Tantrum Street

Online Privacy Statement

Effective as of February 21, 2016

Overview

Effective as of February 21, 2016

Tantrum Street LLC (“Tantrum” or the “Company”) respects your privacy and works hard to protect your personal information. This Statement – along with the separate notice hyperlinked below – describes how we collect, use, and share your personal information.

IMPORTANT: A separate Notice (What Does Tantrum Street LLC Do With Your Personal Information?) is the primary document that describes how Tantrum handles your non-public personal information. To access the Notice, please click here. This Statement supplements the Notice with additional information.

Throughout this Statement, we refer to our website(s), all Tantrum Street product offerings, software, and services (including Cartwheel Register and Skip Wallet) collectively as the “Services.” When you use our Services, you agree that we may use your personal information as described in this Statement and the Notice.

This Statement and the Notice do not describe the practices of any other party that may have access to your personal information, including the practices of merchants who may collect information from you when you interact with them using the Service. To the extent that the Company provides your personal information to its agents or service providers, we take commercially reasonable steps to ensure that they safeguard the confidentiality of such information and use it only for intended purposes.

We use technology to help us collect information

In addition to collecting non-public personal information from individuals who register to use our Services and from other sources (as described in the Notice), Tantrum collects information from individuals who simply visit the Company’s websites.

For example, as you navigate the Company’s websites, Tantrum may collect information about you through the use of “cookies” or similar information-gathering tools. Cookies are small data files that identify you when you use our Services. The information that we may collect with cookies and similar tools includes standard information from your web browser and/or mobile device (such as unique mobile device identifier, browser type, browser version, and browser language), your Internet Protocol (“IP”) address, and the actions you take on the Company’s websites, such as the webpages you view and the links you click.

In addition, log file information is automatically reported by your browser each time you access a webpage. When you register with or view our site, 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 web request, mobile device identifier, IP address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other such information.

We use cookies and log file information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information; (c) monitor the effectiveness of our Services; (d) monitor aggregate metrics such as total number of visitors and traffic; (e) diagnose or fix technology problems reported by our users or engineers that are associated with certain IP addresses; and (f) help you efficiently access your information after you sign in. You have the option to decline or delete our cookies by adjusting your browser or mobile device settings, but this may interfere with your use of our Services.

From time-to-time, Tantrum may engage third parties to track and analyze non-personally identifiable usage and volume statistical information from individuals who visit the Company’s websites. These third parties may place material on our websites, such as banner ads, that allow their servers to place cookies in your web browser. Tantrum may also use other third-party cookies to track the performance of Company advertisements. The information provided to third parties by means of these third party cookies does not include personal information, but this information may be re-associated with personal information after the Company receives it. You may disable the ability of your web browser to receive third party cookies without impairing your ability to use our Services.

Using and sharing your personal information

As described in the Notice, Tantrum will not rent or sell your personal information for third parties to market to you. However, Tantrum may use and share your personal information for the purpose of providing our Services to you, for purposes of fraud control, or in other circumstances permitted by law. For example, Tantrum may disclose your personal information, among other circumstances, in order to: (a) analyze how the Services are used; (b) diagnose service or technical problems; (c) personalize content; (d) comply with legal process; (e) investigate, prevent, or take action regarding suspected or actual illegal activities; (f) enforce our user agreement; (g) investigate and defend ourselves against any third-party claims or allegations or other liability; (h) protect the security or integrity of our site; (i) sell or transfer all or a portion of our business or assets; or (j) protect the rights, property, or personal safety of Tantrum, our users or others. Note that when you use certain Services, you must enter personal information, including credit or debit card information and/or your Skip Wallet PIN, into a mobile device owned and operated by a merchant or another third party. We make efforts to keep this information confidential, but cannot absolutely guarantee its security.

From time to time, we may run contests, special offers, or other events or activities (“Events”) with third party partners. If you provide information to such third parties, you give them permission to use it for the purpose of that Event and for any other use that you approve.

Your choices about your information

Tantrum intends for the personally identifiable information that it collects to be reliable, accurate, complete, and current. If we discover that corrections are necessary with respect to any such information, we will update our records.

You may update or correct your account information at any time by logging in to your account and providing us with updated information. You can review and correct other personal information by contacting us as described below. Requests to access, change, or delete your information will be handled within 30 days.

Note that even if you choose to deactivate your account, we may retain archived copies of certain information about you and your transactions for a period of time that is consistent with applicable law.

Location information

When you first launch any of our mobile applications, you may be asked to consent to the application’s collection of location information. If you consent, information regarding your location may be transmitted to us and/or to third parties in order to provide Services to you. In some circumstances, we may not be able to provide our Services without this location information, which means that you may not be able to use our Services if you do not provide your consent.

If you initially consent to our collection of location information and change your mind, you can revoke your consent by changing the preferences on your mobile device. You also may stop our collection of location information by following the standard uninstall process to remove all Tantrum applications from your device.

Children's online privacy protection

Tantrum does not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to register to use our Services. If you are under 13, please do not send any information about yourself to us, including your name, address, telephone number, or email address. If we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information promptly. If you believe that we might have any information from or about a child under the age of 13, please contact us as described below.

Tantrum is not responsible for the practices employed by third party website that we may link to, nor for the information or content contained therein. We encourage you to review the privacy statements of other websites to understand their information practices and terms of service.

Communication preferences

We may provide notifications to you that are required by law or that are for marketing or other business-related purposes. Subject to applicable law, we may provide such notifications to you via email, hard copy, or through conspicuous posting on our websites or the software on your mobile device. We reserve the right to determine the form and means of providing notifications to you.

You may manage your receipt of marketing and other non-transactional communications by emailing us at privacy@tantrumstreet.com or by clicking on the “unsubscribe” link located on the bottom of the Company’s marketing emails. You cannot opt out of receiving transactional emails related to your account with the Company or the Services.

Changes and updates

We will post notifications of revised versions of this Statement and the Notice on our website(s) at least thirty calendar days before the changes take effect. We encourage you to review this Statement and the Notice whenever you use our Services to stay informed about our information practices.

Contact

Questions regarding this Statement, the Notice, or our information practices should be directed to our Privacy Department by emailing us at privacy@tantrumstreet.com, at calling us at either 214-989-3370 or by sending a letter to:

Tantrum Street LLC Attn: Privacy Department 2929 Canton St. Dallas, TX 75226

Privacy Policy for IP Commerce, Inc

At IP Commerce, Inc. (“IPC”), maintaining and protecting the privacy of IPC customers is very important. IPC believes that protecting your privacy is an integral part of the service provided and IPC knows that you care about how your information is used and shared. This policy describes how IPC collects, stores, uses and protects your personal information.

BY APPLYING FOR TANTRUM STREET SERVICES, YOU EXPRESSLY CONSENT TO OUR USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.

Throughout this policy IPC uses the term “personal information” to describe information that can be used to identify a specific applicant (person or business). IPC does not consider personal information to include information that has been anonymized so that it does not identify a specific user.

How does IP Commerce Collect your Personal Information and What Personal Information Does IP Commerce Gather?

IPC has limited relationships with third parties (“Partners”) and the service IPC provides for them allows you to conveniently apply on-line for a variety of programs offered by its Partners. When you request IPC Partners’ products or services, you are permitting IPC to collect your personal information on their behalf and to provide your personal information to the Partner to fulfill your request. In order to process your application, for example, IPC will request your full name, address, phone number and email address. Our Partners may require additional information, such as your date birth, credit/debit card number, bank account information, social security number or taxpayer identification number, in order to process your application. IPC may also obtain information about you from third parties, such as credit bureaus and identity verification services.

What Security Measures IPC Takes

IPC stores and processes your personal information on IPC computers located in the US. IPC protects it by maintaining physical, electronic and procedural safeguards in compliance with applicable US federal and state regulations. IPC uses computer safeguards such as firewalls and data encryption, enforces physical access controls to our buildings and files, and authorizes access to personal information only for those employees and contractors who require it to fulfill their job responsibilities. When IPC asks you to provide your personal information, it will do so through the Secure Sockets Layer (SSL) protocol, also known as HTTPS. This protocol provides security for your information by encrypting it as it travels from your computer to IPC’s computer. For security purposes, IPC encrypts all submitted data and limit access via other access controls. IPC employees and contractors who have access to personal information are trained in security measures and are required to safeguard your information. Additionally, IPC regularly monitors the adequacy of security procedures through internal and third-party audits.

How IPC Uses and Shares your Personal Information

If you indicate to IPC that you are interested in applying for a program offered by an IPC Partner, the information IPC collects about you will be shared with that Partner. Please note that Tantrum Street has its own privacy policies and IPC does not monitor the subsequent use of your personal information by its Partners. If you prefer that IPC not communicate your personal information to the Partner – DO NOT APPLY. In the course of performing IPC services, IPC may also be reporting to its Partner the personal information collected about you from credit bureaus and/or consumer reporting agencies. IPC may disclose your personal information to law enforcement, government officials or other entities when compelled to do so by a subpoena, court order or similar legal procedures, when needed to do so to comply with law or credit card rules or when in good faith the disclosure of personal information is necessary to prevent physical hard or financial loss or to report suspected illegal activity. Finally, IPC may also share your personal information with companies that IPC merges with or are acquired by. See below for further information regarding business combinations.

IPC will not sell or rent any of your personal information to third parties for their marketing purposes and only shares your personal information with third parties as described in this policy.

The Collection of Anonymous Data

In order to enhance the usefulness of IPC products and services, IPC will collect data about customers’ use of IPC services in a manner that does not include any personal information. While you utilize the service, IPC notes which service pages you visit and the IP address of your computer, but does not link that address information to your personal information. The general information IPC gathers enables IPC to serve our customers better by continually enhancing the service based on up-to-date use patterns.

How Long Does IP Commerce Retain Your Personal Information?

IPC retains all of your information in an on-line fashion for 90 days. IPC does not retain hard copies. After 90 days, applicant information is destroyed. Partners will retain information per their own privacy policies.

Accuracy of your Personal Information

IPC is neither responsible for the accuracy of the information you provide, nor the information that is returned from processing. IPC cannot edit applicant data or results. If you believe that some of the information that was returned is inaccurate, you must contact the Partner to whom you are applying. Information concerning which services your application was processed through, as well as reasons for acceptance or decline, is available from the Partner.

Notification of Changes to this Privacy Policy

This privacy policy may be revised over time as IPC adds new features to its services or as IPC incorporated comments from customers. IPC may amend this privacy policy at any time by posting a revised version on IPC’s Website. Generally, the revised version will be effective at the time of posting. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection. Your personal information will not be used by IPC for any further purposes, except as required to prevent fraud and assist law enforcement, as required by law in accordance with this privacy policy.

Business Combination

In the event of an acquisition of all or part of IPC by another company, or in the event that IPC were to sell or dispose of all or a part of the business, or engaged in another form of business combination, the acquirer would have access to the information maintained by IPC, which could, subject to applicable law, include your personal information. The acquirer’s privacy policy might be different than IPC’s privacy policy, or the acquirer might choose to amend IPC’s privacy policy. IPC will follow the procedures described above, “Notification of Changes to this Privacy Policy,” in the event of changes in this policy resulting from a business combination. Please contact IPC at any time for the most current version of their privacy policy.

The Use of Cookies

IPC may use “cookies,” which are pieces of information that a service transfers to your web browser for record keeping purposes, to facilitate your use of products and services. These cookies provide IPC with a means of identifying you and locating your record in the event you save or submit an application. They do not contain personal information and do not grant any access to the application you have on file with IPC.

You may decline IPC cookies if your browser or browser add-on permits, but doing so may interfere with the use of IPC’s Website.

IPC Partners who allow you to use IPC services may employ cookies and action tags (also known as single pixel gifs or web beacons) to measure usage. IPC cannot comment on their usage.

Links to Other Services

Some pages on the IPC Service may contain links to other services provided by third parties. IPC does not provide any personally identifiable customer information through these links. When you click on one of these links, you are moving to third party’s site. Any information you submit after that point is out of IPC’s control. IPC does not have access to or control over cookies or other features that they may use and encourage you to read the privacy statements of these linked services as their privacy policy may differ.

IP Commerce Policy Regarding Children

Children are not eligible to use IPC services and we insist that minors (persons under the age of 18) do not submit any personal information or use IPC services. We do not knowingly collect personal information about children.

You Can Contact IP Commerce

If you have privacy-related questions that are not addressed here, please contact Operations Support at IP Commerce, Inc., 1001 17th Street, Suite 400, Denver, CO 80202.