Zavee LLC

Privacy and Security Policy

Last updated: August 28, 2009

Introduction

Zavee LLC ("Zavee") is committed to maintaining the confidentiality, integrity and security of all Member Data (as defined below). This Privacy and Security Policy explains how we protect any Member Data provided through our site Zavee.com (the "Site") and how we use that information in connection with the services we offer through the Site (the "Service").

Zavee has adopted rigorous privacy and security policies and procedures based on industry standards to guard against identity theft and provide security for Member Data and other information used by us to provide the Service. We regularly re-evaluate our privacy and security policies and procedures and adapt them as necessary to deal with new challenges.

We collect and store only the minimum information necessary for us to provide the Service to our Members. For example, although you must provide a credit card account number in order to take advantage of the Service, we do not collect the card expiration date, security code or other information that someone would need to make an unauthorized purchase with the card. We also encrypt the card information as soon as it is entered and only use the encrypted number to provide the Service.

We strictly limit the collection and use of Member Data

Certain areas and features of Zavee.com are available without registration or the need to provide any information to us. However, other features of the Site or the Service do require registration which involves providing Zavee with your name, a valid email address and a user-selected password (collectively, the "Registration Information"). In order to benefit from the full functionality of the Service, you also must provide (i) the account number for a valid Visa^®, MasterCard^®, American Express^® or Discover^® card and (ii) either (a) the account number and routing number for a US-based bank account or (b) account information for a valid PayPal account (collectively, the "Account Information"). The Registration Information and Account Information are collectively referred to in this Privacy and Security Policy as the "Member Data."

Zavee may enter into agreements with one or more third-party contractors pursuant to which Zavee provides access to certain of your Member Data in order to provide the Service to you and other Members. For example, we may use a third-party vendor to handle payments of rewards to Members. All such contractors will adhere to privacy and security standards equivalent to Zavee's. All Member Data that is transferred outside of Zavee's secure production environment will be encrypted prior to transfer using industry-standard encryption protocols and will be transferred only over secure data connections.

Your data is secure

We use a combination of firewall barriers, encryption techniques and authentication procedures, among others, to maintain the security of your online session and to protect Zavee accounts and systems from unauthorized access.

When you register for the Service, Zavee requires a password from you for your privacy and security.

Our servers are in a secure facility. Access requires multiple levels of authentication, including biometrics (hand print scan) procedures. Security personnel monitor the system 7 days a week, 24 hours a day. The Site is tested daily for any failure points that would allow hacking. Unencrypted Account Information is physically segregated from the encrypted information that is actually used to provide the Service.

Our databases are protected from general employee access both physically and logically. We enforce physical access controls to our offices. Only a limited number of senior management and technical personnel have access to our databases. Employees are prohibited from placing sensitive content on insecure devices. We encrypt your password so that it cannot be recovered, even by us. All backup media also are encrypted.

However, it is important to understand that these precautions apply only to our Site and systems. Apart from requiring that our vendors maintain privacy and security standards comparable to Zavee's, we exercise no control over how your information is stored, maintained or displayed by third parties or on third-party sites. We also exercise no control over how you protect your own information.

Your Privacy is Our Highest Priority

We do not and will not sell or rent your Member Data to anyone, for any reason, at any time.

Zavee uses and discloses your Member Data only as follows:

• to analyze site usage and improve the Service;
• to determine your eligibility for rewards;
• to process payments of rewards and other amounts payable or receivable through the Service;
• to deliver to you any administrative notices and communications relevant to your use of the Service;
• for market research, project planning, troubleshooting problems, detecting and protecting against error, fraud or other criminal activity; to third-party contractors that provide services to Zavee and are bound by these same privacy restrictions;
• to enforce Zavee's Terms of Use; and
• as otherwise set forth in this Privacy and Security Policy.

Zavee may make anonymous or aggregate Member Data and disclose such data only in a non-personally identifiable manner for research or promotional purposes. Such information does not identify you individually. Access to the Member Data you provide is strictly restricted to Zavee employees and contractors, on an as-needed basis and in accordance with specific internal procedures and safeguard governing access, in order to operate, develop or improve the Service. These individuals have been selected in accordance with our security policies and practices and are bound by confidentiality obligations. They may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

Changes to your Member Data

If your Member Data changes while you are a member of the Service, you may update it any time via the Service. If your Member Data is outdated, incomplete or incorrect you may not be able to take full advantage of the Service, including receiving payment in respect of rewards you may have accrued.

Online session information is only used to improve your experience

When you visit Zavee.com, we may collect technical and navigational information, such as computer browser type, Internet protocol address, pages visited, and average time spent on our Site. This information may be used, for example, to alert you to software compatibility issues, or it may be analyzed to improve our Web design and functionality.

We may use technologies such as cookies and web beacons to help us improve your experience. "Cookies" are text files that are inserted and stored by your Web browser on your computer's hard drive. Zavee may gather information about you or your preferences through cookie technology. "Web beacons" are images embedded in a Web page or email for the purpose of measuring and analyzing site usage and activity. Zavee may use Web beacons to help us analyze Site usage and improve the Service.

Please note that most Internet browsers will allow you to stop cookies from being stored on your computer and to delete cookies stored on your computer. If you choose to eliminate cookies, the full functionality of the Service may be impaired for you. We encode our cookies so that only we can interpret the information stored in them.

We may use third-party service providers to help us analyze certain online activities. For example, these service providers may help us measure the performance of our online campaigns or analyze visitor activity on Zavee.com. We may permit these service providers to use cookies and other technologies to perform these services for Zavee. We do not share any Member Data with these third party service providers, and these service providers do not collect such information on our behalf. Our third party service providers are required to comply fully with this Privacy and Security Policy.

Reviews and messages on Zavee.com

If you submit reviews or send messages to other users, you should be aware that any information you include can be read, collected or used by others and could be used to send you unsolicited messages in violation of our Terms of Use. We are not responsible for the Member Data you choose to submit using these features.

If you receive any messages that you believe to be spammy, abusive or otherwise in violation of Zavee's Terms of Use please notify us immediately at security@zavee.com.

Disclosure of your information to protect our rights or if required by law

Notwithstanding the foregoing, Zavee reserves the right (and you authorize Zavee) to share or disclose your Member Data when Zavee determines, in its sole discretion, that the disclosure of such information is necessary or appropriate:

• To enforce our rights against you or another user or in connection with a breach by you or such other user of this Privacy and Security Policy or Zavee's Terms of Use;
• To prevent prohibited or illegal activities; or
• When required by any applicable law, rule regulation, subpoena or other legal process.

Member Data may be transferred to a third party as a result of a sale, acquisition, merger, reorganization or other transfer involving Zavee or an affiliate of Zavee. Should such a transaction occur, we will use reasonable efforts to require that the surviving entity follow this Privacy and Security Policy with respect to your Member Data.

Deleting your data

Except as may otherwise be provided in the Merchant Membership Agreement between a Merchant and Zavee, Zavee will promptly honor any Member's request to delete such Member's Member Data in whole or in part.

When you request us to delete your account for the Service, your data will be permanently expunged from our primary production servers and further access to your account will not be possible. We also will disable data feeds with third-party contractors to the extent that they contain your Member Data.

However, your data may remain on a backup server or media, which Zavee maintains to ensure our continued ability to provide the Service in the event of malfunction or damage to our primary production servers. We also reserve the right to use any aggregated or anonymous data derived from or incorporating your Member Data.

Email communications from Zavee

We communicate with registered Members primarily through news, messages and notifications on the Site. However, we may send non-promotional, service-related emails to you from time to time. We may also send emails from time to time that promote Zavee, the Service, member Merchants or Causes or third-party partners of Zavee. We may also send emails containing invitations to subscribe to email newsletters.

Zavee subscribers have the ability to opt-out of receiving our promotional emails and to terminate their newsletter subscriptions by following the instructions in the emails. Opting out in this manner will not end transmission of service-related emails.

You are responsible for maintaining the confidentiality of your Login ID and Password

We maintain strict rules to help prevent others from guessing your password. We also recommend that you change your password periodically via the Service. Your password must be at least 6 characters in length. You are responsible for maintaining the security of your email address and password. If you believe that your Registration Information has been stolen or made known to others, you must contact us immediately at security@zavee.com, but in any event you should change your password immediately via the Service. We are not responsible if someone else accesses your account through Registration Information obtained from you or through a violation by you of this Privacy and Security Policy or Zavee's Terms of Use.

We post updates on our website whenever there is a change to our Privacy and Security Policy

We update this Privacy and Security Policy periodically. The date last revised appears at the top of the Policy. Changes take effect immediately upon posting.

Contact us if you have any questions or concerns

Merchants should be aware that certain provisions of this Privacy and Security Policy are subject to the terms of the Merchant Membership Agreement between such Merchant and Zavee.

If you have questions, comments, concerns or feedback regarding this Privacy and Security Policy or any other privacy or security concern, please contact us at security@zavee.com. We will work closely with you to ensure a rapid and personal response.

• Zavee LLC
• 455 NW 35th Street
• Boca Raton, FL 33431
• 888.MyZavee (699.2833)
• 561.290.0388