PRIVACY POLICY

Last revised: January 14, 2019

INTRODUCTION

Purpose. The purpose of this Privacy Policy is to describe how YoEats Technologies Inc., a Delaware corporation (“Company”), collects, uses and shares information about you through (i) our online interfaces (e.g., websites) owned and controlled by us, including www.paywithbrio.com (collectively referred to herein as the “Site”); and (ii) Company’s mobile application (the “App,” and together with the Site, collectively, the “Service”). Please read this notice carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please feel free to Contact Us [** Insert link to contact page or information **] or contact us as described at the end of this Policy.

Our Privacy Policy explains:

Information That We Collect [** Insert links to jump to the sections of the Policy.**]

How We Use and Share Your Information

Access to Your Information and Choices

Security of Your Information

Consent to Processing of Personal Data in United States

Changes to Our Privacy Policy

Questions and How Contact Us

Scope; Third Party Sites. This Privacy Policy applies only to information we collect at and through the Service. The Service may also contain links to third party sites that are not owned or controlled by Company. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave the Site or App and to read the privacy statements of each and every website that collects personal information.

Terms of Service. Please note that your use of the Site and App is also subject to our Terms of Service. [** insert link **]

INFORMATION THAT WE COLLECT

Information You Provide to Us

We collect information you provide to us, for example when you create or modify your account, register to use the Service, purchase products through use of the App, request information from us, contact customer support, or otherwise communicate with us. This information may include:

Name

Email address

Credit / debit card number (solely for payment purposes – such information is collected by a form hosted by Spreedly, Inc., as described below, but such information is not directly stored on our server)

Gender

Date of birth / age

User generated content (feedback, comments, ratings, etc.)

Information We Collect Automatically Through Your Use of the Service

Geo-location

Order information (i.e. food and beverage items purchased in connection with the Services, pricing information, etc.)

No Information from Children Under Age 13

If you are under the age of 13, please do not attempt to register with us at the Site or the App or provide any personal information about yourself to us. If we learn that we have collected personal information from a child under the age of 13, we will promptly delete that information. If you believe we have collected personal information from a child under the age of 13, please Contact Us [** Insert link to contact page or information **] or call us at (312) 320-1482.

HOW WE USE AND SHARE YOUR INFORMATION

To Provide Products, Services, and Information. We collect information from you in order to process, fulfill and administer transactions for products and services that you order using the Service; register and service your user account; provide information that you request from us; facilitate the processing of credit card and debit card transactions; send you promotional materials or advertisements about our products and services, as well as new features and offerings; administer surveys, sweepstakes, promotions and contests.

Sharing with Third Parties. When you order products and/or services from a third party facility (e.g. a restaurant or bar) through the App, we will share that order information with the applicable facility so that your order can be placed, filled and delivered to you efficiently. Additionally, we may provide information to third party service providers that help us operate and manage the Service, process and administer payments (including Spreedly and third party facilities from whom you purchase products or services via your use of the Service), and provide advertising for us. These service providers will have access to your personal information in order to provide these services, but when this occurs we implement reasonable contractual and technical protections to limit their use of that information to helping us provide the service.

Payment Processing. Our Service uses Spreedly, Inc., a third party service that validates, tokenizes and securely stores payment information (“Spreedly”), which is independent from Company. In connection with your use of the Service, Spreedly will collect certain information from you necessary to process any payments you desire to make in connection with the Service, including your credit/debit card number, bank or financial account number, and other personal information. Once such information is submitted and processed, Spreedly will send us a security token that we will save on our server to more efficiently and securely call up your payment information when you wish to make payments in connection with the Service in the future. We only store these security tokens on our server, which do not contain any sensitive card-level data. We do not directly store your payment information on our server. When you choose to make a payment to a third party facility in connection with your use of the Service, the third party facility (e.g. a restaurant, bar, etc.) from which you desire to purchase products or services will utilize your corresponding security token to securely call up your payment information and process your desired payments. For more information on Spreedly, please visit www.spreedly.com.

Aggregated and Anonymized Data. We may analyze, publish and otherwise share aggregated and anonymized data with third parties regarding your use of the Service for informational, marketing and other purposes. Such sharing includes, without limitation, demographic information of users of the Service that may be used by third party bars, restaurants and other facilities to offer and promote products that may be of interest to you via the Service.

Your Consent. In addition to the sharing described elsewhere in this Policy, we will share information about you, including personal information with companies, organizations or individuals outside of Company when we have your consent to do so.

Legal Proceedings. We will share personal information with third party companies, organizations or individuals outside of Company if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

Meet any applicable law, regulation, subpoena, legal process or enforceable governmental request.

Enforce applicable Terms of Service, including investigation of potential violations.

Detect, prevent, or otherwise address fraud, security or technical issues.

Protect against harm to the rights, property or safety of Company, our users, customers or the public as required or permitted by law.

Transfer in the Event of Sale or Change of Control. If the ownership of all or substantially all of our business changes or we otherwise transfer assets relating to our business, the Site and/or the App, or any portion thereof, to a third party, such as by merger, acquisition, bankruptcy proceeding or otherwise, we may transfer or sell your personal information to the new owner. In such a case, unless otherwise permitted by applicable law, your information would remain subject to the promises made in the applicable privacy policy unless you agree differently.

ACCESS TO YOUR INFORMATION AND CHOICES

You can access and update certain information we have relating to your user account by signing into your account and going to the “My Favorites,” “My Account,” and “My Restrictions” section of the App. If you have questions about personal information we have about you or need to update your information, you can Contact Us [** Insert link to contact page or information **], call us at (312) 320-1482 or email us at clay@yoeats.com. You can opt-out of receiving marketing and promotional emails from Company by using the opt-out or unsubscribe feature contained in the emails. Additionally, you may opt-out of receiving push notifications via the App by modifying the notification settings in your phone.

You can close your user account by selecting “Delete Account” in the settings of the App. If you close your account, we will no longer use your account information or share it with third parties. We may, however, retain a copy of the information for archival purposes, and to avoid identity theft or fraud.

SECURITY OF YOUR INFORMATION

We use industry standard physical, technical and administrative security measures and safeguards to protect the confidentiality and security of your personal information. However, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Please note that emails and other communications you send to us through the Service are not encrypted, and we strongly advise you not to communicate any confidential information through these means.

CONSENT TO PROCESSING OF PERSONAL DATA IN THE UNITED STATES

The Site and the App are not intended for and are not directed to residents of the European Union. By using and accessing the Site or the App, users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of personal information on servers located outside of the country where they reside, and that the protection of such information may be different than required under the laws of their residence or location.

CHANGES TO OUR PRIVACY POLICY

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your consent in accordance with applicable law. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.

QUESTIONS AND HOW TO CONTACT US

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us, please Contact Us [** Insert link to contact page or information **] , email us at clay@yoeats.com, call us at (312) 320-1482, or contact us by US postal mail at the following address:

YoEats Technologies Inc.

StartingBlock

821 E. Washington Avenue

Suite 200

Madison, Wisconsin 53703