Introduction

TClub Inc. (“Abound”, "Abound" or "We" or “Us” or “Our”) respects your privacy and is committed to protecting it through Our compliance with this policy. This policy describes:

• The types of information we may collect or that you may provide when you download and register with, access or use, or transact with the Abound / Abound Application or associated website, any associated content, material, or functionality contained on the Abound / Abound Application, all interactive features, applications, widgets, blogs, social networks and social network pages, and other online or wireless offerings that post a link to this Privacy Policy, whether accessed via computer, mobile device or other technology or any associated content, material, or functionality contained on the Abound / Abound Application (collectively, the "App"). The App is owned, developed and managed by Abound / Abound.

• Our practices for collecting, using, maintaining, processing, accessing, storing, protecting and disclosing that information.

• Your rights under applicable law.

This Privacy Policy applies only to personal information you provide or we collect via our App and services. This Privacy Policy does not apply to information that we collect through websites not under our control, including websites you may access through our App, or information that you provide to or is collected by any third party. These third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

If you are a resident of California, Virginia, Colorado, or Texas please also see our “State Privacy Rights” Section of this Privacy Policy.

Service Providers

Abound has relationships with certain service providers in order to provide its services to you. Abound has contracted with financial service partners including the Layer2 Group. Specifically, Layer2 Financial Holdings Inc. ("Layer2") is a Canada Corporation is a technology company. Layer2 Financial Inc., a Delaware Corporation ("Layer2 US") is a subsidiary of Layer2. As of 05/21/24, Layer2 notes on its website that Layer2 US is a FINCEN registered money service business (NMLS ID: 2438695) with money transmitter licenses in a number of states and that Layer2 Financial Inc., a Canada Corporation ("Layer2 CA") is a subsidiary of Layer2 and is a FINTRAC registered money service business (#M21596262). Collectively, all of the foregoing are referred to below as “The Layer2 Group”. Among other services, Layer2 Group, together with Buckzy Payments Inc., assists Abound with “Know Your Customer” requirements and other obligations.

For purposes of satisfying “Know Your Customer” requirements, Abound asks for your identifying information, such as your name, email address, tax identification number, address, telephone number, date of birth, gender, videos, and photographs that may contain images of your face, including your driver’s license or government-issued identification number or card. Abound will also collect information pertaining to your account transactions. Your personal information will be shared with Layer2 (including without limitation its Partner Financial Institutions, as well as Buckzy Payments Inc. (“Buckzy”)) and will be subject to the Layer2 Privacy Policy (to the extent shared with the Layer2 Group). Layer2 will share your information as necessary with its Partner Financial Institutions and other service providers in connection with providing their services.

Users under the Age of 18

The App is not intended for users under 18 years of age, and we do not knowingly collect personal information from individuals under 18. If we learn we have collected or received personal information from a user under 18, we will delete that information. Please be aware that we may not be able to fully delete certain user information until the user cancels their subscription through their Apple account. If you believe we might have any information from or about a individual under 18, please contact us at the e-mail address provided to you in Contact Information section.

Information We Collect and How We Collect It

We may collect information (including personal information) from and about users of the App directly from you when you provide it to us and/or automatically when you use the App. We may also collect personal information from you in connection with your rental application or if you are one of our residents. We retain the personal information that we collect to achieve the purposes for which the personal information was collected. In certain cases, we may need to retain personal information for purposes required under applicable law, for tax, accounting, or audit purposes, or for other purposes permitted or required under law.

Information You Provide to Us via the App.

When you use the App, we may ask for you to provide information by which you may be personally identified, such as, but not limited to, name, postal address, email address, telephone number, geolocation, mobile device identification number, or any other identifier by which you may be contacted online or offline (“personal information”), or that is about you but individually does not identify you.

This information includes information that you provide by filling in forms in the App. This includes information provided when posting material and requesting information. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with the App. We may also collect (a) records and copies of your correspondence (including email addresses and phone numbers), if you contact us; (b) your responses to surveys that we might ask you to complete for research purposes; (c) details of transactions you carry out through the App; and (d) your search queries on the App

You may provide information to be published or displayed to other users on or through the App (collectively, “Content”). Your Content may be transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of third parties with whom you may choose to share your Content. Therefore, we cannot and do not guarantee that your Content will not be viewed by unauthorized persons.

In the event that we provide you with social media login capability, in order to register as a user with us, you may be asked to sign in using your Facebook or other social media site (“SMS”) login. If you do so, you authorize us to access certain SMS account information, such as your public SMS profile (consistent with your privacy settings in SMS), your email address, interests, likes, gender, birthday, education history, relationship interests, current city, photos, personal description, friend list, and information about and photos of your SMS friends who might be common SMS friends with other users. You will also be asked to allow us to collect your location information from your device when you use the App. In addition, we may collect and store any personal information you provide while using the App or in some other manner. This may include identifying information, such as your name, address, email address and telephone number, and, if you transact business with us, financial information. You may also provide us photos, a personal description and information about your gender and preferences for recommendations, such as search distance, age range and gender. If you chat with other users, you provide us the content of your chats, and if you contact us with a customer service or other inquiry, you provide us with the content of that communication.

Automatic Information Collection and Tracking.

When you access the App, technology may be used to automatically collect certain information, including, but not limited to:

• Usage Details. When you access and use the App, we may automatically collect certain details of your access to and use of the App, including traffic data, location data, logs and other communication data and the resources that you access and use on or through the App.

  
  

  Device Information. We may collect information about your mobile device and internet connection, including the device unique device identifier, IP address, operating system, browser type, mobile network information and the device telephone number. Web servers, the main computers that serve up web pages, automatically identify your computer by its IP address. As permitted under applicable law, Abound collects IP addresses for the purposes of system administration, gathering and analyzing aggregated information, creating a better experience for users and auditing the use of our site. We do not normally link IP addresses to anything personally identifiable, which means that your session will be logged, but you remain anonymous to us. We will seek to link your IP address when we feel it is necessary to protect this site and other users from harm and to prevent criminal misconduct.

  Stored Information and Files. The App also may access metadata, tags and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts and address book information.

  Location Information. The App may collect real-time information about the location of your device.

The below chart further summarizes our collection, use, and disclosure of personal information:

Transaction Data Specifics

The Rakuten Card Linked Offer Network (“RCLON”), is the service provider of card-linked-offer content for Abound. Notwithstanding anything to the contrary in the Terms or Privacy Policy, we and our service providers (including RCLON will use transaction information solely as follows:

• Use transaction data to confirm a qualifying purchase or return to match transactions to confirm whether you qualify for a statement credit or an offer;

• Share transaction data with the participating merchant where a transaction occurred as needed for the merchant to confirm a specific transaction occurred or points should be awarded; for example, the date and amount of your purchase and the last 4 digits of your card number so the merchant can verify your purchase with its records if there is a missing or disputed transaction;

• Provide participating merchants or third party service providers aggregated and anonymized information relating specifically to registered card activity solely to allow participating merchants and third party service providers to assess the results of their campaign;

• Create a record of the transaction data and thereafter maintain and use data in connection with operating the Abound program;

• Conduct analysis for the improvement and optimization of the program; and

• Provide information in order to respond to a request from government authority or a payment organization involved in a transaction with you or a merchant.

• By registering a payment card in connection with transaction monitoring, you authorize the Rakuten Card Linked Offer Network (“RCLON”) to share your payment card information with Mastercard, Visa and American Express so it knows you enrolled. You authorize Mastercard, Visa and American Express to monitor transactions on your registered card(s) to identify qualifying purchases in order to determine whether you have qualified for or earned an offer linked to your payment card, and for Mastercard, Visa and American Express to share such transaction details with RCLON to enable your card-linked offer(s) and target offers that may be of interest to you. You may opt-out of transaction monitoring on the payment card(s) you have registered by going to the profile section and tapping on the card you want to remove and then tapping the “Remove Card” button.

You authorize the sharing, exchange and use of transaction data described above and herein by and among us and our third party service providers, applicable payment card networks and applicable merchants.

Other Information Collection Technologies.

The technologies we use for automatic information collection may include:

• Cookies. A cookie is a small file placed on your smartphone or browser. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your browser or smartphone. However, if you select this setting you may be unable to access certain parts of our App.

• Web Beacons. Pages of the App may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit Abound, for example, to count users who have visited those pages and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).

Third-party Information Collection

Aggregated and/or non-personal information. We may use and disclose non-personal information we collect with third parties under any of the above circumstances. We may also share it with third parties to develop and deliver targeted advertising on the App and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine non-personal information we collect with additional non-personal information collected from other sources. We also may share aggregated, non-personal information, or personal information in hashed, non-human readable form, with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis or other business purposes. For example, we may engage a data provider who may collect web log data from you (including IP address and information about your browser or operating system), or place or recognize a unique cookie on your browser to enable you to receive customized ads or content. The cookies may reflect de-identified demographic or other data linked to data you voluntarily have submitted to us (such as your email address), that we may share with a data provider solely in hashed, non-human readable form. To opt-out of cookies that may be set by third party data or advertising partners, please go to www.aboutads.info/choices/.

When you use the App or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include: advertisers, ad networks and ad servers, analytics companies, your mobile device manufacturer, your mobile service provider, etc.

These third parties may use tracking technologies to collect information about you. 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, apps and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

These third parties may include but are not limited to:

• Advertisers, ad networks and ad servers.

• Analytics (including marketing analytics) and digital platform management companies.

• Your mobile device manufacturer.

• Your mobile service provider.

• Plaid, Stripe, your card issuer or other financial services provider.

Other Disclosure of Your Information

In addition to the disclosures described above,we may disclose aggregated information that does not constitute personal information about our users without restriction. Further, we may disclose personal information that we collect or you provide:

• To our subsidiaries,affiliates, group companies, holding companies, located within and/ or outside the US, including in India. Some of our affiliates and/or group companies may offer subsidized service and other offerings to Abound members. As disclosed above, we may integrate your personal information with other group companies’ tools and databases. Those group companies may use that integrated information to enhance their marketing effectiveness and deliver targeted ads. Please find the Times Internet’s, one such group company, privacy policy here.

• To our licensed money transfer vendor, Stripe, in the event that you direct us to transfer funds internationally, in which case Stripe’s privacy policy will apply.

• To contractors, service providers, content providers, and other third parties we use to support our business.

• To third parties to market their products or services to you.

• To fulfill the purpose for which you provide it.

• For any other purpose disclosed by us when you provide the information.

• With your consent.

• 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 Abound Inc.'s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about our App users is among the assets transferred.

• To comply with any court order, investigation, law or legal process, including to respond to any government or regulatory request.

• We reserve the right to disclose information if we believe disclosure is necessary or appropriate to protect our rights, property, or safety or that of our customers, users, contractors or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

In order for you to make purchases through the App, service providers like Plaid and Stripe may collect and share financial and payment card account information.This information is shared with Us on a tokenized basis and with your authorization. From some of our service providers and/or business partners, we receive details about specific transactions. You can learn more about Stripe’s privacy policy here, Plaid’s privacy policy here, and their relationship to provide you with money transfer services here.

The App will also allow you to intentionally interact with third parties, such as those whose products or services are made available through the App. Also, our concierge offering is made available through an automated chat feature provided by Haptik, which you can learn more about here. You can read Haptik's privacy policy here. By using the concierge services, you may also correspond with You Man in India (YMII), which will have access to personal information such as your communications and commercial preferences. You can learn more about YMII’s concierge services here, and find its privacy policy here. 

We do not necessarily control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

When applicable we may integrate social media application program interfaces or plug-ins (“Plug-ins”) from social networks, including Facebook, Twitter, Instagram, Tumblr, Pinterest and possibly others, into our App. Plug-ins may transfer information about you to the Plug-in’s respective platform without action by you. This information may include your platform user identification number, which website you are on, and more. Interacting with a Plug-in will transmit information directly to that Plug-in’s social network and that information may be visible by others on that platform. Plug-ins are controlled by the respective platform’s privacy policy, and not by our Privacy Policy.

State Privacy Rights

Notice of Right to Opt-out of Sale and Sharing Personal Information and Targeted Advertising

We may allow certain third parties (such as online advertising services) to collect your personal information via automated technologies via our App. Under certain U.S. state privacy laws, this may constitute a “sale” or “share” of personal information or “targeted advertising”. We may have “sold” or “shared” personal information, which consists of identifiers, commercial information, and internet or other electronic network activity information to data analytics providers, advertisers, and social networks for the business and commercial purposes of online advertising and to provide third-party social network features and functionality. Under certain U.S. state privacy laws, you have the right to opt-out of this disclosure of your information, which may be considered a “sale”, “sharing”, or “targeted advertising” under such laws. On our website, you may opt-out of this “sale”, “sharing”, or “targeted advertising” on our App by setting a through rejecting cookies in our cookie banner. You may also request to opt-out of this “sale”, “sharing”, or “targeted advertising” by e-mailing us at support@joinabound.com.

California Residents

Direct Marketing.California Civil Code Section 1798.83 permits users of the 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 contact us as noted below in Section 14. Contact Information.

CCPA. This Section of our Privacy Policy contains certain required information and informs California residents of certain rights arising under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”).

Categories of Personal Information Collected.We may have collected the following categories of personal information from you within the last twelve (12) months:

• Identifiers, such as name, address, online identifier, internet protocol address, e-mail address, account name, social security number, driver’s license number, passport number, or other similar identifiers;
• Additional personal information described in California Civil Code Section 17980.80, such as telephone number, bank account number, credit card number, debit card number, or any other financial information, employment, and employment history;
• Characteristics of protected classifications under California or federal law; Commercial information, such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming tendencies;
• Internet or other electronic network activity information;
• Geolocation data;
• Audio and visual information, including pictures and videos;
• Professional or employment-related information;
• Education information;
• Inferences drawn from other personal information; and
• Sensitive personal information.

Categories of Sources From Which Personal Information Is Collected. We may have collected personal information from you from the following categories of sources: (1) directly from you via our services or when you visit one of our digital properties; (2) your devices; (3) your family and friends; (4) our affiliates and subsidiaries; (5) our third-party providers; (6) social networks; and (7) other available sources, such as public records.

Business or Commercial Purposes for Collecting Personal Information. The business or commercial purposes for collecting your personal information are set forth in the “How We Use Your Information” Section of this Privacy Policy.

Categories of Personal Information “Sold” or “Shared” to Third Parties and the Business and Commercial Purposes.The categories of personal information that we have “sold” or “shared” to third parties in the last twelve (12) months and the business and commercial purposes for “selling” or “sharing” such personal information are set forth in the “Notice of Right to Opt-out of Sale and Sharing Personal Information and Targeted Advertising” Section of this Privacy Policy. We do not knowingly “sell” or “share” the personal information of individuals under sixteen (16) years of age.

Categories of Personal Information Disclosed to Third Parties. All of the categories of personal information described above may be shared with third parties as set forth in the “Disclosure of Your Information” Section of this Privacy Policy.

Personal Information Retention. We retain the personal information that we collect to achieve the purposes for which the personal information was collected. In certain cases, we may need to retain personal information for purposes required under applicable law, for tax, accounting, or audit purposes, or for other purposes permitted or required under law.

Use and Disclosure of Sensitive Personal Information. We may collect “sensitive” personal information for limited purposes, such as for conducting a background check and for other purposes that an average consumer would reasonably expect. We do not use or disclose your sensitive personal information outside of the following purposes: (1) performing our service or providing goods, (2) detecting security incidents, (3) resisting malicious, deceptive, fraudulent, or illegal actions, (4) ensuring physical safety, (4) for short-term transient use, including certain non-personalized advertising, (5) maintaining or servicing accounts, providing customer service, verifying customer information, or providing similar services, and (6) verifying and maintaining the quality or safety of a service or product or improving, upgrading, or enhancing a service or product. As such, the right to limit our use and disclosure of such sensitive information does not apply.

Your California Privacy Rights. The following rights apply to California residents:

• the right to know what personal information that we have collected about you, including the categories of information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you;
• the right to delete personal information that we have collected from you and the right to correct inaccurate personal information that we maintain about you (each subject to certain exceptions);
• the right to opt-out of the “sale” or “sharing” of your personal information (as described in the “Notice of Right to Opt-out of Sale and Sharing Personal Information and Targeted Advertising” Section of this Privacy Policy); and
• the right to exercise your rights under the CCPA free of discrimination by us including, but not limited to: denying goods or services to you; charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing a different level or quality of goods or services to you; or suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Your California Privacy Rights. For information on how to exercise your rights under the CCPA, please review the “Exercising Your Rights” Section of this Privacy Policy.

Virginia, Colorado, and Texas Residents

The following rights apply to residents of Virginia, Colorado, and Texas:

• The right to confirm whether we are processing your personal information and to access such personal information.
• The right to correct inaccuracies in your personal information, taking into account the nature of the personal information, and our purposes of the processing of such personal information.
• The right to delete personal information provided by or obtained about you.
• The right to obtain a copy of your personal information that you previously provided to us in a portable and if technically feasible, readily useable format that allows you to transmit the data to another controller without hindrance.
• The right to opt out of the processing of your personal information for purposes of: (1) targeted advertising, (2) the “sale” of personal information, or (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. You may opt out of (1) and (2) as described in the “Notice of Right to Opt-out of Sale and Sharing Personal Information and Targeted Advertising” Section of this Privacy Policy. Your right to opt out of (3) does not apply as we engage in such decision-making, if at all, to comply with law or exercise or defend our legal rights.

Exercising Your Rights

You may make privacy requests by contacting us at 2261 Market Street #4468, San Francisco, CA 94114 or support@joinabound.com. However, please see the “Notice of Right to Opt-out of Sale and Sharing Personal Information and Targeted Advertising” Section of this Privacy Policy above for additional information on how to opt-out of “sale”, “sharing”, or “targeted advertising”You may designate an authorized agent to make such requests on your behalf by having your authorized agent make a privacy request as set forth above. Your authorized agent must complete the webform with their information and disclose the fact that they are your “authorized agent” and provide your first and last name in connection with the request. Before we can honor your requests, we may confirm that the requesting party is the consumer whose information is sought or a person authorized to act on that consumer’s behalf. If a requesting party is an online account holder with a password-protected account, it may be necessary for the account to be accessed by the requesting party to confirm the request(s). In addition, depending on the type of request and the categories of information subject to the request, we may request verifying information from the requesting party such as identifiers or commercial information (e.g., service history) already known to or collected by us. If we refuse to take action upon your request, you may appeal such refusal by contacting us after your receipt of the refusal at 2261 Market Street #4468, San Francisco, CA 94114 or support@joinabound.com.

Video Viewership and Sharing

We are committed to protecting the privacy of our users. This notice explains how we handle and share your personally identifiable information (PII) related to your video rentals, purchases, or streaming activity.

What Information Do We Share?

We may share certain video viewership data, including information about the videos you rent, purchase, or watch, as well as details associated with your account, such as your name, email address, and other personally identifiable information.

Who Do We Share This Data With?

We share your video viewership data with the third parties specified in this Privacy Policy, including without limitation:

• Our affiliates and partners, including companies that assist us in providing services to you, such as content recommendations and advertising.
• Third-party advertising networks to help us deliver relevant ads based on your viewing preferences.

Why Do We Share This Data?

We share your video viewership data for the following purposes:

• To enhance your experience by providing personalized content recommendations.
• To deliver targeted advertising that aligns with your preferences.
• For business operations, such as account management, billing, and customer support.

How Can You Control This Sharing?

You have the right to choose whether we share your data with third parties. You may withdraw your consent at any time by contacting us at legal@joinabound.com.

Retention of Data

We will retain your personally identifiable information for no longer than one year after it is no longer needed for the purposes described above. After this time, we will securely destroy the data.

Social Media Integrations and Sharing

Our websites include social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our website or using our app, and they may set a cookie to make sure the feature functions properly. They may also collect information about your interaction with our (and our partners’) websites, including among other data communications and video viewership data.

Social media features and widgets are either hosted by a third party or hosted directly on our website or app. We also maintain presences on social media platforms including Facebook, Twitter, and Instagram. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.

Financial, Payment Card, and Non-public Personal Information

Abound offers certain limited financial and/or payment-related services. While many of these services are not covered by federal banking laws such as Gramm-Leach-Bliley, we provide this notice to the extent that such laws apply.

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

• Social Security number and credit card information
• Payment history and transaction history
• Credit scores and credit history

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons we choose to share; and whether you can limit this sharing.

Reasons We Can Share Your Personal Information	Does Abound Share?	Can You Limit This Sharing?
For our everyday business purposes—such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus	Yes	No
For our marketing purposes—to offer our products and services to you	Yes	No
For joint marketing with other financial companies	Yes	No
For our affiliates’ everyday business purposes—information about your transactions and experiences	Yes	No
For our affiliates’ everyday business purposes—information about your creditworthiness	Yes	Yes
For our affiliates to market to you	Yes	Yes
For nonaffiliates to market to you	Yes	Yes
For nonaffiliates to market to you	Yes

Who is Providing this Notice?

Abound D/B/A TClub, Inc.

What We Do
How does Abound protect my personal information?				To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
How does Abound collect my personal information?				We collect your personal information, for example, when you: Open an account or provide account information Use your connected credit or debit card Give us your contact information We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.
Why can’t I limit all sharing?				Federal law gives you the right to limit only: Sharing for affiliates’ everyday business purposes—information about your creditworthiness Affiliates from using your information to market to you Sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.
What happens when I limit sharing for an account I hold jointly with someone else?				Your choices will apply to you alone unless you tell us otherwise.

Definitions
Affiliates		Companies related by common ownership or control. They can be financial and nonfinancial companies. Our affiliates include companies like Times Internet Limited and others under common control such as WillowTV.
Nonaffiliates		Companies not related by common ownership or control. They can be financial and nonfinancial companies. Nonaffiliates we share with include marketing and analytics companies.
Joint Marketing		A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Our joint marketing partners include companies that provide financial education and companies that present offers for loans and other financial products and services.

Other Important Information
California		If your account has a California billing address, we will not share your personal information except to the extent permitted under California law.
Vermont		If your account has a Vermont billing address, we will automatically treat your account as if you have directed us not to share information about your creditworthiness with our affiliates.

To limit our sharing, please contact us at 2261 Market Street #4468, San Francisco, CA 94114
Email: legal@joinabound.com

For questions about this policy, please contact us at 2261 Market Street #4468, San Francisco, CA 94114
Email: legal@joinabound.com

Jurisdictions and Data Export

As a global company, Abound and its affiliates use and share data globally, and your information may not remain in the United States (and/or your country of residence, if different). Abound’s affiliated companies under common control, as well as its business partners, are located in the United States, India, and other jurisdictions worldwide. By sharing your information with Abound, you agree that it may not remain in the United States and/or your country of residence.

Abound Dollars and Transactional Data Sharing

To support your rewards and the Abound Dollars system, Abound collects, processes, and shares certain financial, transactional, and account information. Among other things, this may include:

• Commercial Information about you, such as records of products, product types, merchants, merchant types, goods or services purchased, obtained, or considered by you, including products, merchants and coupons you searched for, viewed or clicked, items added to cart and abandoned, shopping trips initiated, merchant sites visited from our Services, transaction history related to our Services, purchase confirmation data, accrued Abound Dollars, Times of India rewards, and other loyalty currency
• Internet and other Network Activity, such as your browsing and search history and your interactions with our sites and Services, including:
• URL’s of the pages you visit, including those tracked by our browser extensions and mobile application;
• Date and time stamps associated with such browsing, searches, and clicks; and
• Page by page clicks that you make as you navigate through our Services, including the web page visited before you came to our website.

In addition to the above, we may receive similar or supplementary information from Plaid and/or our other business partners, and we may share such information with our affiliates and business partners to support our business initiatives, including without limitation our rewards and affiliate advertising programs. We may share this information with our affiliates and partner companies to assist in awarding you rewards for your activities and to enable our partners to make or support further rewards earning offers to you.

Our collection and sharing activities in support of Abound Dollars and other programs may include, without limitation, the following:

Disclosure to Other Times Internet Limited Companies

We collaborate closely with our affiliated businesses and companies within the group companies of Times Internet Limited and share your personal information for our internal business administration. Some of our service providers and business partners to whom we disclose personal information, as described above, may include other Times Internet Limited companies. We may also share information in the categories of identifiers, commercial information like product metrics, and internet browsing and activity information with our affiliates for those corporate affiliates to analyze and monitor usage and trends to improve their services and websites and for strategic planning purposes.

Affiliate Partners

When you click a link to a merchant site displayed on our Services, you demonstrate your intent to engage with that business through our Services. This action directs us to share certain information about you (including the link you clicked on our Services and a unique code assigned to track that your shopping originated from our Services) with an affiliate network or the merchant to accurately account for your purchases with the merchant. Our affiliate partners may also use information pertaining to your purchase and activity to measure performance, add it to their user profiles, or combine it with information they collect elsewhere, potentially making it available for use by their other business clients. The opt-out option we provide in the State Privacy Rights section above would result in our requesting that these affiliates not collect or use your information from our Services except as necessary to validate and provide your Abound Dollars.

Furthermore, to the limited extent that we conduct direct marketing to you or personalize the offers you see on our Services based on profile data compiled from your behavior tracked via our Services for the direct benefit of a specific merchant, this marketing or personalization may also be considered "selling," "sharing," or processing for "targeted advertising" purposes of your personal information. In this scenario, the opt-out option provided in the State Privacy Rights section above, would cover this type of targeted marketing and personalization. We may use information we collect about you in combination with information from current and prospective merchant partners to test and analyze how our Services assist merchants and business partners. The information we share with and receive from a merchant or business partner for this analysis may include online shopping identifiers (such as shopping IDs, order IDs), email address, and Commercial Information (such as whether a purchase was made and the corresponding order value). We may use the results from these tests in an aggregated and deidentified manner to improve our Services and to market our Services to merchants and business clients. You may opt out of our disclosure of your information to these specific third parties for this purpose as outlined in the State Privacy Rights section above.

Referral Marketing Partners

To expand your options for signing up for our Services and starting your Abound Dollars shopping from third-party sites where you learn about our Services, we may partner with certain referral marketing business partners to enable that functionality. This may require us to share certain data about you with them. For instance, if you are referred to our Services from a business partner's website, we may provide that partner with information about your sign-up to validate the referral and activate your Services account access from the partner's site. Additionally, we may disclose information about whether you have made a recent purchase with us and whether you have installed our mobile app or browser extension so that the partner can personalize their email and site content for you.

Disclosure to Digital Advertising Providers

To deliver targeted advertising and marketing services, we partner with certain third parties that automatically collect internet activity information about your use of the Services, such as your browsing history, IP address, pages viewed, and links clicked. They use this information to serve you ads for our Services on other sites you visit. Some of these third parties may also use this collected information to draw inferences about you for their own purposes or separately collect personal information about your online activities over time and across different websites (in addition to our Services) to help predict your preferences and display ads to you that are more likely to be of interest to you.

You may have the right to opt-out of our sharing of your information with certain third parties for cross-context behavioral or targeted advertising purposes. To exercise this right, you can opt out via the instructions in the State Privacy Rights section above, to the extent that these laws apply to you. Note that this Privacy Policy covers only our use of data and does not include further use of data by third parties. If you wish to opt-out of interest-based advertising more generally, please visit www.aboutads.info/choices/.

Financial Partners

To offer you additional redemption options for your Abound Dollars and to market credit and/or debit products to you, we may share your collected information, including identifiers, with financial business partners, which may include other group companies of Times Internet Limited. If you indicate that you would like to receive information about credit and/or debit products from our financial partner(s), you are also directing us to share your information with those parties to enable them to provide that information.

We may also disclose personal information about you to our financial partners to facilitate their marketing purposes and, in some instances, for the financial partner to directly send marketing to you. This could be considered "selling," "sharing," or processing for "targeted advertising" under applicable U.S. state privacy laws, and you may opt-out of this disclosure for partner marketing as outlined in State Privacy Rights section above, if these laws apply to you.

Disclosure for Legal Purposes

We may disclose the information we collect, including personal information, to the extent permitted by applicable law: (i) in response to subpoenas or other legal processes, or if, in our good faith opinion, such disclosure is required or permitted by law without a specific disclosure; (ii) at the request of governmental authorities conducting an investigation; (iii) to enforce our terms and conditions or other policies applicable to our Services; and (iv) to protect the rights, property, life, health, security, and safety of Abound or any third party.

Do Not Track

We treat the information of everyone who comes to our App in accordance with this Privacy Notice, regardless of their “Do Not Track” setting.

Email Consent and Opt-out

Your provision of personal information on a registration form in the course of our providing our services to you constitutes your affirmative consent that we may contact you by email to provide you with information and notices relating to the services and various other offerings that may be available and of interest to you in the future. It also means we may email you regarding updates to this Privacy Policy.

We notify you of this at the time you choose to register, and we will provide you the option not to receive further marketing communications from us at the time you register. Mass commercial email sent by us contains a link with instructions on how to remove yourself from our email list. You will also need to opt-out separately from any third-party emails you may receive.

Information Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

If you receive a suspicious email on our behalf, we suggest you do not reply to it and do not open any attachments, click on links contained in the e-mail, or provide any information in response to it. You can report suspected fraud involving us by sending an email to legal@joinabound.com. Please include the word "phishing" in the subject line of your email and provide as much information as possible about the fraudulent activity or message. We do not send emails requesting a user for payment information, username, or passwords. However, we may verify the username, password, etc., provided by you from time to time.

The safety and security of your information (including personal information) also depends on you. For example, where we have given you (or where you have chosen) a password for access to certain parts of the App, you are responsible for keeping this password confidential. You should not share your password with anyone.

Online Account Management

​​If you elected to subscribe to any online services provided via the App, including the ability to access any password-protected areas of the App, you will be required to submit personal information for the purpose of verifying your identity and your authority to manage the account (“Access Credential Information”). This Access Credential Information will be used exclusively by Abound, our agents, suppliers and third-party service providers for internal use and to respond to your service requests.

Sweepstakes, Promotions, Contests & Surveys​

​Through the App, you may wish to participate in certain online polls, surveys, contests, sweepstakes and other promotions that may be offered from time to time by us, a partner, or other entity. Participation in these polls, surveys, contests, sweepstakes and promotions is completely voluntary; you have a choice about whether or not to disclose information required to enter. Information requested may include data such as your name, address, date of birth, phone number, mobile phone number, e-mail address, username, and/or similar information. Through these online polls, surveys and promotions, you may choose to participate in activities such as sharing information with others and sending email invitations. In connection with any online polls, surveys, contests, sweepstakes and other promotions that may be offered from time to time via the App, we use the information you provide to administer such the polls, surveys, contests, sweepstakes and other promotions. Subject to applicable contractual or legal restrictions, we also may use the information to communicate with you, or the other people you select, about our services or products. Any information that you submit to one of our partners or another entity through the App in the course of any poll, survey, contest, sweepstakes, or promotion offered by any third party shall be fully at your own risk, and Abound hereby disclaims all responsibility for any losses, liability, damages, or expenses that may arise from your submission of such information.

Changes to Our Privacy Policy

​We may update our privacy policy from time to time. If we make material changes to how we treat our users' personal information, we will notify you by e-mail to the primary e-mail address specified in your account or an in-App alert the first time you use the App after we make the change. All such updates and amendments are effective immediately upon notice thereof. We expressly reserve the right to make any changes to this privacy policy at any time, without early or prior notice to you. The most recent version of the privacy policy is reflected by the effective date located at the bottom of this privacy policy. The version of this privacy policy posted at https://www.JoinAbound.com/privacy on each respective date you use the App shall be the privacy policy applicable to your access and use of the App on that date. Our electronically or otherwise properly stored copies of this privacy policy shall be deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this privacy policy which were in force on each respective date you used the App.

Contact Information

2261 Market Street #4468, San Francisco, CA 94114

To ask questions or comment about this privacy policy and our privacy practices, contact us at legal@joinabound.com

EXHIBIT C: VPPA CONSENT

Written Consent for Sharing Video Viewership Data

Under the Video Privacy Protection Act (“VPPA”), We are required to obtain your express written consent before sharing your personally identifiable information (“PII”) related to your video rentals, purchases, or viewing activity. Please read the information below and indicate your consent by signing this form.

What Information Are We Sharing?

We will share the following video viewership data:

• Information about the videos you rent, purchase, or view through our service.
• Your name, email address, account information, and other personally identifiable information associated with your video activity.

Who Will Receive This Data?

Your video viewership data will be shared with:

• Our affiliates and business partners who assist us in providing and improving our services, including content recommendation services and advertising partners.
• Advertising networks and other third parties who will use this data to deliver personalized ads and content based on your viewing preferences.

Why Are We Sharing This Data?

We will share your video viewership data for the following purposes:

• To provide you with personalized content and recommendations.
• To deliver targeted advertisements that reflect your interests.
• To improve and optimize our service offerings.

Your Consent: By signing below, you agree that We may share your video viewership data with its affiliates and partners as described above. This consent is effective for two years from the date of signing, unless you withdraw it earlier.

You may withdraw your consent at any time by contacting us at [Insert Contact Information]. Upon receipt of your request, we will promptly cease sharing your data with third parties as required by law.

• I consent to the sharing of my video viewership data with [Company Name]'s affiliates and partners for the purposes described above.