Privacy Policy

This Privacy Policy (“Policy”) explains how Stagwell QR Code Platform LLC, a Delaware limited liability company doing business as Intreego (“Intreego,” “we,” “us,” or “our”), collects, uses, discloses, and retains personal information in connection with: (a) the intreego.ai (https://www.intreego.ai/) website (the “Website”); and (b) the Intreego platform and services, including but not limited to digital menu access, QR code-based promotional offers, receipt-based rebate programs, and SMS/text messaging programs (collectively, the “Services”).

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By accessing the Website or using the Services, you acknowledge that you have read, understood, and agree to the terms of this Policy. If you do not agree, please discontinue use of the Website and Services.

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This Policy does not govern information collected by third-party websites, applications, or services that may be linked from the Website or Services, or information collected by our brand clients or venue partners operating under their own privacy policies.

Intreego operates a three-sided platform connecting: (i) consumers who access digital menus and promotional offers via QR code scan ("Consumers"); (ii) businesses and venues that deploy Intreego-powered digital menus ("Venue Partners"); and (iii) brand clients that sponsor promotions, rebates, and offers surfaced through those menus ("Brand Clients").

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Depending on context, Intreego acts as:

• A data controller with respect to Consumer personal information collected through the Website and Services;

• A data processor or service provider with respect to information processed on behalf of Venue Partners or Brand Clients under separate commercial agreements; and

• An independent administrator with respect to specific promotional programs operated by Intreego on behalf of Brand Clients.

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This Policy applies to Intreego in its capacity as a data controller. Consumers who have questions about how a specific Venue Partner or Brand Client handles their information should contact that party directly.

We collect information in three ways: directly from the Consumer, automatically through your use of the Website and Services, and from third parties.

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3.1 Information You Provide Directly

When you interact with the Website or Services, you may provide us with:

• Contact information, such as your name, email address, and phone number, when submitting a rebate claim, enrolling in our SMS messaging program, requesting a demo, or otherwise contacting us;

• Receipt data, when you upload a photograph or scan of a purchase receipt to participate in a rebate or promotional program, including: product name, Stock Keeping Unit (SKU), and/or Universal Product Code (UPC); quantity purchased and price paid; date and time of purchase; retailer name, store number, and location; transaction or receipt identifier; and payment method type (e.g., cash or card - not your full card number);

• Account credentials, if Intreego makes account registration available, including username and password; and

• Any other information you choose to provide in connection with a promotion, survey, contest, sweepstakes, or customer service inquiry.

We do not collect your full credit or debit card number, Social Security number, government-issued identification number, or full home address from your receipt.

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3.2 Information Collected Automatically

When you visit the Website or use the Services, we automatically collect certain technical and usage information, including:

• Device and browser information, such as IP address, device type, operating system, browser type and version, and unique device identifiers;

• Usage data, such as pages visited, time spent on pages, links clicked, referring URL, and session duration;

• Location data, limited to city and state level derived from your IP address; and

• Cookie and tracking data, as further described in Section 4 below.

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3.3 Receipt Images

When you upload a receipt image, we temporarily retain that image solely to extract the receipt data described in Section 3.1. Receipt images are deleted within sixty (60) days of upload regardless of program status.

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3.4 Information from Third Parties

We may receive information about you from third parties, including:

• Venue Partners, who may provide basic consumer interaction data in connection with in-venue QR code deployments;

• Brand Clients, who may provide Consumer contact lists or eligibility data in connection with specific promotional programs; and

• Third-party service providers, such as fraud detection services, analytics providers, and payment fulfillment platforms (e.g., Tremendous), who may share transaction or verification data with us.

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We use cookies and similar tracking technologies (collectively, "Cookies") on the Website and Services. Cookies are small text files placed on your device that help us recognize you, remember your preferences, and analyze how you use our platform.

We use the following types of Cookies:

• Essential Cookies: Required for the Website and Services to function. These cannot be disabled without disrupting core functionality.

• Analytics Cookies: Help us understand how users interact with the Website and Services, including which pages are visited most frequently and where users encounter errors.

• Functional Cookies: Enable personalization features, such as remembering your preferences or, if applicable, recognizing your account across sessions.

• Marketing/Tracking Cookies: Used to deliver relevant promotional content and measure the effectiveness of promotional campaigns run through the Services.

You may manage Cookie preferences through your browser settings. Disabling certain Cookies may limit the functionality of the Website or Services. For more information, please see our Cookie Policy at [intreego.ai/cookies-policy].

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We use the information we collect for the following purposes:

• To operate and deliver the Services, including verifying qualifying purchases, processing rebate claims, and fulfilling promotional offers;

• To administer Venue Partner digital menu deployments and Brand Client promotional programs;

• To communicate with you, including sending transactional messages (such as rebate confirmations), SMS/text marketing messages if you have opted in, and responses to your inquiries;

• To detect and prevent fraud, abuse, and unauthorized use of the Services;

• To conduct analytics and generate aggregated or de-identified insights about program performance, consumer engagement, and platform usage;

• To provide Brand Clients with program performance data and, where applicable and disclosed, Consumer-level data as further described in Section 6;

• To improve and develop the Website and Services;

• To comply with applicable laws, regulations, and legal process; and

• To enforce our Terms of Use and other applicable agreements.

We do not use your personal information to make automated decisions that produce legal or similarly significant effects on you without human review.

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We do not sell your personal information. We share your information only as described below.

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6.1 With Brand Clients

Intreego's Services are funded in part by Brand Clients who sponsor promotions, rebates, and offers available through the platform. Depending on the specific program you participate in, we may share your information with the sponsoring Brand Client in one of two ways:

• Aggregated or de-identified data: Program performance metrics, consumer engagement statistics, and other insights that cannot reasonably be used to identify you individually. This type of sharing occurs across all programs.

• Identified program data: Where a specific program is structured to include it, and where separate consent is obtained from you at the time of program participation, we may share identified information - such as your email address, receipt data, or purchase history associated with that program - directly with the sponsoring Brand Client. The applicable program materials (e.g., rebate terms and conditions) will disclose when this type of sharing will occur.

You will always be informed, at or before the time of participation in a specific program, whether identified data sharing with a Brand Client will occur. If you do not wish to have your identified information shared with a Brand Client, you may decline to participate in that program.

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6.2 With Venue Partners

We may share aggregated, de-identified data with Venue Partners about consumer engagement with their menus and promotions. We do not share identified Consumer information with Venue Partners except as necessary to fulfill a specific promotional program in which you have enrolled at that venue.

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6.3 With Service Providers

We share information with third-party vendors and service providers that help us operate the Website and Services, including:

• Cloud hosting and infrastructure providers;

• Fraud detection and identity verification services;

• Payment and rebate fulfillment platforms (e.g., Tremendous);

• SMS and mobile messaging platforms;

• Analytics and measurement providers; and

• Customer support tools.

These service providers are contractually required to use your information only to provide services to us and are prohibited from using it for their own commercial purposes.

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6.4 For Legal Compliance and Protection

We may disclose your information where required or permitted by law, including in response to a court order, subpoena, or government request; to protect the rights, property, or safety of Intreego, our users, or others; to detect, investigate, or prevent fraud or illegal activity; or to enforce our agreements.

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6.5 Business Transfers

In the event of a merger, acquisition, financing, reorganization, or sale of all or substantially all of our assets, your information may be transferred as part of that transaction. We will provide notice before your information becomes subject to a materially different privacy policy, and we will give you the opportunity to opt out where required by law.

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6.6 With Your Consent

We may share your information with other third parties where you have provided separate, affirmative consent for us to do so.

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If you opt in to receive SMS or text messages from Intreego (including promotional messages, program updates, cart reminders, or transactional notifications), the following terms apply:

• Consent to receive automated marketing text messages is not a condition of any purchase or participation in any program.

• Message and data rates may apply. Message frequency varies.

• We collect your name, phone number, and email address when you enroll, as well as message metadata and message contents.

• Your mobile number and SMS consent will not be sold to third parties. We may share your number with messaging platform providers solely to enable delivery of messages.

• To opt out of SMS messages at any time, reply STOP to any message from us. You may receive a single confirmation message following your opt-out. Reply HELP for support.

• For assistance, contact us at info@intreego.ai.

SMS-related data is governed by both this Policy and our Messaging Privacy Policy, which is incorporated herein by reference.

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We retain your information for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required by law. Our general retention periods are:

• Receipt images: Deleted within sixty (60) days of upload.

• Program participation data (receipt data, purchase data): Retained for twelve (12) months following the close of the applicable program, then deleted or anonymized.

• Technical and device data: Retained for twelve (12) months for fraud detection and analytics, then deleted.

• Rebate and financial records: Retained for five (5) years, or as required by applicable tax and financial recordkeeping law.

• SMS opt-in records: Retained for the duration of your enrollment in the messaging program, plus an additional period as required for legal compliance.

• Account data (if applicable): Retained for the duration of your account, plus a reasonable period following account closure.

Following the applicable retention period, we will delete or anonymize your information. Where deletion is not immediately practicable (for example, because data is stored in backup archives), we will securely isolate your information from further processing and delete it as soon as practicable.

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We implement industry-standard technical, administrative, and physical safeguards to protect your information from unauthorized access, use, disclosure, alteration, or destruction. These measures include encryption of data in transit and at rest, access controls limiting employee and contractor access to personal information on a need-to-know basis, and contractual security requirements imposed on our service providers.

No method of electronic transmission or storage is completely secure. We cannot guarantee the absolute security of your information. If you have reason to believe your interaction with us has been compromised, please contact us immediately at the information provided in Section 12.

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Depending on your state of residence, you may have certain rights with respect to your personal information. We honor these rights for all U.S. residents, regardless of state, to the extent practicable

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10.1 Rights Available to You

• Right to Know/Access: You may request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, our business or commercial purpose for collecting it, and the categories of third parties with whom we have shared it.

• Right to Delete: You may request that we delete the personal information we have collected about you, subject to exceptions permitted by applicable law (for example, information we are required to retain for legal compliance or fraud prevention).

• Right to Correct: You may request that we correct inaccurate personal information we maintain about you.

• Right to Opt Out of Sale or Sharing for Targeted Advertising: We do not sell your personal information as that term is defined under applicable law. Where we share identified Consumer data with Brand Clients as described in Section 6.1, such sharing is program-specific and consent-based. If you have previously consented and wish to withdraw consent to identified data sharing, contact us at the information in Section 12.

• Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights. Note that because receipt submission is the only method of participating in certain programs, withdrawal of consent to data collection may affect your ability to receive the associated rebate or offer.

• Right to Limit Use of Sensitive Personal Information: To the extent we collect sensitive personal information as defined under applicable law, you may request that we limit our use to purposes necessary to perform the Services.

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10.2 How to Submit a Request

To exercise any of the rights above, contact us at info@intreego.ai or by mail at the address in Section 12. We will respond to verifiable consumer requests within 45 days of receipt. We may extend this period by an additional 45 days where reasonably necessary and will notify you in advance if an extension is required. We will not require you to create an account to submit a request, and we will not charge a fee for reasonable requests.

To verify your identity, we may ask you to confirm the email address, phone number, or other information associated with your account or program participation.

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10.3 Authorized Agents

You may designate an authorized agent to submit a privacy rights request on your behalf. To do so, please provide written authorization or a power of attorney and contact us at the information in Section 12. We may still require you to verify your own identity directly.

The Website and Services are not directed to children under the age of 13. We do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13 without verifiable parental consent, we will delete that information promptly.

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Certain programs available through the Services are intended only for adults of legal drinking age (21 years of age or older) and carry additional age verification requirements.

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Stagwell QR Code Platform LLC, d/b/a Intreego

Attn: Privacy Officer

One World Trade Center, 285 Fulton Street

New York, NY 10007

Email: info@intreego.ai

We may update this Policy from time to time to reflect changes in our practices, the Services, or applicable law. If we make material changes, we will post the updated Policy on this page with a new effective date and provide notice as required by applicable law. Where required, we will obtain your consent before applying material changes to previously collected information.

Your continued use of the Website or Services following the posting of changes constitutes your acceptance of the revised Policy. We encourage you to review this Policy periodically.

This Section supplements the rest of this Policy and applies solely to California residents. It is provided pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, "CCPA").

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14.1 Categories of Personal Information Collected

In the preceding twelve (12) months, we have collected the following categories of personal information as defined under CCPA Section 1798.140:

• Identifiers (e.g., name, email address, phone number, IP address, unique device identifiers)

• Personal information listed in Cal. Civ. Code § 1798.80(e) (e.g., name, email address)

• Commercial information (e.g., purchase history, receipt data, products purchased)

• Internet or other electronic network activity (e.g., browsing behavior, session data, interaction with the Website and Services)

• Geolocation data (city/state level, derived from IP address)

• Inferences drawn from other personal information to create a consumer profile (e.g., purchase preferences, offer engagement)

• Sensitive personal information: None currently collected beyond what is disclosed above.

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14.2 Categories of Sources

We collect personal information directly from you, automatically through your use of the Website and Services, and from Venue Partners, Brand Clients, and third-party service providers as described in Section 3.

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14.3 Business and Commercial Purposes

We collect and use personal information for the business and commercial purposes described in Section 5.

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14.4 Categories of Third Parties with Whom We Disclose Personal Information

• Brand Clients (aggregated/de-identified data for all programs; identified data where separately consented)

• Venue Partners (aggregated/de-identified data)

• Service providers (as described in Section 6.3)

• Law enforcement or government entities (where required by law)

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14.5 Sale and Sharing of Personal Information

We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising purposes, except as disclosed in Section 6.1 with respect to Brand Client data sharing on a consent-based basis.

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14.6 California Consumer Rights

In addition to the rights described in Section 10, California residents have the right to request information about our data practices for the preceding twelve (12) months. To submit a CCPA request, contact us at info@intreego.ai. We will respond within 45 days and will not discriminate against you for exercising your rights.

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