respective privacy policies and your privacy settings. We may also collect Anonymous Information, including Device identifiers, from third-party devices present at certain third-party locations, such as retail stores, restaurants, and other points of interest. Such devices may use wifi, near field communication (NFC), or Bluetooth low-energy (BLE) beacon technology to transmit signals about the location of your Device to us so that we may notify you via push message that you are near a location where you may use the Services.

HOW WE PROTECT AND STORE YOUR PERSONAL INFORMATION

We store and process your personal information using third party servers located in data centers in the United States. This information is protected by physical, electronic and procedural safeguards in compliance with applicable US federal and state regulations. We also use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our office and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities.

We strive to ensure security on our systems. Despite our efforts, we cannot guarantee that personal information may not be accessed, disclosed, altered or destroyed by breach of our administrative, managerial and technical safeguards. Therefore, we urge you to take adequate precautions to protect your personal data as well, including never sharing your Ten10 password with anyone.

If Ten10 learns of a systems security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Services, you agree that Ten10 may communicate with you electronically. Ten10 may post a notice on the website or mobile application if a security breach occurs. We may also send an email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice of a security breach), please contact us.

HOW WE USE INFORMATION
We may use Anonymous Information as described elsewhere in this Privacy Policy and for research and commercial purposes, such as to improve the Services.

We may use Personal Information for the purposes described elsewhere in this Privacy Policy and internally for our general commercial purposes, including, among other things, to:

• provide the Services and notices related thereto;
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• analyze, improve and customize the Services;
• provide customer and technical support for the Services;
• send you announcements, newsletters, promotional materials, and other information about the Services and third-party products and services that we think may be of interest to you;
• detect, prevent and investigate actual or suspected fraud, hacking, infringement, or
• other misconduct involving the Services;
• collect fees and other amounts owed in connection with the Services; and
• comply with tax and other applicable laws

In the event you or Ten10 terminates your account, you agree that we may retain your data, including personal and transaction information, for one year from the date of termination for audit and merchant invoicing purposes.

HOW WE SHARE INFORMATION
We may share Anonymous Information with third parties as described elsewhere in this Privacy Policy and for our commercial purposes.

We do not share Personal Information with our affiliates or third parties, except as described elsewhere in this Privacy Policy and as follows:

• if you request or authorize it;
• to complete a transaction or provide a service requested by you;
• to our Third-Party Service Providers that provide services to support the Services, such as payment processing, data analysis, email delivery, hosting, order fulfillment, infrastructure, network storage, customer service, technical support, and promotional services and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them;
• to comply with applicable laws, rules, and regulations, including but not limited to tax laws;
• to comply with governmental and regulatory requests, court orders, and subpoenas;
• to protect our rights, property, and safety and the rights, property, and safety of our users and others
• to enforce our rights arising from any contracts entered into between you and us, including the Terms of Service;
• with merchants that you transact with that already have Personal Information about you for the purpose of verifying offer-qualifying transactions; and
• if the disclosure is done as part of a purchase, transfer, or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, your Personal Information may be one of the transferred assets) or in the event of bankruptcy.

YOUR CHOICES ABOUT YOUR INFORMATION
You may opt not to receive promotional emails from us by contacting us or by following the “unsubscribe” instructions in any promotional email you receive from us. Please note, however, that we may still send you non-promotional emails about your relationship with us.

INFORMATION YOU SHARE SOCIALLY
The Services may allow you to connect and share your actions, comments, content, and information publicly or with friends. The Company and the Payment Card Networks are not responsible for maintaining the confidentiality of any information you share publicly or with friends. In addition, the Services may allow you to connect with us on, share on, and use third-party websites, applications, and services. Please be mindful of your personal privacy needs and the privacy needs of others as you choose to connect and share information with friends and others. We cannot control the privacy or security of information you choose to make public or share with others. We also do not control the privacy practices of third parties. Please contact those websites and services directly if you want to learn about their privacy practices.

HOW WE PROTECT YOUR INFORMATION
We have, and require our Third-Party Service Providers to have, administrative, technical, and physical safeguards in place in our respective physical facilities and in our respective computer systems, databases, and communications networks that are reasonably designed to protect information contained within such systems from loss, misuse, and alteration. The measures we use may include storing Personal Information on secured servers, transmitting Personal Information using encryption technologies, and auditing and reviewing our data collection and storage practices.

To be clear, we do not store your Payment Card account information, and we do not have control over or responsibility for your Payment Card account information. When you provide your Payment Card account information through the Website or the Application, it is stored and/or processed by our Third-Party Service Providers in order for you to use the Services. Our contracts with these third parties require them to have administrative, technical, and physical safeguards to protect the security and confidentiality of such information.

No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your Personal Information. You also play a role in protecting your Personal Information. Please safeguard your username and password for your Account and do not share them with others. If we receive instructions using your Account log-in information, we will consider that you have authorized the instructions. You agree to notify us immediately of any unauthorized use of your Account or any other breach of security related to the Services. We reserve the right, in our sole discretion, to refuse to provide the Services, terminate your Account, and to remove or edit content.

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
Subject to applicable law, which might, from time to time, oblige us to store your Personal Information for a certain period of time, we will respect your wishes to correct inaccurate information. Otherwise, we will retain Personal Information for the period of time necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by applicable law. You may change your Account information at any time by updating your Account profile via the Website or the Application.

LINKS TO THIRD-PARTY WEBSITES AND APPLICATIONS
When you access or use the Services, you may be directed to other websites or applications that are beyond our control. We may also allow third-party websites or applications to link to the Services or use Cookies with the Services. We are not responsible for the privacy practices of any third parties or the content of linked websites and applications. We encourage you to read the applicable privacy policies and terms and conditions of such parties, websites, and applications. This Privacy Policy only applies to the Services.

SOCIAL SECURITY NUMBERS AND TAXPAYER IDENTIFICATION NUMBERS
In certain circumstances we are required to collect Social Security Numbers or Taxpayer Identification Numbers in connection with an individual’s participation. This information is required by law for governmental and tax purposes. It is our policy to protect the confidentiality of Social Security and Taxpayer Identification Numbers. We use these types of data to carry out our business needs and to comply with local, state and national governmental requirements including tax reporting, among other things. We do not use this information for identification purposes.

We have adopted administrative, technical and physical procedures to restrict access to this information to those employees or agents who need to use it for our business purposes and to protect it from unauthorized use, disclosure, access, or destruction. We may disclose this information to third parties, such as our service providers, who agree to protect this information and to keep it confidential and secure. We destroy, erase or render unreadable this type of information when disposing of our records. Our employees periodically undergo training regarding the safeguarding of Social Security and Taxpayer Identification Numbers.

CHANGES TO THIS PRIVACY POLICY
We may revise this Privacy Policy from time to time in our sole discretion, subject to applicable law. When we revise this Privacy Policy, we will post the revised version on the Website and the Application. The revised Privacy Policy will be effective upon posting on the Website and the Application, unless otherwise set forth therein or as otherwise required by applicable law. You are free to decide whether or not to accept a revised version of this Privacy Policy, but accepting this Privacy Policy, as revised, is required for you to continue accessing and using the Services. If you do not agree to this Privacy Policy or any revised version of this Privacy Policy, your sole recourse is to terminate your access to and use of the Services. Except as otherwise expressly stated by us, your access to and use of the Services are subject to the version of this Privacy Policy in effect at the time of your access or use of the Services.

CONTACT US
If you have any questions regarding this Privacy Policy or the Services, please contact us