Effective Date: September 8, 2022

This Privacy Policy describes how Two Twenty Two, Inc., d/b/a The Bitcoin Company (“The Bitcoin Company,” “we,” or “us”) and its subsidiaries: Two Twenty Three, LLC. and Two Twenty Four Technologies, Inc., collect and use your personal data that you provide in connection with our products and services, including without limitation, the loyalty program we market and promote which offers rewards points convertible into Bitcoin for (i) registering your credit and debit cards and using them in connection with card-linked offers, (ii) purchasing Visa® gift cards on our website and through our app, (iii) purchasing gift cards from participating merchants on our website and through our app, and (iv) any other ancillary services related to the services described above. This Privacy Policy also applies to visits to our website at www.thebitcoincompany.com, our app and any additional company websites or apps from which this Privacy Policy is accessible as well as other interactions with you.

In this Privacy Policy, the above are referred to collectively as the “Services.” This policy describes the choices available to you regarding our use of your personal data and how you can access and update this data. Services include software and services that we own and operate directly, as well as software and services that we market or provide from or on behalf of third parties. Your use of the Services is governed by our Terms of Service (the “Terms”) available at www.thebitcoincompany.com/terms . Capitalized terms used herein without definition shall have the meanings assigned to them in the Terms.

If you have any questions regarding this Privacy Policy, please contact us at support@thebitcoincompany.com. By using any of the Services you understand and agree that your personal information will be treated in accordance with this policy. If you do not agree to the terms of this Privacy Policy, please do not provide us with any personal information and do not use the Services.

The Services are intended for a general audience. We do not knowingly collect personal information from children under the age of 13. We will delete any personal information collected that we later determine to be from a user younger than the age of 13. If you are a parent or guardian of a child under the age of 13 and you believe he or she has disclosed personal information to us, please contact Customer Service using the contact information below.

The Services are provided to users from systems in the United States. If you are from outside the United States and use the Services, please be aware that the data protection laws in the United States may differ from those of the country where you are located, and your personal information may be subject to access requests from governments, courts, or law enforcement in the United States according to the laws of the United States. In addition, such data may be accessed in or stored on servers located outside your resident jurisdiction and in jurisdictions that may have less stringent privacy practices than your own. If you use the Services or provide us with any information, we may transfer, processes, use, share, and store  your information, including personal information, to our service providers or affiliates located in the United States as set forth in this Privacy Policy.

If you are a California resident, you may have certain rights as provided in the California Consumer Privacy Act (“CCPA”).  For the CCPA-specific provisions of this Privacy Policy, please see Section VI below.

 

I. Information Collected Via the Services

We may obtain various types of personal data about users of the Services and website visitors. This data may include:

  • Email address and a password you create if you choose to create an account (otherwise, we collect a username);
  • First and last name, email address, a Bitcoin address, Bitcoin payment invoice or a Bitcoin Node ID to convert your points to bitcoin;
  • Information about purchases made using debit or credit cards that have been linked to a user’s account (including the merchant name and amount of purchase) and the debit or credit card number of linked cards;
  • Delivery address for delivery of a physical gift card;
  • Information collected through Internet-based and e-commerce activities such as information obtained from log files, cookies, clear gifs (i.e., web bugs), images, and scripts;
  • Customer service and information about your prior experiences with our services.
  • Information collected from our third-party service providers such as for anti-money laundering and sanctions screening purposes; and
  • Other transaction-related data relating to your participation in the loyalty program, such as information about qualifying purchases, rewards earned (including prepaid card number), withdrawals, available balance.
  • Information to personalize your shopping experience, such as your favorite brands.

When providing the Services we may also collect the following information about your devices, including:

  • Device information, such as the operating system version, processor type, memory space, and the like;
  • Information about software on your device, including the version of certain software programs and when they were installed and/or upgraded; 
  • Browsing history, preferences, internet protocol (IP) addresses, unique identifiers (as required to provide the services), device types, general device location (to provide accurate information and gift cards), and other similar information; and
  • Information collected from logs, configuration files, and other system or software-level information.

We will retain your information for as long as your account is active and as needed to provide the Services. We will retain and use your information as reasonably necessary to conduct our business, comply with our legal obligations, resolve disputes, and enforce our agreements.

 

II. Information Usage and Sharing

We may use the personal data you submit in order to:

  • Accomplish our business purposes, including to deliver or provide the Services you have requested, establish or maintain customer and business relationships, improve the Services, provide access to Internet-based and e-commerce activities, perform invoicing and accounting functions, meet our legal and regulatory obligations such as anti-money laundering and sanctions screening, and conduct other activities as necessary or appropriate in connection with the Services.
  • Market our products and services to you, and the products and services of our third-party partners, including to send you information about products, services, or promotions.
    • Opt-Out:  You may opt out of these promotional communications by following the instructions in each message, or by contacting us at support@thebitcoincompany.com. 
  • Send you service updates, and alerts related to the Services, including notices of security incidents, downtime, or planned maintenance. You may not opt-out of these service or transactional communications. If you do not wish to receive them, you have the option of deactivating your account and ceasing your use of the Services.
  • Create and administer your online account, facilitate rewards redemption, and convert points into bitcoin;
  • Facilitate your registration and participation at our events, such as hackathons, developer workshops, bitcoin conference engagements, and teaching events;
  • Respond to your requests for information and provide you with more effective and efficient customer service;
  • Provide you with updates and information about the Services;
  • With your consent, contact you by email, postal mail, or phone regarding our Services and third-party products, services, surveys, research studies, promotions, special events, and other subjects that we think may be of interest to you;
  • Customize the advertising and content you see via the Services;
  • Help us better understand your interests and needs, and improve the Services, including through research and reports, and test and create new products, features, and services;
  • Secure our websites and applications, and resolve technical issues being reported;
  • Comply with any procedures, laws, and regulations which apply to us; and
  • Establish, exercise, or defend our legal rights.

In addition, we may transfer or share personal data with our service providers under written contracts as needed for such service providers to perform services on our behalf, including to fulfill our obligations to you such as hosting our website, providing rewards services, sending communications, assist us in meeting our legal and regulatory obligations such as anti-money laundering and sanctions screening, providing marketing and advertising services. Service providers and business partners that are provided information under this section will not use personal data for any other purposes. If we have actual knowledge that a business partner or service provider is processing your personal data in a way that is contrary to this Privacy Policy, we will take reasonable steps to prevent or stop such processing. 

We may transfer or disclose personal data, including your contact information, to our affiliates, licensees, partners, and other third parties as appropriate in accordance with the terms of written agreements for legitimate business or marketing purposes. We will obtain your prior consent where required by applicable laws. 

We will, in our sole discretion, disclose your personal data to third parties in certain additional limited cases:  (1) when we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may be causing injury to or interference with our rights or the rights of our customers and vendors; (2) when we believe in good faith that the law requires us to do so; (3) to a subsequent owner, co-owner, or operator of a website or service or in connection with a merger, consolidation, or restructuring, or the sale of substantially all of our interests and/or assets, or other corporate change, including during the course of any due diligence process; (4) in situations involving threats to the physical safety of any person; and (5) where required or permitted by applicable law.

Notwithstanding anything to the contrary in the Terms or this Privacy Policy, we and our Third-Party Service Providers will use transaction information solely as follows:

  • Use transaction data to confirm a Qualifying Purchase or return to match transactions to confirm whether you qualify for Points;
  • Share transaction data with the participating Merchant where a transaction occurred as needed for the Merchant to confirm a specific transaction occurred or Points should be awarded; for example, the date and amount of your purchase and the last 4 digits of your card number so the merchant can verify your purchase with its records if there is a missing or disputed transaction;
  • Provide participating Merchants aggregated and anonymized information relating specifically to Member Card activity solely to allow participating Merchants to assess the results of their campaigns;
  • Create a record of the transaction data and thereafter maintain and use data in connection with operating the loyalty program;
  • Conduct internal analysis for the improvement and optimization of the program; and 
  • Provide information in order to respond to a request from government authority or a payment organization involved in a transaction with you or a Merchant.

You understand and authorize the sharing, exchange and use of transaction data described above and herein by and among The Bitcoin Company and The Bitcoin Company’s Third-Party Service Providers, applicable Card Networks and applicable Merchants.

For fraud protection purposes only, we collect data on your Battery Usage, Device Identifier, Device Storage, MAC Address, and SIM information.

III. Information Security

Your data is of the utmost importance to us. We use Secure Socket Layer Security (“SSL”) and other transmission technologies to encrypt your personal data so it cannot be read in transit. In addition, we use secure technology, privacy protection controls, and restrictions on employee access to safeguard your personal information in storage.

Please note, however, that although we employ industry-standard security measures to safeguard the security of your personal information, no transmissions made on or through the Internet are guaranteed to be secure. Therefore, we cannot ensure the absolute security of any information you transmit to us.

IV. Tracking Technologies

To the extent permitted by applicable law, we and our marketing partners, affiliates, or analytics or service providers, may use technologies such as cookies, beacons, tags, browser and device fingerprinting, network traffic monitoring, active scripting, recognition technologies, and scripts, to analyze trends, administer the Services, track users’ behavior while using the Services, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.

There may be other tracking technologies used by us in connection with the Services. Further, third parties may use tracking technologies in connection with our Services, which may include the collection and storing of information about your online activities over time and across third-party websites or online services.

Interest-Based Advertising

We may partner with one or more third parties such as ad networks and other advertising companies to display tailored advertising via the Services or on other sites. Our third-party partner(s) may use tracking technologies such as cookies and pixel tags to gather information about your use of the Services and other websites (such as web pages you visit and your interaction with our advertising and other communications) and use this information to make predictions about your preferences, develop personalized content and provide you targeted advertising based upon your browsing activities and interests both on and off our website. This information may also be used to evaluate the effectiveness of our online advertising campaigns.

For more information about interest-based advertising and to understand your options, including how you can opt-out of receiving behavioral ads from participating third-party advertising companies, please visit : 

Please note that even if you opt-out of interest-based advertising by a third party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads from us, but the ads will not be targeted based on behavioral information about you and may therefore be less relevant to you and your interests. 

To successfully opt out, you must have cookies enabled in your web browser (see your browser’s instructions for information on cookies and how to enable them). Your opt-out only applies to the web browser you use so you must opt-out of each web browser on each computer you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt-out again.

V. Other Services

If you click on a link to a third-party site, you will leave the site you are visiting and be redirected to the site you selected. Because we cannot control the activities of third parties, we do not accept responsibility for any use of your personal data by such third parties, and we do not guarantee that they will adhere to the same privacy policies as described in this Privacy Policy. We encourage you to review the privacy policies of these third parties. If you visit a third-party site that is linked to a Service, you should read that third-party site’s privacy statement before providing any personal data.

Our Services may include social media features, such as the “Share This” button that allows you to like us on Facebook or share our content on Twitter. These features may collect your IP address and information regarding your use of the Services. Social media features are either hosted by a third party or hosted directly on our systems. Your interactions with these features are governed by the privacy statement of the applicable company.

VI. Access to Information

Depending on the jurisdiction in which you reside, you have the right to access, update and correct inaccuracies in your personal information in our custody or control subject to limited exceptions under applicable law. You may request access, updating and corrections of inaccuracies in your personal information in our custody or control by emailing or writing to us at the contact information set out below. We may request certain personal information for the purpose of verifying the identity of the individual seeking access to his or her personal information records.

VII. California Consumer Privacy Act

A. Categories of Personal Information We Collect

Along with the information in the Privacy Policy as a whole, the CCPA requires us to describe the information we collect in certain “categories.”  The categories we collect may include:

  • Identifiers (such as real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers);
  • Commercial information (such as transaction data);
  • Internet or other network or device activity (such as browsing history and information on interaction with a website, application, or advertisement);
  • Geolocation data (at an IP-based or city/state/zip level);
  • Inference data about you drawn from the data in this section (based on user profile information);
  • Legally protected classifications (such as age and gender);
  • Other information that identifies or can be reasonably associated with you (e.g., information you voluntarily provide as you use the Services, such as additional profile information or user-generated content).

B. The Sources From Which the Categories of Personal Information Are Collected

We collect personal data directly from information you provide to us; indirectly from our affiliates, service providers, and other vendors; and indirectly through your interactions with websites or advertisements.

C. Business Purposes for Our Collection of Personal Information

The following is a list of the business purposes for our collection of information.

  • Provide the Services you have requested, including invoicing and accounting;
  • Respond to your requests for information and provide you with more effective and efficient customer service;
  • Provide you with updates and information about the Services;
  • Contact you by email, postal mail, or phone regarding our Services and third-party products, services, surveys, research studies, promotions, special events, and other subjects that we think may be of interest to you;
  • Customize the advertising and content you see via the Services;
  • Help us better understand your interests and needs, and improve the Services, including through research and reports, and test and create new products, features, and services;
  • Secure our websites and applications, and resolve technical issues being reported;
  • Comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others; and
  • Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others.

D. Sharing of Categories of Personal Information

We may share categories of personal information to accomplish the various business purposes above and as described throughout this Privacy Policy.

E. CCPA Rights Disclosure

If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:

  • Inform you about the categories of personal information we collect or disclose about you and the categories of sources of such information;
  • Inform you about the business or commercial purpose for collecting personal information and the categories of third parties with whom we share/disclose personal information (which is also disclosed in this Privacy Policy);
  • Provide you with the specific pieces of personal information we collect about you; and
  • Delete personal information we have about you.

Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the Services to you. You may only make such a request twice within a twelve-month period. Requests are generally free; however, we may charge a reasonable fee or deny your request if it is manifestly unfounded, excessive, or repetitive.

To make a CCPA request, please contact us at support@thebitcoincompany.com. We will request information, which at a minimum will include your name and email address, to verify your identity. We may request additional information to verify your identity before responding to a request. Under the CCPA, you may have an authorized agent submit a request on your behalf, and we will collect certain authorization and verification information from the agent and you in such circumstances.

The CCPA further provides you with the right to receive information about the financial incentives that we offer to you, if any, and the right not to be discriminated against for exercising your rights under applicable law.

If you would like further information regarding your legal rights under California law, please contact us at support@thebitcoincompany.com.

F. California Do Not Sell Notice and Information Request

If you are a California resident, the CCPA provides you with the right to opt out of the “sale” of your “personal information.” We may allow some of our advertising partners to collect certain pieces of information from our site visitors, such as device identifiers, cookies, advertising IDs, IP addresses, and usage activity, so that we and our partners can deliver ads that are more relevant to you. This type of information sharing with our advertising partners may be considered a “sale” under the CCPA. If you want to opt out of these activities, please contact us at support@thebitcoincompany.com.  Please note that some or all of the Services may not function if you choose to opt out of such activities.

If you are a California resident, California Civil Code Section 1798.83 allows you to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for the third parties’ direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding twelve calendar months. If you are a California resident and would like to make such a request, please submit your request in writing to:

Two Twenty Two, Inc. d/b/a The Bitcoin Company

2028 E Ben White Blvd #240-6969

Austin, TX 78741

United States

 

VIII. Contact Us

You can access, update or correct your information, or otherwise ask us questions about this Privacy Policy or about the manner in which we or our service providers treat your personal information by contacting us as follows:

Ben Price, CEO

support@thebitcoincompany.com

Two Twenty Two, Inc. d/b/a The Bitcoin Company

2028 E Ben White Blvd #240-6969

Austin, TX 78741

United States

We may update this Privacy Policy from time to time to reflect changes to our information practices. When we make changes to this Privacy Policy, we will revise the “Effective Date” at the beginning of this Privacy Policy. If the changes to the Privacy Policy are material, we will notify you a notice within the Services or via email if we have your email address on file.