ROVE MILES PRIVACY POLICY

1.1 Purpose of this Policy

This Policy describes the data collection and privacy practices that apply when you interact with Rove Miles in any manner, including visiting our website, using our mobile applications, booking travel services, or participating in our rewards program.

1.2 Platform & Services

This Policy applies only to the Rove platform and related services that we control and operate. It does not apply to any third-party services, partner platforms, or external websites that may be linked within Rove Miles.

1.3 Acceptance of this Policy

By using our platform or creating an account with Rove, you expressly acknowledge and agree to the practices described in this Policy. If you do not consent to these practices, do not use our platform.

2.1 Account & Personal Information

When you register or use Rove Miles, we may collect:

• Full name
• Title
• Email
• Date of birth
• Password
• Phone number
• Country of residence
• IP address
• Invite code or source of referral (if applicable)
• Home airport (if applicable)
• Destinations (if applicable)

2.2 Travel & Preferences Data

To enhance your travel bookings and rewards experience, we collect:

• Wishlist items (e.g., saved flights, destinations)
• Search history and booking intentions (e.g., previously viewed travel routes)

2.3 Third-Party Integrations & Linked Accounts

If you choose to link or integrate third-party services with your Rove account, we may collect:

• OAuth or login credentials from providers such as Google, Apple, or other social logins
• Airline loyalty program numbers and status levels where applicable
• Other partner rewards program account details

Note: Data collected from third-party integrations is subject to both this Policy and the privacy terms of the third-party service. We encourage you to review those policies as well.

4.1 No Sale of Personal Data

We do not sell your personal data to third parties for monetary or other valuable consideration.

4.2 Service Providers & Partners

We may share your data with:

• Partner travel providers to facilitate flight, hotel, or travel bookings and redemptions.
• Third-party service providers who assist with our operations (e.g., payment processors, fraud detection services, data analytics).
• Partner rewards programs or other providers involved in the accrual of miles on your account.

4.3 Legal Compliance & Protection

We may disclose personal data if required by law or in good-faith belief that such action is necessary to:

• Comply with legal obligations or respond to lawful requests from public authorities.
• Protect our rights, privacy, safety, or property, and that of our users or the public.

4.4 Business Transfers

In the event of a merger, acquisition, or sale of all or a portion of our assets, user data may be transferred to the acquiring entity. We will strive to ensure the acquiring entity upholds privacy practices that are consistent with this Policy.

4.5 Mobile Information

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

5.1 Use of Cookies

We utilize cookies, web beacons, and similar technologies to:

• Enable essential site features and maintain session data (e.g., user login).
• Analyze site traffic and usage patterns to improve our platform.
• Personalize marketing and promotional content based on user interests.

5.2 Managing Cookies

You can manage your cookie preferences through your browser settings. Disabling certain cookies may impact the functionality or availability of some platform features.

5.3 Analytics & Advertising

We may partner with analytics providers and advertising networks that use tracking technologies to collect information about your online activities over time. These third parties may have their own privacy policies governing their use of such information.

7.1 Security Measures

We implement industry-standard security measures designed to protect your data from unauthorized access, alteration, disclosure, or destruction. These measures include encryption, firewalls, and secure server hosting.

7.2 User Responsibility

You are responsible for maintaining the confidentiality of your account credentials and taking appropriate steps to protect against unauthorized access to your devices or accounts.

7.3 No Liability for Third-Party Breaches

While we strive to safeguard your information, no security system is foolproof. We are not responsible for data breaches or unauthorized activities that occur on third-party systems outside of our control.

8.1 Retention Period

We retain personal data for as long as it is necessary to:

• Fulfill the purposes outlined in this Policy.
• Provide our services and ensure the functionality of the Rove Miles platform.
• Comply with legal obligations (e.g., tax, accounting, auditing).

8.2 Deletion Requests

If you wish to delete your account or request that we no longer use your data, please contact us as described in Section 11. We may retain certain data for legitimate business purposes or as required by law.

9.1 Applicable Laws

We comply with applicable U.S. data protection and privacy laws, including relevant provisions of the California Consumer Privacy Act (CCPA), if and to the extent it applies to Rove Miles.

9.2 CCPA Rights (If Applicable)

If you are a California resident, you may have additional rights under the CCPA, such as the right to know and the right to request deletion of certain personal data. We provide these rights consistent with the legal requirements. For more information, please contact us as described below.

10.1 Right to Modify

We may update or modify this Policy at any time to reflect changes in our practices or applicable laws. If we make any material changes, we will notify you by email (if you have provided one) or through a prominent notice on our website.

10.2 Acceptance of Changes

By continuing to use our platform after any revised Policy has been posted, you accept and agree to the updated terms.

11.1 Privacy Inquiries & Requests

If you have questions about this Policy, wish to exercise any of your privacy rights, or have concerns about our data practices, please contact us using the information below:

• Email: support@rovemiles.com
• Mail: Rove Card Inc, Attn: Legal Department, 250 Greenwich St, 39th Floor, New York, NY 10007

11.2 Response Time

We will respond to legitimate requests and inquiries within a reasonable timeframe, typically within 30 days or as otherwise required by applicable law.