Policy Version Date: February 2019

EarlyAccess Privacy Policy

EarlyAccess, Inc. (“EarlyAccess,” “us,” or “we”) operates an online platform and provides certain services through the website located at https://hipalerts.rontomich.com/ and various other websites operated by EarlyAccess where this Privacy Policy is displayed (each, a “Site”), as well as through various applications, widgets and other interfaces (collectively, the “Applications” and together with the Sites, the “Platform”). This privacy policy (this “Policy”) discloses the ways in which we collect, use and disclose information from the users of the Platform and the services offered through the Platform (the “Services”). When you use the Services, you signify that you have read, understand, and agree to the terms of our current Privacy Policy, and to the collection, use and dissemination of your personal information and automatically-collected information as described in this Privacy Policy.

If you have questions or concerns regarding this Policy, you should contact us by e-mail at support@earlyaccess.com.

Ownership and Use

EarlyAccess may collect, share, transfer, sell or use data and information collected through the Platform and Services as stated in this Policy. IF YOU OBJECT TO THE TERMS OF THIS POLICY, YOU SHOULD NOT USE OR ACCESS THE PLATFORM OR SERVICES.

EarlyAccess’ Customers and Other Third Parties.

The web sites of certain of our customers, advertisers or affiliates and other third-parties may be accessible through the Platform and Services. You may be asked to provide personally identifiable information (or other information) to these third parties. These third parties maintain their own data privacy policies and practices. WE ARE NOT RESPONSIBLE FOR THE POLICIES OR PRACTICES OF THESE THIRD PARTIES. YOU SHOULD REVIEW THE APPLICABLE PRIVACY POLICIES OF THESE THIRD PARTIES BEFORE PROVIDING THEM WITH ANY INFORMATION.

Registered Users.

Registration is not mandatory to access the public areas of the Platform. Registration is, however, required for access to certain areas of the Platform and the use of certain of the Services provided through those areas of the Platform. The areas of the Platform requiring registration are noted on the Platform.

Users registering to receive an account on the Platform will be assigned a username and will select a password for purposes of accessing their accounts and the portions of the Platform available to account holders. We will send new registrants of certain parts of the Platform or Services a welcoming email to verify email address and account. When accessing the portions of the Platform available to account holders, and using the Services provided through those areas of the Platform, users may be required to provide their username and password.

EarlyAccess is not responsible for any loss or misuse of your username and password. YOU SHOULD NOT SHARE YOUR USERNAME OR PASSWORD WITH OTHERS.

Personally Identifiable Information.

Personally identifiable information includes information by which you may be personally identified, either directly or in combination with other information. We only collect and share personally identifiable information regarding users of the Platform or Services as described in this Policy. Except as noted in this Policy, personally identifiable information collected on the Platform or through the Services is NOT shared with third parties without your consent.

We may automatically collect personally identifiable information from you when you use or access the Platform or Services. We may also collect personally identifiable information from you through a number of voluntary sources through the Platform or Services, such as responses, registrations, surveys, reviews, comments, emails, postings, messages or other submissions and communications that you provide to us. The personally identifiable information we may collect from you will include, by way of example:

ï E-mail address

ï Contact information (including, phone number and billing address);

ï Financial information, such as account or credit card numbers (“Financial Information”);

ï User-specific information on areas of the Platform accessed and the Services used;

ï Domain name and Internet Protocol (IP) address;

ï Username and password information for the Platform or Services; and

ï Other information you provide to us, such as information provided through postings, responses, registrations, surveys, reviews, comments, emails, messages or other submissions and communications that you provide to us.

YOU SHOULD NOT PROVIDE EARLYACCESS WITH ANY PERSONALLY IDENTIFIABLE INFORMATION (OR SUBMIT OR POST ANY PERSONALLY IDENTIFIABLE INFORMATION TO THE PLATFORM OR IN RESPONSE TO ANY COMMUNICATION) UNLESS YOU WOULD LIKE US TO USE THAT INFORMATION IN ACCORDANCE WITH THIS POLICY. LIKEWISE, YOU SHOULD NOT SUBMIT OR POST ANY INFORMATION TO THE PORTIONS OF THE PLATFORM OR SERVICES ACCESSIBLE TO OTHER USERS UNLESS YOU WANT THAT INFORMATION TO BE ACCESSIBLE TO THOSE OTHER USERS OF THE PLATFORM OR SERVICES.

The personally identifiable information that we collect from users of the Platform or Services (both registered and unregistered) may be used for a variety of purposes, including by way of example:

ï Providing the Services;

ï Notifying users of the Platform or Services about updates to and activities on the Platform or Services and about goods and services that we feel may be of interest to you;

ï Improving the content of the Platform or Services;

ï Analyzing data and patterns regarding usage of the Platform or Services;

ï Allowing users to submit comments and inquiries to our helpdesk;

ï Contacting users of the Platform or Services for marketing purposes; and

ï Contacting users of the Platform or Services for information verification purposes.

We may also share certain personally identifiable information we collect through the Platform or Services with third party companies so that they may offer products and services to users of our Platform or Services that we believe will be of interest to those users.

We do not permanently store the Financial Information that we collect. The Financial Information is passed through to our third-party payment processor to complete financial transactions submitted through the Platform or Services.

Non-Personally Identifiable Information.

Where possible, our servers automatically recognize and collect certain non-personally identifiable information regarding visitors to the Platform and users of the Services, including by way of example,

1. Your mobile device and network identifiers, such as MAC or IP addresses;

2. Your mobile device’s unique device ID;

3. Geo-location Data: parts of our Platform do not work without geo-location data. We use both precise geo-location data and very non-precise general market location (i.e. a major metropolitan area, like Sayulita, Mexico) in different ways to provide an optimal Platform experience while respecting your privacy.

4. We record your general location whenever you use the parts of the Platform.

5. We use your precise geo-location every time you use parts of the Platform (i.e. a GroovyPack app) to identify the market you are in and display merchants near you.

6. We only record your precise geo-location at these limited times:

ï When you set up an account

ï When you redeem a coupon

ï When you go into offline mode

ï When you cross a geofence

There is an optional setting in parts of the Platform (i.e. a GroovyPack app) that will send you a push notification when you are near a merchant or when you cross a geofence. For this service to work we use your precise geo-location in the background at all times and send you a push notification when our system has determined you are likely nearby a merchant or have crossed into a geofence.

We collect and aggregate this geo-location data to provide only the de-identified and aggregated coupon redemption data to merchants and partners for their analysis so they can, for example, determine how often a coupon is redeemed at a given merchant location. We do NOT provide your specific geo-location data nor your identity to any third party; rather, we only provide the aggregated redemption data to our merchants and partners.

The following data is de-identified and aggregated to provide data for both analysis and reporting to our merchants and partners:

1. Your coupon history, including purchases and redemptions;

2. Your content interests, including which media posts were viewed and how often;

3. Domain server;

4. Type of mobile device;

5. Type of operating system your mobile device uses;

6. Date and time you access the Platform and Services and date and time you redeem specific coupons; and

7. Other information regarding the system and connection of each visitor or user.

We also collect information about how visitors access and use the Platform and Services, including by way of example what pages of the Platform are viewed and what portions of the Services are used. We may collect this information directly, or through a third party service provider acting on our behalf to operate the portions of the Platform or provide portions of the Services (see “Consent to the Use of Third Party Providers” section below for information on our use of third party providers). This information allows us to improve the content of the Platform and Services, facilitate research and analysis of the Platform and Services, and develop and refine our Services. Sometimes, we utilize the services of a third party to help us understand this information better, although the information that is disclosed to these entities remains in non-personally identifiable form.

Disclosure as Required by Law.

Though we make every reasonable effort to preserve user privacy, we may need to disclose personally identifiable information of certain users of the Platform or Services when we have a reasonable and good-faith belief that the disclosure is necessary to enforce the terms of use for the Platform, comply with a judicial proceeding, court order or other legal process, or to otherwise enforce or protect our rights under applicable law, including, without limitation, our intellectual property rights. In this situation we will use reasonable efforts to provide notice of this disclosure to all affected users, to the extent reasonably possible under the circumstances.

Enhancement of Personal Information.

We may combine and enhance our user database information with data and information we collect independently from the Platform or Services and third party data and information to better target our advertising and provide pertinent offers in which we think our users would be interested. We may also use certain summary demographics internally and as products provided to third parties.

Service Announcements.

On occasion it is necessary to send out service related announcements. For instance, if the Platform or any of the Services are temporarily suspended for maintenance we might send users an email. Generally, users may not opt-out of these communications, though they can deactivate their account. These communications are not promotional in nature.

Special Offers and Updates.

Established members may occasionally receive information on products, services and special deals, and periodic communications. Out of respect for the privacy of our users we present the option to not receive these types of communications. Please see the “Choice and Opt-out” section below.

Your California Privacy Rights.

California law provides that California residents have a right to request that businesses tell them how their personally identifiable information has been shared with third parties for those third parties’ direct marketing purposes. However, there is an exception to this requirement for businesses that have adopted and disclosed, in their privacy policy, a policy of not disclosing a person’s personally identifiable information to third parties for those third parties’ direct marketing purposes if that person has exercised an option to opt-out of the disclosure of their personally identifiable information to third parties for such purposes.

We have adopted a policy of allowing you to opt-out of the disclosure of your personally identifiable information to third parties for their direct marketing purposes and thus falls within this exception. Instructions for opting out can be found in the section below entitled “Choice and Opt-Out.”

Choice and Opt-out.

We provide you with a choice whether to receive certain emails and other communications through the Platform and Services.

We provide you the opportunity to ‘opt-out’ of having your personally identifiable information used for certain purposes. You may opt-out of receiving email or telephone calls from us or having your email address shared with third parties. In addition, you may opt-out of having your personally identifiable information shared with third parties for the third parties’ direct marketing purposes.

All opt-out requests can be made by contacting us through email or submitting a support inquiry via our HelpDesk. Our contact information is found in the section below entitled “Contact Information.”

Children.

The Platform and Services are not directed to children under 13 years of age. We do not knowingly solicit or collect personal information from children under 13 years of age.

Customer Service.

We provide customer service as set forth in our terms of use for the Platform and Services. We communicate with users to provide these services in accordance with our terms of use.

Cookies and Web Beacons.

“Cookies” include commonly used pieces of information in the form of small files that are placed on an individual’s computer hard drive to enable the individual to more easily communicate and interact with the Platform and Services. We may use cookies on a Site or in communications sent through the Services for various purposes, including by way of example:

ï Saving user preferences;

ï Recording session information;

ï Saving certain information about users of the Platform and others who visit the Platform; and

ï Facilitating and enhancing interaction with the Platform.

We do not use cookies to retrieve information from a computer that is unrelated to EarlyAccess or the Platform or Services.

A cookie does not collect or keep your name or other personally identifying information; however, we may link the information obtained through cookies to other personally identifiable information to give us a better understanding of your preferences, so that we can provide a more meaningful experience to you on our Platform and through our Services.

“Web beacons” (also known as “single–pixel” or “clear” GIFs) include electronic images imbedded in the Platform or in communications sent through the Services which are invisible to users. Web beacons collect information, such as identifiers, time and date of access, and descriptions of the pages or communications in which the web beacons are imbedded. The Platform and communications sent through the Services may include web beacons. We may use the web beacons on the Platform and communications sent through the Services for various purposes, including by way of example to track users who have visited our Platform or otherwise accessed communications sent through the Services.

We may also use a third party provider to analyze data and patterns regarding usage of the Platform and the communications sent through Services. This third party provider may use cookies or web beacons to collect such information.

Most browsers will allow you to erase cookies from your computer hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. You may also be able to refuse certain web beacons by adjusting the settings on your browser or email software. Please refer to your browser or email software instructions or help screen to learn more about these functions.

Access, Review, Update.

You may review the following information that we maintain: username, password, historical transaction information, contact information, material uploaded and comments posted to the Platform. You may update your username, password, contact information, material uploaded and comments posted to the Platform, delete the app, or delete your account with EarlyAccess by contacting us through email or submitting a support inquiry via our HelpDesk. Our contact information is found in the section below entitled “Contact Information.”

Consent to the Use of Third Party Providers.

In addition to the specific third parties noted in this Policy, we may also contract with other third parties to operate various portions of the Platform or provide various portions of the Services on an outsourced basis. For example, we may contract with a web site hosting provider to host all or a portion of the Platform or Services or provide users with remote access to our HelpDesk. We may also use a third party payment processor to facilitate payments for the Platform or Services. By visiting the Platform or using the Services, you consent to our use of these third party providers to collect both personal and non-personal information from you as part of the services that these third parties provide to us. You also consent to our providing your personal and non-personal information to these third party providers for the purpose of enabling the providers to provide their services to us. In each case, your personal and non-personal information will be used by our third party service providers on our behalf under the terms of this Policy, and you consent to the maintenance, processing, and use of your personal and non-personal information by us and these third party providers as described in this Policy.

Notification of Changes.

We may change this Policy at any time. If we change this Policy, we will notify users through a posting of the change to the Platform or by way of an email. Changes to this Policy will be effective upon the earlier of the date 30 days following the date we provide notification of the changes or the date on which you agree to the changes on the Platform or through the Services. In any case, even if you have not been asked to agree to a change to this Policy, your continued use of the Platform or Services after 30 days following notification of that change will constitute your acceptance of the change. Unless we seek and receive your consent, we will use all information in accordance with the version of this Policy under which the information was last collected. Users may prevent their information from being used for purposes other than those for which it was originally collected by emailing us at support@earlyaccess.com.

Security.

We will use at least industry standard security measures on the Platform to protect the loss, misuse and alteration of the information under our control. While there is no such thing as “perfect security” on the Internet, we will take all reasonable steps to insure the safety of your personal information. For example, our policy is that only those individuals who need your personally identifiable information to perform a specific job are granted access to that personally identifiable information. Likewise, all employees and contractors are kept up-to-date on our security and privacy practices. Finally, the servers that we store personally identifiable information on are kept in a secure environment.

Contact Information.

All inquiries concerning this Policy and the Platform or Services in general may be made by contacting us at:

EarlyAccess, Inc.
13918 E. Mississippi Ave, #64541
Aurora, CO 80012
USA
support@earlyaccess.com

Transfer of Information.

If we elect, in our reasonable discretion, to transfer ownership or control of the Platform or Services to a third party, whether or not in the context of an acquisition, merger, or reorganization, you consent to our transfer of your personally identifiable information and non-personally identifiable information to that third party, provided that all use of your information by that third party remains subject to the terms of this Policy.

Thank you for visiting the Platform and using the Services.