PRIVACY POLICY

This privacy policy (the “Privacy Policy”) describes our policies on the collection, use, and disclosure of personal information from you in connection with your use of our websites, mobile applications, email addresses and other related services (the “Services”). We take your privacy seriously and make it a priority to protect personally identifiable information that we obtain from and about our users. By using the Services, you consent to the collection, use, and disclosure of your personal information in accordance with this Privacy Policy. This Privacy Policy is incorporated by reference into the Blink Terms of Service and subject to the provisions of the Terms of Service.

DEFINED TERMS

Capitalized terms used but not defined in this Privacy Policy have the meanings given to them in the Terms of Service.

“Personal Information” as used in this Privacy Policy, is information that personally identifies a specific individual, such as an individual’s name, address, telephone number, date of birth, e-mail address or username, alone or in combination with other information. Information about an individual’s activities, such as information about his or her activity on the Services, demographic information, or preferences, comprises Personal Information only when any of this information is linked to or used in combination with personally identifiable information.

“Aggregate Information” is information that we collect about a group or category of products, services, or users that is aggregated and not personally identifiable or from which individual identities are removed. Personal Information does not include “aggregate” or other non-personally identifiable information.

WHAT INFORMATION DO WE COLLECT?

We receive and may store Personal Information that you provide to us by using the Services, including the following:

REGISTRATION INFORMATION

The Services may give you the ability to register for a Blink account or to create and update a user profile on the applicable Service. If we offer user account or profile functionality on the Services, we will collect the Personal Information that you provide to us in the course of registering for an account or creating or updating a user profile. This information may include, for example, name, postal address, telephone number, e-mail address, any photo you submit through the registration process, and related demographic information about you. If you feel that an unauthorized account has been created on your behalf or depicting you, you may request its removal by sending an email to info@engageblink.com.

You may, now or in the future, be given the option to link Integrated Services to your Blink account or otherwise access such Integrated Services, such as social networking sites, financial institution sites, or financial account aggregation services. By linking your Blink account to an Integrated Service, you authorize us to access and store the credentials you provide, your name, email address(es), date of birth, gender, current city, and other information that your settings on the Integrated Service enable us to access, and to use and disclose such information in accordance with this Privacy Policy. We encourage you to check the privacy policies and settings of these Integrated Services to understand and change the information sent to us or made available through these Integrated Services.

INTERACTIVE FEATURES

We collect the information, including Personal Information, that you provide to us in the course of using any interactive functionality on the Services, for example by posting comments to forums, submitting reviews, uploading photographs and other content (the “User Materials”), voting, and submitting or transferring other information to interact with the Services and other users.

CORRESPONDENCE

If you contact us by e-mail, by online web submissions, by mail or other means, we collect the Personal Information contained within, and associated with, your correspondence. By submitting any suggestions, recommendations, proposed improvements or other ideas to us, you agree that we may use, incorporate into the Services, adapt or otherwise commercialize such submissions without compensation or credit to you.

INVITATION SERVICE

We may offer an invitation service to tell a friend about the Services. If you choose to use our invitation service to tell a friend about the Services, we may ask you for information needed to send the invitation, such as your friend’s email address or phone number. We may also offer you to the opportunity to invite your friend via third party services such as Facebook and Twitter. We will automatically send your friend an email or text message inviting him or her to try the Services. By providing email addresses or phone numbers of non-users, you represent that you have the right to do so and that such information may also be provided to the third party service that you have designated to contact the non-user. We store and use this information to send this invitation, to register a friend if your invitation is accepted, to track and monitor the success of our invitation service, and for administrative or internal business purposes. Your friend may contact us at info@engageblink.com to request that we remove this information from our database.

DEVICE INFORMATION

We collect information about the nature of the device from which you are accessing the Services (e.g., a personal computer or a mobile device), including your browser’s Internet Protocol (IP) address, browser type, the identifier for any handheld or mobile device that you may be using, and the Web site that you visited immediately prior to or after accessing any Web-based Services.

USE INFORMATION

We collect information about the actions you take on the Services, and the content, features, and activities that you access and participate in on the Services.

COOKIES AND CLEAR GIF INFORMATION

We may use technologies such as standard server logs, cookies and clear GIFs (also known as “Web beacons”) to passively collect information to enhance your user experience. Cookies are small data files stored by your Web browser on your computer. Cookies allow us to recognize you when you return to the Services and personalize your online experience, so the information you receive is more relevant to you. Please review your web browser “Help” file to learn the proper way to modify your cookie settings. Note that if you delete, or choose not to accept, cookies from the Services, you may not be able to utilize the features of the Services to their fullest potential. Clear GIFs are tiny graphic images that allow us to determine which features of the Services you have accessed or to measure the effectiveness of any searches you may do on our site. Clear GIFs also enable us to send you email in a format you can read and let us know when you have opened an email message from us.

LOCATION INFORMATION

We may offer features designed to help you use the Services in whole or in part based on your location. You will be given the opportunity to opt-in to location-based services, normally through an opt-in screen on our mobile App. Once you opt-in to location based services, we obtain information about your location through various methods such as pinpointed GPS data or cellphone/cell tower proximity. You may withdraw your permission for Blink to access pinpointed location information, but depending on the device or browser associated with the Service you’re using, location information permissions may not be controlled by us. If you do not opt-in to location-based services, you may not have access to all the features necessary to use the Services.

INFORMATION ON THIRD-PARTY SITES

Third parties, such as companies displaying content on the Services or sites or services provided by third parties such as credit card service providers or marketing affiliates (“Third-Party Sites”) that may be linked to from the Services, may passively collect information about your use of their services, Third-Party Sites or content. We do not have access to, or control over, any third-party means of passive data collection.

We may also collect or receive information about you, including Personal Information, from other sources and we may combine this information with other Personal Information we maintain about you. If we do so, this Privacy Policy governs any combined information that we maintain in personally identifiable format.

HOW WE USE YOUR INFORMATION

The Services are highly personalized, and we use your Personal Information in a variety of ways in the operation of our business.

We may use Personal Information that you provide to the Services or that we collect and/or aggregate to provide services and information that you request; to provide all features and services found on the Services; to enhance, improve, operate, and maintain the Services, our programs, services, Web sites, and other systems; to create new features and functionality; to prevent fraudulent use of the Services and other systems; to prevent or take action against activities that are, or may be, in violation the Blink Terms of Service or applicable law; to tailor or customize credit card recommendations, rewards information, promotions, advertisements, offers, content, and other aspects of your experience on and in connection with the Services; to maintain a record of our dealings with you; to understand and analyze your usage trends, interests, and preferences; in an aggregated or otherwise non-personally identifiable manner; for other administrative purposes; and for any other purposes that we may disclose to you at the point at which we request your Personal Information, and pursuant to your consent.

If we link or associate any information gathered through passive means with Personal Information, or if applicable laws require us to treat any information gathered through passive means as Personal Information, we treat the combined information as Personal Information under this Privacy Policy. Otherwise, we use and disclose information collected by passive means in aggregate form or otherwise in a non-personally identifiable form.

We may also use Personal Information you provide to contact you regarding, or otherwise make available through the Services, products, services, promotions, and offers, both from ourselves and from third parties, that we believe you may find of interest. We allow you to opt-out from receiving marketing communications from us as described in the “Choice” section below.

HOW DO WE DISCLOSE YOUR INFORMATION?

We disclose your Personal Information in a variety of circumstances in connection with the development, operation, provision, maintenance, and enhancement of the Services or our business, including:

• To other users of the Services who view or otherwise have access to any User Materials you upload, post or otherwise transmit on or through the Services. Carefully consider the content of such User Materials. If you include Personal Information in User Materials, it is at your own risk.
• In connection with the reorganization, reincorporation, acquisition, debt financing, merger, sale of our relevant assets or business or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which Personal Information is transferred to one or more third parties as one of our business assets. In the event that all or a portion of Blink or its assets are acquired by or merged with a third party entity, we reserve the right, in any of these circumstances, to transfer or assign the information that we have collected from users in connection with such merger, acquisition, sale, or other change of control.
• To third-party service providers or partners (e.g., data storage and processing facilities, financial institutions, financial account aggregation services providers, and merchants) that assist us in our work, in which case, we limit the Personal Information provided to that which is reasonably necessary for them to perform their functions.
• If we believe that doing so is required to comply with state, local, and federal laws (such as Malaysia Copyright law), in response to a court order, judicial or other government subpoena or warrant, to otherwise cooperate with law enforcement activity, to identify potential violations of our user policies, or to protect our reputation, property or other legal rights (including, but not limited to, enforcement of our agreements), our users, and the public from harm or illegal activities.
• We may also make certain automatically collected or Aggregate Information available to (i) comply with various reporting obligations; (ii) for business or marketing purposes; or (iii) assist such parties in (a) understanding our users’ interests, habits, and usage patterns for or related to certain programs, content, services, credit cards, rewards, promotions, advertisements and/or information, features, or functionality available through the Services and b) making available or tailoring such parties’ programs, content, services, credit cards, rewards, promotions, offers, advertisements, or other information to our users.

HOW DO WE PROTECT INFORMATION?

We use certain physical, managerial, and technical safeguards designed to help improve the integrity and security of your Personal Information. However, we cannot and do not ensure or warrant the security of any information you transmit to us or store on the Service; you do so at your own risk. If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice through the Services if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach you should notify us at info@engageblink.com.