Xceleration Privacy Policy

Effective
Date / Last Updated: January 26, 2022

1.
Introduction

Your
privacy is important to us. We are Xceleration Partners, LLC (“Xceleration” or
“we” or “us”). We post this privacy statement (the “Privacy Statement”) so that
you are aware of the personal information we collect, how it is handled and
with whom it is shared.

This
Privacy Statement relates to the following websites:  www.xceleration.com, and www.rewardstation.com (together, the
“Xceleration Websites”), and services provided through Xceleration Websites or
Xceleration-Powered Websites (collectively the “Xceleration Services” or
“Services”).  An “Xceleration-Powered Website” means a website not owned
by Xceleration, but which has a license from Xceleration to utilize certain
Xceleration technologies. A “User” means any individual who has access through
the use of a password to an Xceleration Website or Xceleration-Powered Website,
including buyers of Xceleration Services, participants of programs provided
through an Xceleration Website or Xceleration-Powered Website, and employees
and agents of corporate clients and Suppliers.

Your Use of the Website or Services Implies Your Consent

Your
use of Xceleration Websites or Services signifies your acceptance of our
collection and use of your personal information in accordance with this Privacy
Statement.  If you do not agree or are not comfortable with any policy
described in this Privacy Statement, your remedies are to discontinue your use
of the relevant website or to follow instructions described elsewhere in this
Privacy Statement.

Changes in this Privacy Statement    

We
reserve the right to modify this privacy statement at any time, so please
review it frequently. If we make material changes to this policy or use of your
personal information, we will notify you within this Privacy Statement and by
means of notification on our home page, your program website, another
appropriate place or by email. We may also notify you by posting the updated
policy on our Websites and revising the “Effective Date” above. Please remember
to check back every so often for updates.

Testimonials

We
may post customer testimonials on our web sites, which may contain personal
information such as the customer’s name.  We obtain the customer’s consent
prior to posting such testimonial.

Security of Data

The
security of your personal information is important to us.  When you enter
information (such as credit card or social security numbers) on our
registration or order forms, we encrypt that information using secure socket
layer technology (SSL). (To learn more about SSL, go to
http://en.wikipedia.org/wiki/Secure_Sockets_Layer). When we store your
information in databases or in flat files, we utilize encryption technologies
designed to ensure data protection that is consistent with accepted industry
standards.

The
security of your personal information is important to us.  When you enter
information (such as credit card or social security numbers) on our
registration or order forms, we encrypt that information using secure socket
layer technology (SSL). (To learn more about SSL, go to
http://en.wikipedia.org/wiki/Secure_Sockets_Layer). When we store your
information in databases or in flat files, we utilize encryption technologies
designed to ensure data protection that is consistent with accepted industry
standards.

The
safety and security of your personal information, however, also depends on you.
Where we have given you (or where you have chosen) a password for access to
certain parts of our Websites or Services, you are responsible for keeping this
password confidential. We ask you not to share your password with anyone.

Laws and Regulations

This
Privacy Statement has been reviewed by legal counsel in conjunction with
applicable laws and regulations, and we will use commercially reasonable
efforts to monitor and update this Privacy Statement as necessary for legal
compliance purposes.  With regard to any personal information we collect
from citizens of the European Union, we agree to comply with the EU’s General
Data Protection Regulation (GDPR).

Retention Policy

We
will retain personal information only as long as necessary to fulfill the
purposes set forth in this Privacy Statement, or for a period specifically
required by law or regulation and thereafter will be disposed of securely or
made anonymous so that it cannot be identified to any individual.

Xceleration’s
specific retention policy is set at three years.  After three years, all
data that is not currently in use as part of an active program will be
destroyed.

Privacy Incident and Breach Management

We
have implemented a formal privacy incident and breach management program,
which specifies the following: (a) Incidents and breaches are reported to a
member of our breach team.; (b) The manager or employee responsible for privacy
issues and security has the overall accountability and is supported by the
privacy and security steering committee(s) .; (c) We have a privacy breach
notification policy in order to deliver notices in a timely and legal fashion.;
(d) Our program includes a clear escalation path.; and (e) Our program sets
forth a process for contacting law enforcement, regulatory, or other
authorities when necessary.

If
you feel there has been an incident or breach please contact Xceleration at
678-680-7363 or email us at info@xceleration.com (put “Privacy
Compliance” in subject line).

Changes Related to Privacy

We
have ongoing processes in place to monitor, assess, and address the effect on
privacy requirements from various changes, including but not necessarily
limited to changes related to legal and regulatory environments, industry
standards, contracts with third parties, business operations and processes,
people assigned responsibility for privacy and security matters, and
technology.

Categories of Who Is Covered in this Privacy Statement

• If you are a
  visitor to the portions of Xceleration Websites or an Xceleration-Powered
  Website that can be accessed without a password (our “Public Website”),
  please see the section “Public Website Privacy Statement” with respect to
  data about you. We refer to you as a “Public Website Visitor”
• If you are a
  User, please see the section “User Privacy Statement” below for
  information on our data processing practices with respect to data about
  you.

What Is Not Covered in this Privacy Statement

We
cover only our data processing practices described in this Privacy Statement.
Without limitation, this Privacy Statement does not cover data that we collect
offline, on businesses or legal entities or on our employees.

Xceleration
is not responsible for any practices employed by websites linked to or from our
website or their information or content. Please remember that when you use a
link to go from our Websites to another website, this Privacy Statement is no
longer in effect. Your browsing and interaction on any other website is subject
to that website’s own rules and policies. Please read over those rules and
policies before proceeding. The information they collect may be associated with
your personal information or they may collect information, including personal
information, about your online activities over time and across different
websites and other online services. They may use this information to provide
you with interest-based (behavioral) advertising or other targeted content. We
do not control these third parties’ tracking technologies or how they may be
used. If you have any questions about an advertisement or other targeted
content, you should contact the responsible provider directly.

Children’s Privacy

The
Children’s Online Privacy Protection Act was created to protect children under
the age of 13 from unsuspecting acts or practices in conjunction with
collecting, using, and disclosing any information about them. Our Services are
not intended for anyone under the age of 13. If you are under 13, do not use or
provide any information on or through our Services. If we learn we have
collected or received personal information from a child under 13 without
verification of parental consent, we will delete that information. If you are a
parent or guardian or otherwise believe we might have any information from or
about a child under 13, please contact us so that we can delete the child’s
information. The Services will never knowingly accept, collect, maintain or use
any information from a child under the age of 13. If a child whom we know to be
under the age of 13 sends personal information to us online, we will only use
that information to respond directly to that child or notify parents.

“Do Not Track” Disclosures

Certain
state laws require us to indicate whether we honor “Do Not Track” settings in
your browser over time and across third party websites as it relates to
targeted advertising. We adhere to the standards set out in this Privacy Policy
and do not monitor or follow any Do Not Track browser requests we might receive
from you or your browser.

Your California Privacy Rights

California
Civil Code Section § 1798.83 permits users of our services that are California
residents to request certain information regarding our disclosure of personal
information to third parties for their direct marketing purposes. To make such
a request, please send an email to info@xceleration.com

How You Can Contact Us

If you have questions or concerns regarding
this Privacy Statement, you should first contact us by email at
info@xceleration.com (put “Privacy Compliance” in subject line).  You can
also write to us at Attention: Privacy Officer, Xceleration Partners, LLC,
5901-A Peachtree Dunwoody Rd, Suite 200, Atlanta, GA 30328, USA. Xceleration
will respond to personal information change requests within 30 days of
receiving such requests.

2.
Overview of Xceleration Services

2.1 Suppliers of Services to Corporate Clients

Xceleration
provides access to its applications via Xceleration Websites and
Xceleration-Powered Websites to suppliers of services to corporate clients
(“Suppliers”). These Suppliers include travel and event reservation services,
and merchandise fulfillment suppliers.  Xceleration may share certain of
your information, including personal information, with such Suppliers. For
instance, Xceleration may share certain delivery information in order to make
sure certain rewards we have offered arrive at your correct address. Any such
Suppliers or other service providers are required by contract to implement
privacy and security safeguards in respect of your personal information that
are consistent with this policy.

2.2 Buyers of Services

Individuals
and companies (“Buyers”) use Xceleration’s technology via Xceleration Websites
or Xceleration-Powered Websites to design and manage incentive, recognition and
reward programs.

2.23 Participants of Programs Purchased by Buyers

Participants
(generally corporate client employees or stakeholders) use Xceleration Services
when invited or registered by a corporate client to participate in a program or
Services being provided to a corporate client. They do so by viewing an
Xceleration-Powered Website that contains incentive, recognition and/or reward
programs created by the corporate client. By accessing Xceleration Services,
the Participant provides information required for participation in reward
activities and programs.

3.
Public Website Privacy Statement

This
section describes how Xceleration uses and disseminates information collected
about Public Website Visitors through our Public Website; it does not cover any
other data processing activities.

We Won’t Collect Any Information about Public Website Visitors.

We
use cookies and various traffic tracking technologies to monitor the use of our
Public Websites. We collect such data related to Internet Protocol (“IP”)
addresses, browser type, and cookies, but do not link it to any personally
identifiable information (such as names and email addresses) that you may
submit to us through other means.

Use of Cookies.

A
“cookie” is a small text file containing information that a web browser
transfers to your computer’s hard disk for record-keeping purposes. On the
Public Websites, we may use cookies to analyze our site traffic patterns, but,
except as described above, we link cookies only to IP addresses and not any
personally identifiable information about Public Website Visitors.

To manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and related consents, we use the consent tool “Real Cookie Banner”. Details on how “Real Cookie Banner” works can be found at https://devowl.io/rcb/data-processing/.

The legal basis for the processing of personal data in this context are Art. 6 (1) lit. c GDPR and Art. 6 (1) lit. f GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.

The provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we will not be able to manage your consents.

 4. User
Privacy Statement

4.1 Buyers of Services for Corporate Clients

If
you are a User acting as a Buyer of Services, the following terms are
applicable to you:

4.1.1 General Information

• We may use
  your personal information for the purposes of (a) providing Xceleration
  Services or to provide you information you request about your account or
  our products or services; (b) facilitating communications between you and
  third parties; (c) our marketing activities; (d) all credit and other
  financial checks in relation to any payments made by you for Xceleration
  Services; (e) carrying out our obligations and enforcing our rights
  arising from any contracts entered into between you and us, including for
  billing and collection; and (f) fulfilling any other purpose for which you
  provide your personal information or any other purpose with your consent.
• Xceleration
  does not resell or transfer your e-mail addresses or any other personal
  information to third parties without your explicit permission or as
  allowed by law. The following are some examples of when Xceleration may
  share your personal information: (a) to our advisors, contractors, service
  providers, and other third parties we use to support our business 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; (b) to comply with any court order, law or legal process, including
  to respond to any government or regulatory request; (c) if we believe
  disclosure is necessary or appropriate to protect the rights, property, or
  safety of Xceleration, our employees and customers or others; and (d) to a
  buyer or other successor in the event of a merger, divestiture,
  restructuring, reorganization, dissolution or other sale or transfer of
  some or all of Xceleration’s assets or equity interests, whether as a
  going concern or as part of bankruptcy, liquidation or similar proceeding,
  in which personal information held by Xceleration about our users is among
  the assets transferred.

• You have a
  right to access personal information about you that Xceleration 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.
• Registering
  to use Xceleration Services requires you to give us some contact
  information (like your name, phone number, street and e-mail
  address).  We will use this contact information to send you
  information about our systems and Xceleration. Your contact information is
  also used to contact you when necessary (for example, following up on a
  request from you for technical support).
• You can
  update your records in the Xceleration system by accessing the user
  information administration feature in the system or by sending an email
  to info@Xceleration.com (put
  “Update Records” in the subject line). You can also write to us at
  Attention: Privacy Officer, Xceleration Partners, LLC, 5901-A Peachtree
  Dunwoody Rd, Suite 200, Atlanta, GA 30328, USA.

4.1.2 Communications

You
may choose to receive special offers and other messages from Xceleration or its
partners.  You may, however, also choose to cease receiving such messages
by updating your profile or sending an e-mail to info@Xceleration.com (put “Privacy
Compliance” in subject line) to change information previously provided, remove
your information from our database, cancel any future communications or to
cancel our service. You can also write to us at Attention: Privacy Officer,
Xceleration Partners, LLC, 5901-A Peachtree Dunwoody Rd, Suite 200, Atlanta, GA
30328, USA.

4.2 Participants of Programs Hosted by Corporate Clients

If
you are a participant using Xceleration Services to register for a program
hosted by a corporate client, the following terms are applicable to you:

4.2.1 General Information

• Your
  personal information and other pertinent information will be collected
  when you register for a program on an Xceleration-Powered Website. Any
  information that you provide will be stored on a system managed or
  controlled by Xceleration or a trusted partner on Xceleration’s behalf.
• The
  information you provide is the property of the corporate clients to whom
  you have provided the information.
• All such
  personal information is completely accessible to the respective corporate
  client and its agents.  Each Xceleration corporate client has its own
  privacy statement.  By providing your personal information to
  Xceleration for use by a corporate client or a Supplier (e.g. to make
  reservations with a particular hotel, or order an award to be shipped to
  your home address) you consent to Xceleration providing a copy of your
  personal information to that corporate client or Supplier for collection,
  processing and any further transfer in accordance with the privacy
  statement (if any) of that corporate client or Supplier.  Xceleration
  in not responsible for any actions of corporate clients or Suppliers;
  however, Suppliers are required by contract to implement privacy and
  security safeguards consistent with this policy.

4.2.2 Communications

Xceleration
corporate clients may use various methods for allowing you to choose to receive
or cease receiving messages, depending upon the individual corporate client’s
needs and the requirements for each specific program. Corporate clients may
include in their registration web site a question about not receiving messages,
use an unsubscribe email reply option, or use other means in which removal from
the invitee or participant list is an option.  Xceleration does not sell
or distribute data to any third party (other than to the applicable corporate
clients and Suppliers) except as authorized under this policy.

5.
EU and Switzerland Privacy Statement

5.1 Notice

Xceleration
collects personal information from and about individuals via Xceleration
Websites and Xceleration-Powered Websites for the purposes of (a) providing
Xceleration Services; (b) facilitating communications between you and third
parties; (c) our marketing activities; and (d) all credit and other financial
checks in relation to any payments made by them for Xceleration Services.

Any
complaints or questions should be first sent to us by email at info@Xceleration.com (put “Privacy
Compliance” in subject line).  Users can also write to us at Attention:
Privacy Officer, Xceleration Partners, LLC, 5901-A Peachtree Dunwoody Rd, Suite
200, Atlanta, GA 30328, USA. Xceleration will respond to personal information
change requests within 30 days of receiving such requests.

When
Xceleration receives personal information from the EU or Switzerland merely for
processing purposes in the United States and does not control the collection of
the personal information, Xceleration may not provide notification of this EU
and Switzerland Privacy Statement to the Users to which such personal
information relates. In such event, Xceleration reserves the right to process
personal information in the course of providing Xceleration Services to Buyers,
Suppliers or other of its clients or otherwise for Xceleration’s operation of
its business without the knowledge of the Users involved.

5.2 Choice

Except
as provided below, Xceleration gives Users from whom it collects personal
information the opportunity to choose not to allow Xceleration to disclose his
or her personal information to a third party or to use it for a purpose
incompatible with the purpose for which it was originally collected (the
“opt-out” rights). For Sensitive personal information, Xceleration requires
such User to affirmatively choose to allow for the data is to be disclosed to a
third party or used for a purpose other than its original purpose (the “opt-in”
choice).

Users
desiring to exercise their opt-out rights should first contact us by email
at info@Xceleration.com (put “Privacy
Compliance” in subject line). Users can also write to us at Attention: Privacy
Officer, Xceleration Partners, LLC, 5901-A Peachtree Dunwoody Rd, Suite 200,
Atlanta, GA 30328, USA.

When
Xceleration receives personal information merely for processing purposes in the
United States and does not control the collection of the personal information,
Xceleration may not provide such choices to the Users to whom such personal
information relates.

5.3 Accountability for Onward Transfer to Third Parties

Xceleration
may disclose personal information to a third party if (a) Xceleration has
received the applicable User’s permission to make the disclosure, (b) the
disclosure is required in response to a lawful request by public authorities,
including to meet national security or law enforcement requirements, or (c)
allowed by a law that creates conflicting obligations for Xceleration or that
explicitly authorizes disclosure (except that we will limit such disclosure to
the extent necessary). otherwise permitted by law.

5.4 Data Integrity and Purpose Limitation

Xceleration
takes reasonable steps to ensure that personal information is reliable,
accurate, complete, current and relevant for the purposes for which it was
collected.

5.5 Access

Xceleration
acknowledges that EU and Swiss individuals have the right to access the
personal data that we maintain about them.  Consistent with any applicable
client commitments, Xceleration will permit Users upon their request to access
their personal information and correct any erroneous information. The User may
need to provide sufficient identifying information, such as name, address,
birth date, and social security or national health insurance or an equivalent
number. Such access may be denied or limited by Xceleration if providing such
access is unreasonably burdensome, expensive under the circumstances, or if in
giving such access would violate another person’s rights. In some
circumstances, Xceleration may charge a reasonable fee for access to personal
information. Users can contact the Xceleration customer services team at
support@rewardstation.com to request access to change or delete personal
information.

6.
RIGHTS OF EU RESIDENTS UNDER GDPR

This
Section 6 only applies to users of our Websites who are residents of the
European Union.

6.1 Whenever we collect personal information from you, we may do
so on the following legal bases:

1. Your consent
   to such collection and use;
2. Out of
   necessity for the performance of an agreement between us and you, such as
   your agreement to use our solutions;
3. Our
   legitimate business interest, including but not limited to the following
   circumstances where collecting or using personal information is necessary
   for: (i) intra-organization transfers for client data for administrative
   purposes; (ii) product development and enhancement, where the processing
   enables us to enhance, modify, personalize, or otherwise improve our
   services and communications for the benefit of our users, and to better
   understand how people interact with our Website; (iii) communications and
   marketing, including processing data for direct marketing purposes, and
   subject to your opt-in for these purposes, and to determine the
   effectiveness of our promotional campaigns and advertising; (iv) fraud
   detection and prevention; (v) enhancement of our cybersecurity, including
   improving the security of our network and information systems; and; (vi)
   general business operations and diligence.

In
each circumstance, however, we will weigh the necessity of our processing for
the purpose against your privacy and confidentiality interests, including
taking into account your reasonable expectations, the impact of processing, and
any safeguards which are or could be put in place. In all circumstances, we
will limit such processing for our legitimate business interest to what is
necessary for its purposes.

6.2  We may retain your personal information for a period
of time consistent with the original purpose for collection.  For example,
we keep your personal information for no longer than reasonably necessary for
your use of our products and services and for a reasonable period of time
afterward. We also may retain your personal information during the period of
time needed for us to pursue our legitimate business interests, conduct audits,
comply with our legal obligations, resolve disputes and enforce our agreements.

6.3  Residents of the European Union have the following
rights under GDPR:

1. The right to
   be informed. You are entitled to be informed of the use of your personal
   information. This Privacy Policy provides such information to you.
2. The right of
   access. You have the right to request a copy of your personal information
   which we hold about you.
3. The right of
   correction: You have the right to request correction or changes of your
   personal information if it is found to be inaccurate or out of date.
4. The right to
   be forgotten: You have the right to request us, at any time, to delete
   your personal information from our servers and to erase your personal
   information when it is no longer necessary for us to retain such data.
   Note, however, that deletion of your personal information will likely
   impact your ability to use our services.
5. The right to
   object (opt-out): You have the right to opt-out of certain uses of your
   personal information, such as direct marketing, at any time.
6. The right to
   data portability: You have the right to a “portable” copy of your personal
   information that you have submitted to us. Generally, this means your
   right to request that we move, copy or transmit your personal information
   stored on our servers / IT environment to another service provider’s
   servers / IT environment.
7. The right to
   refuse to be subjected to automated decision making, including profiling:
   You have the right not to be subject to a decision and insist on human
   intervention if the decision is based on automated processing and produces
   a legal effect or a similarly significant effect on you.
8. The right to
   lodge a complaint with a supervisory authority.