PRIVACY POLICY


Self Point USA INC. (the "Company", "us", "our" or "we") provides vicariously through its designated software, website (the "Website") and application (the "Application") web-based services in the form of a merchant network platform for the purpose of facilitating communications between merchant members (the "Offerers") and users interested in receiving information and engaging with the Offerers for the purpose of purchasing their respective merchandise (the "Offerees"), as well as to allow certain third parties (the "Third Parties") to provide and exchange self-generated content and Offerers related content (together, the "Third Parties' Content") which is directly or indirectly related to the said merchandise (together, the "Service"; the Service users, including the Offerers, Offerees and Third Parties shall be referred to as the "Users", "you" or "your").


Your privacy is important to us. We highly value and respect the privacy of the personal information we obtain from you by using our Website, Application and Services and we have created this privacy policy (the “Privacy Policy”) to inform you about how we collect, use and share your information, and our privacy practices in general.


By accessing and using the Website, Application and/or Services, you agree to be bound by this Privacy Policy. If you do not agree to any of the provisions as set hereunder in this Privacy Policy, you have no right to use the Website, Application or Services. This Privacy Policy should be read together with the Terms of Service and together they constitute the entire agreement between you and us. This Privacy Policy may be updated from time to time and therefore we ask you to check back periodically to read the most updated Privacy Policy. Your continued use of the Website, Application and/or Services shall be deemed to be your continued acceptance of the terms of this Privacy Policy, as amended.


Information That We Collect


Personal Information. During your access and use of the Website, Application and/or Services, we may collect, save or otherwise keep in our possession certain information that identifies you personally, such as your name, serial account number, physical address, phone number, email address, photo, shopping history and other such information (“Personal Information”). We may collect such information through your access and use of the Website, Application and/or Services as well as credentials you provide us to link the Website, Application or Services with third parties including third parties through which you may access our Website, Application and/or Services, or from information that is entered into our system by any other User uploading, sharing or otherwise making such information available.


Non-Personal Information. We may also collect, save or otherwise keep in our possession information that does not identify you personally, such as your history of use of the Website, Application and/or Services. We refer to information that does not identify you personally as “Non-Personal Information”.


Additional Information. When accessing or using the Website, Application and/or Services, we may also collect, save or otherwise keep in our possession certain information that your browser sends to every Internet website you visit, such as your IP address, your browser information (including browser type, capabilities and language), your operating system, the date and time you accessed the website, certain location-based data, and the website from which you linked to the Website, Application and/or Services. When you choose to log into the Website or the Application via your Facebook account, you explicitly provide us with your approval to receive information about your contacts.

By accessing and using the Website, Application and/or Services, you voluntary agree to provide us with any information, and to collect, save or otherwise keep in our possession such information (including Personal Information). If you refuse to provide us such information you may not have access to all functionality of the Website, Application and/or Services.


Please note that while we make reasonable efforts to secure all information and User Accounts, it is impossible to have the information and User Accounts completely secure. As such, we cannot accept any liability for the disclosure of Personal Information as a result of unauthorized access to our system, Website, Application or Accounts.


Our Use of Information


We will not sell, trade or rent your Personal Information to unaffiliated third parties unless you explicitly provide us with permission to do so. By using the Website or Application you explicitly provide us with your approval to share your information, including but not limited to Personal Information, with third party entities and/or individuals. This may for instance be the case, where you enter loyalty card information from a specific retailer in order to benefit from and update such loyalty card account, where you invite or are invited to share a shopping cart with or by other Users, or where you invite or are invited to use the Website or Application. We use Personal Information for internal purposes only, to improve our Website, Application or Services and to better tailor them to meet your needs. Among other things, birth dates will be used for alcohol orders. We use your Personal Information to provide customer service and contact you about your use of the Services.


By analyzing the information we are provided or we collect, save or otherwise keep in our possession, including all Personal Information, we may compile certain statistical information, such as without limitation anonymous information about how Users use the Website, Application and/or Services (the “Statistical Information”). Statistical Information helps us understand trends and User needs so that new products and services can be considered and so existing products and services can be tailored to User desires. Statistical Information is anonymous and will not be linked to any Personal Information for provision to third parties. For instance, we use Google Analytics in a non-personal way for analyzing Users' interactions with various parts and features of the Website and the Application (you can learn more about the information collected by Google by clicking on the following link http://www.google.com/analytics/standard/features/).We may share such Statistical Information with our affiliates, without restriction, on commercial terms that we can determine in our sole discretion.


Offerers and other Affiliated Parties. You acknowledge and agree that in order for the Services to be performed, we may send Personal Information to the Offerers from whom you have purchased products and such Offerers may share such information with their affiliated parties and/or other third party service providers (packaging and delivery services, etc.) all in order to fulfill purchase orders.


Legal Disclosures. In the event we are required to disclose Personal Information or Non-Personal Information, or any other related information pursuant to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws or regulations, we will make such disclosure. It is our policy to cooperate with law enforcement agencies, and we will fully cooperate with any ongoing law enforcement investigation, including to the extent we are required to disclose Personal Information.


Change of Ownership. In the event the ownership of all or a part of our business were to change, your Personal Information and other related information pertinent to the business’ operations would likely be transferred to, or licensed for use by, the new owner.


To Protect Us or You. We may disclose your Personal Information and other related information in the event we reasonably believe such disclosure is necessary to protect the Website, Application or Services, our rights or property, or the rights of any third party. We may disclose your Personal

Information and other related information, when we have reason to believe that disclosing such information is necessary to identify, contact or bring legal action against someone who may be violating this Privacy Policy or may be causing injury to or interference with (either intentionally or unintentionally), our rights or property, other Users, or anyone else that could be harmed by such activities. You thus authorize us to disclose any information about you to law enforcement or other government officials if we, in our sole and absolute discretion, believe that such disclosure is necessary or appropriate.


Third Party Service Providers. We may use third-party service providers to perform certain services on our behalf. We may provide your Personal Information to these third-party service providers. These third-party service providers will be contractually restricted from using Personal Information for any other purpose and required to comply with all applicable laws with respect to your Personal Information. Such third party service providers may be located in jurisdictions that are not your home jurisdiction and, as such, may be subject to statutory or regulatory obligations that are not as protective as the applicable laws or regulations in your home jurisdiction.


Registration through Third Party Accounts. The Website, Application and Services are accessible and usable through certain third party accounts, such as Facebook and Gmail (each such account, a “Third Party Account”). In order to access and use the Website, Application or Services you must link the Website or the Application to your Third Party Account, by either: (i) providing your Third Party Account login information to the Company through the Website or the Application; or (ii) allowing the Company to access your Third Party Account, as is permitted under the applicable terms and conditions that govern your use of each such Third Party Account. You represent that you are entitled to disclose your Third Party Account login information to the Company and/or grant the Company access to your Third Party Account (including for use for the purposes described in these Terms), without breach by you of any of the terms and conditions that govern your use of the applicable Third Party Account and without obligating the Company to pay any fees or making the Company subject to any usage limitations imposed by such Third Party Account operator, developer or any other third party service provider. By registering through a Third Party Account you represent and warrant that such account is yours and you have all right to provide us with the information in such account. By granting us access to your Third Party Account, you acknowledge that the Company may, as applicable, access, make available and store any public information available in your Third Party Account, including but not limited to friends and contacts lists, profile picture, date of birth, information shared, uploaded, posted or otherwise made available by the Users in any means on such Third Party Accounts or any other public information.


You agree that you will supply accurate and complete information to us when accessing or using the Website, Application through your Third Party Account, and that you will update such information promptly after it changes. You shall have all responsibility for any inaccuracies in any information you provide to us, or in respect of your failure to keep such information up-to-date. The Company reserves the right to refuse to allow anyone wishing to access or use the Website, Application or Services to do so through his Third Party Account for any reason at its sole discretion. You may not provide false information during your access and use of the Website and/or Application. You shall not share your Third Party Account for the purposes hereof with any third party, nor let any third party access to your Third Party Account for purposes of accessing or using the Website, Application or Services, and are responsible for maintaining the confidentiality of the login information as described above. You are fully and solely responsible for the security of your mobile device and all activity on and through your Third Party Account, even if such activities were not committed by you. The Company will not be liable for any losses or damages incurred by unauthorized use of your Third Party Account for the purposes hereof, either to you or to any other User or third party, and you agree to indemnify and hold the Company harmless for any improper or illegal use of your Third Party Account, including any Content or Travel Information shared or otherwise made available. Without derogating from the foregoing, we may terminate your use of the Website, Application and/or Services if you let any third

party use your Third Party Account for accessing or using the Application or Services inappropriately or if you or anyone accessing or using the Website, Application or Services through the Third Party Account violates this Privacy Policy or the Terms and Conditions.


Other Websites, Services and Communities


Please be aware that when you are using the Website, Application and/or Services, you could be directed via hyperlinks or other means to third-party websites, services and online communities that are not affiliated with us. Our Privacy Policy only addresses the use and disclosure of information we collect from you. Different rules or policies may apply to the use or disclosure of the information which you disclose to third parties. These third-party websites, services and online communities may send their own cookies to visitors to collect data or solicit your Personal Information. The privacy policies of these websites, services and online communities may be very different from this Privacy Policy. We are not responsible for the privacy practices of these other websites, services and online communities and cannot guarantee the security of any of your Personal Information collected, used or shared there.


Cookies


A cookie is a small piece of text that is sent to a visitor's browser. The browser provides this piece of text to the device of the originating visitor when this visitor returns. A “persistent” cookie may be used to help save your settings and customizations across visits. The cookies allow us to recognize your browser or mobile device and tell us how and when pages in the Website are visited and by how many people. We may also record the referring page that linked you to us; the page you visit after our Website; the ads you see; the ads you click on; other information about the type of Web browser, computer, platform, related software and settings you are using; any search terms you have entered on this Web Website or a referral site; and other usage activity and data logged by our servers. Our advertising partners may also transmit cookies to your computer, when you click on ads that appear on our site. This Privacy Policy does not cover the use of cookies by any advertisers. When we collect usage information (such as the numbers and frequency of visitors to the Website), we only use this data in aggregate form, and not in a manner that would identify you personally. Most web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. Also, you are free to delete any existing cookies at any time. Please note that some features of the Website may not function properly when cookies are disabled or removed.


Promotional Materials and Newsletters


The User gives his express consent to the Company to use any of his registration details for the purpose of providing the User with promotional materials and newsletters (the "Promotional Materials and Newsletters") by any means available, including via email, text and SMS messages, fax, post, automated dialing services or any other means, all in accordance with the Company's sole discretion as shall be from time to time, and to receive such Promotional Materials and Newsletters.

The User further acknowledges that the Promotional Materials and Newsletters may include the advertisement of third parties, and he expressly consents to the receipt of such advertisements as part of the Promotional Materials and Newsletters.

The User may contact the Company at any time by sending a request via e-mail to support@self-point.com notifying the Company of his refusal to further receive the Promotional Materials and Newsletters.


User Communications

Exchanges or communications between Users via the Website, Application or Services may be scanned, analyzed and reviewed by us for the purpose of fraud prevention, investigation, risk assessment, research & development of the Website, Application and Services and regulatory compliance. While this will be performed mainly by automated methods, manual review may be necessary under certain circumstances.

By using the Website, Application or Services, you acknowledge that we may review, scan, analyze, and store your communications, whether performed by automated methods or manually.


Policy Regarding Children


You must be at least the age of majority in your jurisdiction or older to use the Website, Application or Services, or otherwise to duly receive the permission of your parents or legal guardian to use the Website, Application and Services; we do not knowingly collect information from children under the age of legal capacity. If you are under the age of majority, please do not attempt to send any information about yourself to us, including your name, address, telephone number, or email address. No one under the age of majority may provide any Personal Information to us or on the Website, Application or Services, unless otherwise permitted by his parents or legal guardian. If we become aware that we have collected Personal Information from a child under the age of majority in contrary to these terms herein, we will use commercially reasonable efforts to delete such information from our database.

Questions


You may direct questions concerning this Privacy Policy by email to support@self-point.com by adding the word ‘privacy’ in the subject line.