INMAR INTELLIGENCE PRIVACY POLICY

WHOSE PRIVACY PRACTICES ARE DESCRIBED BY THIS PRIVACY POLICY?

This Privacy Policy describes the policies and practices of Inmar, Inc. and its U.S. wholly owned subsidiaries and affiliates BrightBridge, LLC; Digitus Solutions LLC; Inmar Analytics, Inc.; Inmar Brand Solutions, Inc.; Inmar Clearing, Inc.; Inmar Intelligence Automotive, LLC; Inmar Post-Purchase Solutions, LLC; Inmar Rx Solutions, Inc.; Inmar - RXT, LLC; Inmar Services, LLC; Inmar Solutions, LLC; Inmar Supply Chain Solutions, LLC; Inmar – YouTech, LLC; and Qualanex, LLC (collectively and individually referred to as “Inmar,” “we,” “our,” or “us”) regarding our collection of personal information directly from consumers and our use and disclosure of that information.

This Privacy Policy also addresses our practices where we receive personal information from businesses, government entities, and other entities to which we provide our services (“Business Customers”) or otherwise process personal information on behalf of our Business Customers in connection with services we provide to them. The manner in which we collect, use, and disclose personal information on behalf of our Business Customers is subject to our Business Customers’ directions, but will generally align with the descriptions provided below.

This Privacy Policy is subject to any agreements or terms of service that govern your use of the services. This Privacy Policy applies regardless of the means used to access or provide information through the services. For more information about how users with disabilities can access this Privacy Policy in an alternative format, please see our Accessibility Statement.

WHAT BUSINESS ACTIVITIES DOES THIS POLICY COVER?

This Privacy Policy addresses our different lines of business:

PROMOTIONAL SERVICES. We assist businesses who are seeking to promote the sale of goods and services and the consumers for those goods and services by managing different promotional offerings such as marketing, rebates, coupons, and loyalty programs. We also operate websites and provide mobile applications that enable consumers to choose and redeem discount offers for goods and services that are of interest to them.
SUPPLY CHAIN SERVICES. We assist businesses and consumers with supply chain needs related to reverse logistics including facilitating better management of consumer returns processing, managing product recalls, enabling the liquidation of returns or overstocked inventory, and conducting supply chain studies to generate data analytics that facilitate better supply chain management.
HEALTHCARE SERVICES. We assist and support retailers, hospitals and pharmacies with financial management activities related to the provision of healthcare, such as by processing insurance payments for prescriptions and providing performance analytics.

WHAT PERSONAL INFORMATION DOES INMAR COLLECT OR RECEIVE?

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). The table below describes the categories of personal information we may have collected from our users within the last twelve months:

Category	Examples
A. Identifiers.	A real name, alias, postal address, unique personal identifiers (such as device identifiers, internet protocol addresses, cookies, beacons, pixel tags mobile ad identifiers or similar technology, customer numbers, unique pseudonyms, user aliases, telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular customer or device), online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, pregnancy or childbirth and related medical conditions), veteran or military status, genetic information (including familial genetic information).
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
F. Geolocation data.	Physical location or movements.
G. Sensory data.	Audio, electronic, visual, thermal, or similar information.
H. Professional or employment-related information.	Current or past job history or performance evaluations.
I. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.

HOW DOES INMAR OBTAIN YOUR PERSONAL INFORMATION?

We may collect personal information directly from consumers in a variety of ways, such as:

When a consumer registers and/or creates an account with us, we may collect authentication and other information provided by the consumer as part of the registration, such as a username, password, and contact information such as name, email address, or phone number, and security questions and answers.
When a consumer interacts with or makes selections on our websites and applications, we may collect records of those interactions or selections. For example, if a consumer selects a digital coupon that is offered within an application or website, we may make a record of that selection so we will be able to inform retailers that the consumer is entitled to the benefit of the coupon.
When a consumer submits redemption information to us as part of a rebate program, such as a receipt, or other information that is otherwise necessary for us to process the rebate.
When a consumer otherwise submits information or communicates with us, such as through features like feedback forms or otherwise contacting us via telephone, email, fax, or postal mail.

We may also collect other personal information automatically when a consumer visits or uses our websites, applications, or other online services, including as described below:

BROWSER AND DEVICE INFORMATION. Certain information may be automatically collected by most browsers or devices, such as information about consumer’s devices (such as IP addresses and MAC addresses), operating systems, and browsers. We may use this information to ensure that our websites and applications function properly. We may also collect advertising device identifiers, such as IDFA for iOS devices and AAID for Android devices.
INFORMATION STORED IN COOKIES. Our websites may also use available web-based technologies to collect consumer data, such as cookies or web beacons. Cookies are pieces of information stored directly on users’ computers or devices. Cookies allow us to collect information such as browser type, time spent on the online services, pages visited, referring URL, and other traffic and usage data. We may also use cookies for purposes such as determining what features interest our users, revising our site features or operations, and as further described below. For more information, see the “What Options and Choices Do Consumers Have Regarding Personal Information?” section below.
PIXEL TAGS AND LOG FILES. Our websites may also use other tracking systems such as log files and pixel tags. For example, pixel tags, sometimes called web beacons, are similar in function to a cookie and can tell us certain information like what content has been viewed.
INFORMATION COLLECTED IN CONNECTION WITH ANALYTICS TECHNOLOGY: We may use various technologies to learn more about how visitors use our websites, applications, or other online services, such as Google Analytics 4 (“GA4”). GA4 uses cookies to help us analyze how visitors use the Website. If you so choose, you may be able to opt out by turning off cookies in the preferences settings in your browser. For more information on GA4, including how GA4 collects, uses, and discloses information, refer to the following page: www.google.com/policies/privacy/partners/. We may also use other technologies to monitor your activities on our website.
IP ADDRESS: An IP address is a number that is automatically assigned to the computer that a consumer uses by their Internet Service Provider (“ISP”). An IP address may be identified and logged automatically in our server log files whenever a user accesses our websites, applications, or other online services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications, and other services. We may use IP addresses for purposes such as calculating usage levels, diagnosing server problems, and administering our websites, applications, and other online services.
LOCATION INFORMATION. We may receive consumers’ approximate location or data that indicates their approximate location, such as their IP address and locations where they redeem coupons or discounts. Such data assists us in improving our applications in future versions of our services, and also enables us to offer better services both to consumers and to our Business Customers.

We may also receive various types of personal information about consumers from our Business Customers as part of the services we provide, such as:

When we manage a retailer’s customer loyalty program, we may obtain a consumer’s registration information, such as the consumer’s name, address, phone number and any unique ID associated with their registration. We may also receive records of consumers’ purchase histories, discounts, and other benefits to which the consumer is entitled.
When we provide Supply Chain Services, we may receive personal information, such as consumer names, mailing addresses, and other contact information, in order to receive and manage returns for our Business Customers.
When we provide Healthcare Services, we may receive consumers’ personal information, such as consumer names, insurance providers, insurance plans, prescription purchases, and prescription costs, in order to invoice insurance companies for prescription purchases at our pharmacy customers.
When our Business Customers otherwise provide or direct us to receive personal information.

Whenever we receive personal information from our Business Customers, like retailers, manufacturers, or government entities, we may use and disclose such personal information as authorized by those Business Customers. We are not responsible for the policies or practices of our Business Customers with respect to the personal information those Business Customers provide to us or otherwise collect from consumers.

We may combine the information we obtain from third parties with information that we or our affiliated organizations have collected about you.

This Privacy Policy does not apply to anonymized or aggregated data that does not allow us or third parties to identify or contact you.

FOR WHAT PURPOSES AND IN WHAT MANNER DO WE USE PERSONAL INFORMATION?

We may use personal information for purposes that include the following:

Providing and operating our services, including for and on behalf of our Business Customers.
Completing transactions and performing contractual obligations.
For internal business operations, such as evaluating and improving the effectiveness of our operations, including our services, websites, applications, and marketing efforts, conducting research and analysis, developing new services, and performing other internal business operations, including as described elsewhere in this privacy policy.
To update or modify our websites, applications, or other online services features or operation.
For marketing purposes.
To communicate with consumers, our Business Customers, and others.
To create aggregate or deidentified data.
Storing information about consumer preferences, recognizing consumers’ activities associated with our services, and customizing consumers’ user experiences.
Determining consumers’ locations in order to provide location-based services to consumers or our Business Customers.
To evaluate an actual or potential merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, including as part of bankruptcy, liquidation, or similar proceeding.
To debug, identify, or repair errors or effectuate similar functional enhancements in connection with our websites, applications, or other services.
To maintain the safety, security, and integrity of our websites, applications, other technology assets, and our business.
To protect against malicious, deceptive, fraudulent, or illegal activity, and participating in any prosecution or enforcement of laws or agreements meant to prevent or punish such activity.
Protecting the legal rights, property, safety, and security of our organizations, employees, customers and others.
To comply with applicable law, other legal requirements, and industry standards.
To enforce our policies, terms of use, or rights arising from contracts.
For such purposes as consumers may authorize at the time they submit the information.
For any other purpose with consumer consent.

TO WHOM AND FOR WHAT PURPOSES DO WE DISCLOSE PERSONAL INFORMATION?

We may disclose personal information, including for the purposes described above:

To our Business Customers and the contractors, service providers, and other third parties our Business Customers may use to support their operations. For example, if a consumer provides us their contact and purchase information to join a retailer loyalty program, we may disclose that contact and purchase information to the retailer for whom we manage that program.
To our affiliate organizations.
To our contractors, service providers, and other third parties we use to support our organization.
To communicate with consumers, our Business Customers, and others.
To comply with applicable law, other legal requirements, and industry standards.
To enforce our policies, terms of use, or rights arising from contracts.
To investigate or prevent unlawful activities or misuse of our services.
To protect the legal rights, property, safety, and security of our organizations, employees, customers and others and to prevent fraud and other harm.
To a buyer or other successor or organization in the event of an actual or potential merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, including as part of bankruptcy, liquidation, or similar proceeding.
For such purposes as the consumer may authorize at the time they submit the information.

THIRD-PARTY TREATMENT OF CONSUMER INFORMATION

Inmar’s mobile applications and websites may include links to applications, websites, information and services provided by third parties. Inmar is not responsible for the privacy practices of those third parties. We encourage consumers to review the applicable privacy policies of such third parties if they elect to follow the links provided.

WHAT OPTIONS AND CHOICES DO CONSUMERS HAVE REGARDING PERSONAL INFORMATION?

Consumers may choose not to provide the personal information we collect directly from them. However, not providing information we request may restrict consumers’ ability to use certain features of our services or our Business Customers’ services where we collect or receive personal information on behalf of our Business Customers. For example, consumers may be able to restrict the collection of personal information or functionality through their device’s operating system or by disabling cookies, but doing so may prevent them from using the functionality of the relevant website, application, or online service.

We may allow third parties to use our websites, applications, and online services to collect personal information about consumers’ online activities over time and across different websites, applications, and other online products or services.

You may follow instructions contained in our marketing and promotional emails to opt out of future marketing and promotional emails. Please note that you may still receive promotional or marketing emails after opting out, but that marketing may not be tailored to you or your interests.

Your mobile device may also have settings that allow you to prevent sharing geolocation information with us. You should consult your mobile device’s settings or help documentation for more information about exercising these options. As described above, much of the personal information we process is received from or collected on behalf of our Business Customers, such as retailers and manufacturers. Where we are processing personal information received from or collected on behalf of our Business Customers, we may have no direct relationship with the individuals whose personal information we process under these circumstances. If we receive your personal information from one of our Business Customers or if we process your personal information on behalf of one of our Business Customers and you would like to make an inquiry, complaint, or otherwise exercise choices that Business Customer may provide, please contact the Business Customer that you interact with directly.

RETENTION OF INFORMATION

We may retain personal information in our databases to the extent we deem necessary to carry out the processing activities described above, including but not limited to compliance with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies, and to the extent we reasonably deem necessary to protect our and our partners’ rights, property, or safety, and the rights, property, and safety of our users and other third parties. While we may remove personal information from the databases that we use in active operation of our business, some or all of that personal information may be retained in archival backups of those databases.

INFORMATION SECURITY

We maintain appropriate administrative, technical, and physical safeguards designed to protect personal information in our possession. We cannot guarantee the security of the information that we collect and store. If you believe that information about you has been compromised, please let us know by emailing privacy@inmar.com.

PRIVACY POLICY CHANGES

Inmar reserves the right to update this Privacy Policy from time to time. We will make any such updates publicly available for review, and will indicate the date as of which the revised Privacy Policy becomes effective. As permitted under applicable law, by using our services after such notice, you consent to our updates to this policy as of the Effective Date listed below.

ADDITIONAL INFORMATION FOR EBT USERS:

If we make material changes, we will notify you of the changes through email or on the website.

INTERNATIONAL USERS

Our services are not targeted to individuals outside of North America. If you are located outside the United States, please be aware that information we collect may be transferred to, processed and stored by us or our service providers outside the country in which you are located, including in the United States, in accordance with this Privacy Policy and applicable laws.

CHILDREN’S DATA

Children under 16 years of age are not permitted to use the services, and Inmar does not knowingly collect information from children under the age of 16. By using the services, you represent that you are 18 years of age or older, or are 16 years of age or older and have valid parental consent to do so.

The table below describes the categories of California Personal Information we may have collected from consumers within the last twelve months:

Category	Examples
A. Identifiers.	A real name, alias, postal address, unique personal identifiers (such as device identifiers, internet protocol addresses, cookies, beacons, pixel tags mobile ad identifiers or similar technology, customer numbers, unique pseudonyms, user aliases, telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular customer or device), online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, pregnancy or childbirth and related medical conditions), veteran or military status, genetic information (including familial genetic information).
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
F. Geolocation data.	Physical location or movements.
G. Sensory data.	Audio, electronic, visual, thermal, or similar information.
H. Professional or employment-related information.	Current or past job history or performance evaluations.
I. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.

PRIVACY RIGHTS AND CHOICES FOR RESIDENTS OF CERTAIN U.S. STATES

The California Consumer Privacy Act of 2018 and its successor legislation (“CCPA”) and other similar privacy laws in other states (collectively, “Applicable State Laws”) provide certain residents with specific rights regarding their personal information. This section describes the rights California residents and residents of other states under Applicable State Laws have and explains how these residents can exercise those rights, as applicable.

ACCESS TO PERSONAL INFORMATION AND DATA PORTABILITY RIGHTS

California residents and residents of other states under Applicable State Laws may request that we disclose certain information about our collection, use, and disclosure of their personal information over the past twelve months. If we receive and confirm a verifiable consumer request pursuant to the “Exercising Your Privacy Rights” section below, where permitted by Applicable State Laws, we will disclose to that resident one or all of the following depending on the scope of the request:

The categories of personal information we collected about that resident over the past twelve months.
The categories of sources for the personal information we collected about that resident over the past twelve months.
Our business or commercial purpose for collecting that personal information over the past twelve months.
The categories of third parties with whom we share that personal information over the past twelve months.
The specific pieces of personal information we collected about that resident over the past twelve months.
The categories of personal information about that resident that we disclosed for a business purpose, to the extent we have made such disclosures over the past twelve months.

California residents and residents of other states under Applicable State Laws also have the right to request a copy of the personal information we have collected and maintained over the past twelve months.

DELETION REQUEST RIGHTS

Subject to certain exceptions, California residents and residents of other states under Applicable State Laws may request that we delete the personal information we collected about them. If we receive and confirm a verifiable consumer request pursuant to the “Exercising Your Privacy Rights” section below, we will delete and direct our service providers to delete that resident’s personal information, unless an exception applies.

CORRECTION RIGHTS

California residents and residents of other states under Applicable State Laws have the right to request that we correct inaccurate personal information that we have collected and maintain about them.

EXERCISING YOUR PRIVACY RIGHTS

To request that we exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Calling us at 844-392-1073; or
Submitting this webform.

If you have an account with us, we may deliver our written response to that account. If you do not have an account with us, we will deliver our written response through email. Any disclosures we provide will only cover the 12-month period preceding your verifiable request's receipt. For data portability requests, we will select an industry-acceptable format to provide your personal information.

Unless a request is manifestly unfounded or excessive, we will not charge a fee to process or respond to your verifiable consumer request. If we determine that a request is manifestly unfounded or excessive, we will tell you why we made that decision and reserve the right to either refuse to act on your request or charge you a reasonable fee to complete your request.

In order to protect your personal information, please note that:

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
The request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized agent. In order to verify your request, we may ask you to provide information such as your first and last name, email address, mailing address, phone number, or any other information necessary to verify your identity.
The description of the request must provide sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with your personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. You may designate an authorized agent to submit requests on your behalf through a valid power of attorney in certain circumstances or through signed written permission that authorizes the agent to act on your behalf. We may mandate additional requirements when requests are submitted through an authorized agent, such as, requiring the submission of signed written permission for the agent to act on your behalf, requiring you to verify your identity directly with us, and/or otherwise requiring you to confirm the authorized agent’s permission to act on your behalf directly.

You are not required to create an account with us to make a verifiable request. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

As described above, where we are processing personal information received from or collected on behalf of our Business Customers, we may act as a “service provider” or “processor” as defined in Applicable State Laws and have no direct relationship with the individuals whose personal information we process under these circumstances. If we receive your personal information from or on behalf of one of our Business Customers or if we process your personal information on behalf of one of our Business Customers and you would like to make an inquiry or complaint, please contact the Business Customer that you interact with directly.

SALES OF PERSONAL INFORMATION

In the preceding twelve months, we have not sold the categories of personal information described above that we collected. We do not “sell” your personal information as that term is defined under Applicable State Laws.

NON-DISCRIMINATION

Subject to certain exceptions, you have the right to not receive discriminatory treatment for exercising your access, data portability, and deletion rights described above.

RIGHTS OF CALIFORNIA RESIDENTS

California residents who have an established business relationship with us may request information regarding third parties, if any, to whom Inmar may have disclosed personal information (as defined by Cal. Civ. Code § 1798.83(e)(7)) for the direct marketing purposes of those third parties during the preceding calendar year.

All such requests should be submitted in writing to the Inmar Privacy Office at the postal address provided in the “Contacting Us” section below.

RIGHTS OF NEVADA RESIDENTS

Nevada residents have the right to request that we do not sell your personal information (as defined in N.R.S. § 603A), even if your personal information is not currently being sold.

All such requests should be submitted in writing to the Inmar Privacy Officer at the postal address provided below.

CONTACTING US

If you have any questions or comments about this Privacy Policy or would like to exercise any applicable rights under this Privacy Policy, please contact Inmar’s Privacy Office at:

Inmar, Inc.
Attention: Privacy Office
1 W. 4th St., Suite 500
Winston-Salem, NC 27101
privacy@inmar.com

Please include your name, contact information, and the nature of your request so that we can respond appropriately and promptly to your communication.

This Privacy Policy is effective as of and was last updated on: November 29, 2023