Changemaker Privacy Policy

This Changemaker Privacy Policy ("Privacy Policy") describes how All Digital Rewards, LLC ("ADR," "we," "us," or "our") collects, uses, shares, retains, and protects information when individuals access or use the Changemaker service ("Changemaker" or the "Service"). Changemaker is a product of ADR. Changemaker enables organizations to create workspaces and challenges that encourage participation, collaboration, continuous improvement, recognition, and rewards.

An organization that sponsors or makes Changemaker available to participants is referred to as a "Sponsor." A Sponsor may make Changemaker available directly through ADR or through an ADR channel partner (a "Program Partner"). A workspace may display Sponsor or Program Partner branding; unless otherwise stated in the workspace, Changemaker is operated by and powered by ADR. When ADR processes participant information to provide a Sponsor's program, ADR does so on the Sponsor's behalf and in accordance with the agreement governing that program, and the Sponsor (or, where the program is provided through a Program Partner, the Program Partner under its agreement with ADR) determines the purposes for which participant information is collected and used. This Privacy Policy should be read together with the Changemaker Terms of Use and any additional privacy notice, program rules, or terms provided by the Sponsor.

By accessing or using Changemaker, you acknowledge the practices described in this Privacy Policy. Where consent is required by applicable law, we will request consent in the manner required by law.

1. Information We Collect

Information You or Your Sponsor Provide

We may receive information directly from you or from the Sponsor administering your workspace or challenge. Depending on the configuration of the program, this may include:

• Name, email address, username, participant or employee identifier, and other account information.
• Workspace, organization, department, team, location, or other program-related attributes provided by you or the Sponsor.
• Challenge enrollment and participation information.
• Activity responses, survey or quiz responses, suggestions, ideas, comments, feedback, attachments, and other content you submit through Changemaker.
• Files you upload to show completion of an activity, such as photos, documents, or receipts or other proof of purchase, where a challenge requires them. Please do not upload information about other people, or sensitive information that the activity does not require.
• Points, recognition, badges, completion status, reward eligibility, and redemption-related information.
• Leaderboard rankings, standings, and recognition-feed activity associated with your account.
• Health, wellness, and fitness information that you submit or that a wellness challenge is configured to collect, such as activity logs, step counts, goal progress, or completion of wellness activities (see Section 6).
• Communications and support requests you send to us.

Information Collected Automatically

When you use Changemaker, we may automatically collect technical and usage information such as IP address, browser type, device information, operating system, login activity, pages or features accessed, timestamps, and other information used to operate, secure, troubleshoot, and improve the Service. We may use cookies and similar technologies for authentication, preferences, security, analytics, and Service functionality. See Section 7 for more information, including our use of Google Analytics.

Open or Public Workspace Registration

Certain Sponsors may permit individuals to register for a workspace through a Sponsor-specific or challenge-specific enrollment link. If you register in this manner, we collect the information needed to create and administer your account and provide access to eligible open-enrollment challenges. Registration in a workspace does not necessarily provide access to every challenge offered by that Sponsor.

Administrators, Business Contacts, and Website Visitors

If you administer Changemaker for a Sponsor or Program Partner, we collect your name, business contact information, role, and account activity to provide the Service, support the account, and communicate with you about the Service, including product updates. If you request a demo, contact us, or otherwise visit our website, we collect the information you provide and website usage information to respond to you and to send you information about ADR products and services. You may unsubscribe from ADR marketing emails at any time using the link in the email.

2. How We Use Information

We may use information collected through Changemaker to:

• Create, authenticate, maintain, and secure participant accounts and workspaces.
• Administer challenge enrollment, activities, submissions, collaboration, approvals, completion tracking, points, recognition, and rewards.
• Display leaderboards, standings, recognition feeds, and other social features configured by the Sponsor.
• Provide Sponsors with program administration, participation, outcome, and reporting information.
• Measure challenge participation, outcomes, and engagement, and support program improvement.
• Provide customer service and respond to questions or requests.
• Detect, investigate, prevent, and respond to fraud, abuse, security incidents, or violations of applicable terms.
• Maintain, troubleshoot, analyze, and improve Changemaker and ADR's services, including through de-identified or aggregated information.
• Comply with applicable legal, regulatory, contractual, audit, and recordkeeping obligations.
• Use information for other purposes disclosed to you at the time of collection or with your consent.

3. Sponsor Access, Participant Visibility, and Participant Submissions

Changemaker is generally provided on behalf of a Sponsor. Information about your participation may be available to authorized Sponsor personnel, including information you submit in activities or challenges, completion status, points, recognition, and program results. Participants should not submit information they do not want shared with the Sponsor or other authorized users where the applicable challenge or collaboration feature is designed to make that information visible.

The Sponsor determines its own internal use of information it receives through Changemaker. Sponsor use of information may also be governed by the Sponsor's privacy notices, policies, employment practices, program rules, or other terms.

3A. Information Visible to Other Participants

Changemaker includes social and recognition features, such as leaderboards, team standings, recognition feeds, comments, and collaboration spaces. Leaderboards display your full name together with your points, rank, badges, and completion status to other participants in the same workspace or challenge. Depending on how the Sponsor configures a workspace or challenge, other participants may also see your team or department, recognition you give or receive, and content you post to shared areas. This information is visible only to authorized users of that workspace and is not published to the general public.

For wellness challenges, leaderboards display points, rank, and completion status. They do not display the underlying health or wellness information you submit, such as step counts or activity logs, unless the challenge is configured to do so and you are notified before you participate.

4. How We Share Information

We may share information as necessary to operate and support Changemaker, including with:

• The Sponsor and authorized Sponsor administrators or managers for program administration, reporting, recognition, and measurement.
• Other participants in your workspace or challenge, as described in Section 3A.
• The Program Partner, if any, through which the Sponsor's program is provided, for program administration, support, and reporting.
• Service providers that perform functions on our behalf, such as hosting, communications, analytics, security, support, reward fulfillment, and related technology services.
• Reward suppliers or fulfillment providers when information is necessary to deliver a reward selected or earned by a participant.
• Third-party applications, integrations, or AI agents that you or your Sponsor authorize to connect to Changemaker. Information a connected tool retrieves is governed by that provider's terms and privacy practices.
• Government authorities, regulators, courts, or other parties when disclosure is required by law or reasonably necessary to protect rights, safety, security, or the integrity of the Service.
• A successor or acquiring entity in connection with a merger, acquisition, reorganization, financing, sale of assets, or similar business transaction.

We may create and use de-identified or aggregated information to operate, analyze, and improve Changemaker and ADR's services. We will not attempt to re-identify de-identified information except as permitted by law.

We do not sell personal information and do not share personal information for cross-context behavioral advertising. We do not use the content you submit through Changemaker to train artificial intelligence models.

5. Rewards and Marketplace Services

A Changemaker program may allow participants to earn points or other recognition that can be redeemed through an employee or rewards marketplace. When you access a separate reward redemption service, additional terms, privacy notices, supplier terms, cardholder or accountholder agreements, or program rules may apply. Changemaker participation and reward redemption may therefore be governed by different or additional terms. If a reward requires tax reporting, any tax identification information is collected and handled through the reward redemption service under its own terms and privacy notices, not through Changemaker.

6. Health and Wellness Information

Some Sponsor programs include wellness challenges, such as fitness, activity, nutrition, or well-being activities. In those programs, Changemaker may collect health or wellness information that you submit or that the challenge is configured to collect.

We use health and wellness information only to administer the applicable challenge, validate completion, award points or rewards, and provide Sponsor reporting as configured for the program. We do not sell health and wellness information or use it for advertising.

Unless the program is configured otherwise and you are notified in advance, Sponsor reporting for wellness challenges is limited to participation, completion, and points information and does not include the underlying health details you submit. The same limit applies to what other participants see on leaderboards, as described in Section 3A.

Where required by applicable law, we will obtain your consent before collecting or sharing health information. If a Sponsor's program is offered by or on behalf of a group health plan or another entity subject to HIPAA, the handling of protected health information is governed by the applicable agreement with that entity and its privacy notices. Questions about how a Sponsor uses wellness program results should be directed to the Sponsor.

7. Cookies and Similar Technologies

We may use cookies and similar technologies to maintain sessions, authenticate users, remember preferences, protect the Service, understand usage, and support Service functionality. Browser settings may allow you to limit certain cookies, but disabling required cookies may prevent portions of Changemaker from functioning properly.

We use Google Analytics to understand how our website and the Service are used. Google Analytics uses cookies to collect information such as pages visited, time on page, and device and browser information. We do not use Google Analytics advertising features, and we do not send names, email addresses, or health or wellness information to Google Analytics. You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout.

Some browsers offer a "Do Not Track" setting. Because there is no common industry standard for responding to these signals, the Service does not currently respond to Do Not Track signals. Because we do not sell personal information or share it for cross-context behavioral advertising, there is no sale or sharing to opt out of, and we treat Global Privacy Control signals consistent with that practice.

8. Communications

We send service communications on behalf of the Sponsor, such as account setup, challenge invitations, reminders, approval notices, and reward notifications. Because these messages are part of the program, you generally cannot opt out of them while participating, though you may be able to adjust notification preferences in your account settings.

We do not use participant information to send ADR marketing communications. If a program offers text messages, we will obtain consent where required by law. You may reply STOP to opt out or HELP for help. Message and data rates may apply. Message frequency varies by program. Mobile numbers and text message opt-in information are not shared with third parties or affiliates for their marketing or promotional purposes.

9. Data Retention

We retain personal information for as long as reasonably necessary to provide the Service, administer the applicable program, satisfy Sponsor instructions and the agreement governing the program where applicable, and meet legal, regulatory, tax, audit, security, dispute-resolution, and other legitimate business requirements. Retention periods may vary by record type and program. When information is no longer required, it may be deleted, de-identified, or otherwise disposed of in accordance with applicable requirements and our retention practices. When a Sponsor's program or agreement ends, participant information is deleted, returned, or de-identified as provided in the governing agreement, subject to any retention required by law.

10. Privacy Rights and Choices

Depending on your location and applicable law, you may have rights concerning your personal information, which may include rights to request access, correction, deletion, restriction, portability, or information about certain processing or disclosures. Some requests may need to be directed to the Sponsor when the Sponsor controls the applicable information or determines how it is processed.

Requests may be submitted to compliance@alldigitalrewards.com or (866) 415-7703. We may need to verify your identity before completing a request, and certain information may be retained where permitted or required by law. You may use an authorized agent to submit a request where permitted by law. We will not discriminate against you for exercising your privacy rights. We will respond within the time required by applicable law. If we decline your request, you may appeal by replying to our response or contacting us at the address above, and we will respond to your appeal as required by applicable law. This Privacy Policy is available in an accessible format on request.

11. Security

We use technical, administrative, and organizational safeguards designed to protect information against unauthorized access, use, alteration, disclosure, destruction, or loss. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for protecting your password and account credentials and for promptly reporting suspected unauthorized account access.

12. Age Requirement

Changemaker is intended only for individuals 18 years of age or older. We do not knowingly collect personal information from individuals under 18. If we learn that we have collected personal information from an individual under 18, we will delete it and close the associated account.

13. United States Only

Changemaker is offered only in the United States and is intended for use by individuals located in the United States. Information is stored and processed in the United States.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The updated version will be posted with a revised effective date or otherwise communicated as required by applicable law. If we make material changes, we will provide notice through the Service or by email before they take effect. Your continued use of the Service after an update is subject to the updated Privacy Policy.

15. Contact Us

For questions or concerns about this Privacy Policy or Changemaker privacy practices, contact:

All Digital Rewards, LLC

7272 E. Indian School Rd., Suite 540, Scottsdale, AZ 85251

Privacy/Compliance: compliance@alldigitalrewards.com | (866) 415-7703

Participant Support: support@changemaker.im