This policy is effective as of and was last updated on March 21, 2017

BLOOM MASTERCARD PREPAID PROGRAM PRIVACY POLICY

Engage Financial Technology, Inc. ("Company") respects the privacy of its users whether accessing or using the www.mybloom.us website ("Website") or downloading and using the Bloom mobile application. The www.mybloom.us website and the Bloom mobile application are hereby referred to collectively as the Engage Financial Technology, Inc. Online Experience (“EFTOE”). The following Company privacy policy ("Privacy Policy") is designed to inform you, as a user of the EFTOE, about the types of information that our Company may gather about or collect from you in connection with your use of the EFTOE. It also is intended to explain the conditions under which our Company uses and discloses that information, and your rights in relation to that information.

Changes to this Privacy Policy are discussed at the end of this document. Each time you use the EFTOE, however, the current version of this Privacy Policy will apply. Accordingly, each time you use the EFTOE you should check the date of this Privacy Policy (which appears at the end of this document) and review any changes since the last time you used the site.

Children

The EFTOE is not intended for children under 13 years of age. Our Company does not knowingly collect personal information from children under 13.

Gathering, Use and Disclosure of Non-Personally-Identifying Information

Users of the EFTOE Generally

"Non-Personally-Identifying Information" is information that, without the aid of additional information, cannot be directly associated with a specific person.

"Personally-Identifying Information," by contrast, is information such as a name or email address that without more, can be directly associated with a specific person.

Like most website operators, our Company gathers from users of the EFTOE Non-Personally-Identifying Information of the sort that Web browsers depending on their settings may make available. That information includes the user's Internet Protocol ("IP") address, operating system and browser type and the locations of the Web pages that the user views immediately prior to accessing the EFTOE, while navigating the EFTOE and immediately after leaving the EFTOE.

Our Company analyzes Non-Personally-Identifying Information gathered from users of the EFTOE to help our Company better understand how the EFTOE is being used. By identifying patterns and trends in usage, our Company is able to better design the EFTOE to improve users' experiences, both in terms of content and ease of use. From time to time, our Company may also release the Non-Personally-Identifying Information gathered from EFTOE users in the aggregate such as by publishing a report on trends in the usage of the EFTOE.

Web Cookies

A "Web Cookie" is a string of information that a website stores on a user's computer, and that the user's browser provides to the website each time the user submits a query to the site. Our Company uses Web Cookies to track the pages that users visit during each EFTOE session, both to help our Company improve users' experiences and to help our Company understand how the EFTOE is being used.

As with other Non-Personally-Identifying Information gathered from users of the EFTOE, our Company analyzes and discloses in aggregated form information gathered using Web Cookies, so as to assist our Company, its partners and others better understand how the EFTOE is being used. Our Company does not attempt to link information gathered using Web Cookies to Personally-Identifying Information.

COMPANY USERS WHO DO NOT WISH TO HAVE WEB COOKIES PLACED ON THEIR COMPUTERS SHOULD SET THEIR BROWSERS TO REFUSE WEB COOKIES BEFORE ACCESSING THE WEBSITE, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF THE WEBSITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES. WEBSITE USERS WHO REFUSE WEB COOKIES ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY.

Web Beacons

"Web Beacon" is an object that is embedded in a web page that is usually invisible to the uses and allows website operators to check whether a user has viewed a particular web page. Our Company may use Web Beacons on the EFTOE to count users who have visited particular pages and to deliver co-branded services. Web Beacons are not used to access users' Personally-Identifying Information; they are a technique that our Company may use to compile aggregated statistics about EFTOE usage. Web Beacons collect only a limited set of information including a cookie number, time and date of a page view, and a description of the page on which the Web Beacon resides.

You may not decline Web Beacons, however, they can be rendered ineffective by declining all cookies or modifying your browser setting to notify you each time a cookie is tendered and permit you to accept or decline cookies on an individual basis. Third parties are not permitted to use Web Beacons on the EFTOE.

Collection, Use and Disclosure of Personally-Identifying Information

EFTOE Registration

As defined above, Personally-Identifying Information is information that can be directly associated with a specific person. Our Company collects a range of Personally-Identifying Information from and about EFTOE users. Much of the Personally-Identifying Information collected by our Company about users is information provided by users themselves at the time they sign up to submit materials for a EFTOE interactive program. That information includes each user's name, address, phone number, email address, social security number and date of birth. Transactional User data may also be saved for analysis and recommendations.

Users of the EFTOE are under no obligation to provide our Company with Personally-Identifying Information of any kind, with the caveat that a user's refusal to do so may prevent the user from using certain EFTOE features.

BY REGISTERING WITH THE WEBSITE, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY-IDENTIFYING INFORMATION AS DESCRIBED IN THIS "COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION" SECTION.

Online Forums and Blog

Certain Personally-Identifying Information collected from users is disclosed as a matter of course as a result of those users' use of the EFTOE. USERS ASSUME ALL RESPONSIBILITY FOR ANY LOSS OF PRIVACY OR OTHER HARM RESULTING FROM THEIR VOLUNTARY DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION.

DMCA Infringement Notifications, Notices of Violations of EFTOE Terms of Service and Other Communications Directed to our Company

By submitting a Copyright Infringement Notification or other communication (including communications about content stored on or transmitted through the EFTOE) you consent to have such communication forwarded to the person or entity who stored, transmitted or linked to the content addressed by your communication, in order to facilitate a prompt resolution. For Notices of Violations of EFTOE Terms of Service or other communications (but not DMCA Infringement Notifications), upon request our Company will edit out your name and contact information. However, DMCA Infringement Notifications (including any personally identifying information set forth in the Notifications) will be forwarded as submitted to our Company without any deletions.

Other Disclosures

As described in the previous sections titled "Collection, Use and Disclosure of Personally-Identifying Information," users may, at their option, disclose their own Personally-Identifying Information by any means they choose, including without limitation sharing transactional data with third party partners for special offers; our Company will disclose Personally-Identifying information under the following circumstances:

Contests, Giveaways and Surveys

From time to time, our Company may offer EFTOE users the opportunity to participate in contests, giveaways and other promotions. Any information submitted in connection with such activities will be treated in accordance with this Privacy Policy. From time to time, our Company may also ask EFTOE users to participate in surveys designed to help our Company improve the EFTOE. Any Personally-Identifying Information provided to our Company in connection with any survey will be used only in relation to that survey, and will be disclosed to third parties not bound by this Privacy Policy only in non-personally-identifying, aggregated form.

Email to Friends Feature and Referral Program

Our Company offers users the ability to send friends emails about the EFTOE. If users choose to use this feature, be assured that our Company only uses friends’ email addresses on a one-time basis to send the requested email.

Collection and Use of Information by Third Parties.

Generally

Our Company contractually prohibits its contractors, affiliates, vendors and suppliers from disclosing Personally-Identifying Information received from our Company other than in accordance with this Privacy Policy). Third parties are under no obligation to comply with this Privacy Policy, however, with respect to Personally-Identifying Information that users provide directly to those third panics or that those third patties collect for themselves. Our Company neither owns nor controls the third-party websites accessible through the EFTOE. Thus, this Privacy Policy does not apply to information provided to or gathered by the third parties that operate them. Before visiting a third-party, whether by means of a link on the EFTOE or otherwise, and before providing any Personally-Identifying Information to any third party, users should inform themselves of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in those users' discretion, protect their privacy.

Privacy Policy Changes

Our Company may, in its sole discretion, change this Privacy Policy from time to time. Any and all changes to our Company's Privacy Policy will also be reflected on this page. Unless our Company obtains your express consent, any revised Privacy Policy will apply only to information collected after such time as the revised Privacy Policy takes effect, and not to information collected under any earlier Privacy Policies. Our Company encourages visitors to frequently check this page for any changes to its Privacy Policy.