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Tier Rewards Privacy Policy

Effective Date: August 21, 2026

This Privacy Policy describes how Comp Trading LLC, operator of the Tier Rewards platform (“Comp Trading,” “Tier Rewards,” “we,” “us,” or “our”), collects, uses, discloses, and protects personal information in connection with the Tier Rewards website, software platform, redemption experiences, applications, customer support, and related services (collectively, the “Services”).

Tier Rewards is a product and service of Comp Trading LLC and is not a separate legal entity.

This Privacy Policy applies when you visit https://tierrewards.com, use a Tier Rewards redemption experience, communicate with us, receive or redeem a reward through Tier Rewards, or otherwise interact with the Services.

Certain Tier Rewards programs are offered on behalf of casinos, gaming operators, employers, promotional sponsors, or other organizations (“Program Sponsors”). Those organizations may separately collect and use personal information under their own privacy policies.

1. Information We Collect

The information we collect depends on how you interact with Tier Rewards.

Information You Provide to Us

We may collect information you voluntarily provide, including:

  • name;

  • email address;

  • telephone number;

  • mailing and shipping address;

  • account information;

  • reward or redemption information;

  • product selections;

  • order and fulfillment information;

  • customer-service communications;

  • information submitted through forms, surveys, or support requests; and

  • other information you choose to provide.

If payment is required for a particular transaction, payment information may be processed by us or by a third-party payment provider. We may not directly store complete payment-card information when payment processing is handled by a third party.

Information Provided by Program Sponsors

Casinos and other Program Sponsors may provide information to Tier Rewards in order to administer rewards, promotional programs, events, or redemption opportunities.

This information may include:

  • name or customer identifier;

  • player, loyalty, membership, or account identifier;

  • reward eligibility;

  • promotional or event eligibility;

  • reward tier or value;

  • redemption credentials or codes;

  • contact information;

  • fulfillment information; and

  • other information necessary to administer the applicable program.

The type of information provided depends on the Program Sponsor and the program being administered.

Information Collected Automatically

When you access the Services, we may automatically collect certain technical and usage information, including:

  • IP address;

  • browser type and version;

  • device type;

  • operating system;

  • referring and exit pages;

  • date and time of access;

  • pages and features viewed;

  • interactions with the Services;

  • approximate location derived from IP address;

  • log information; and

  • cookie or similar technology identifiers.

We may use cookies, pixels, log files, and similar technologies to operate, secure, analyze, and improve the Services.

2. How We Use Personal Information

We may use personal information to:

  • provide, operate, maintain, and improve Tier Rewards;

  • administer player gifting, loyalty reward, promotional, and redemption programs;

  • determine or validate reward eligibility based on information provided by a Program Sponsor;

  • process reward selections and orders;

  • source, ship, deliver, and fulfill products;

  • provide customer service and technical support;

  • communicate regarding orders, rewards, events, account activity, and the Services;

  • operate and secure accounts and redemption experiences;

  • prevent fraud, misuse, unauthorized access, and other prohibited activities;

  • diagnose technical problems and maintain system security;

  • understand usage and improve the functionality and performance of the Services;

  • comply with contractual obligations to Program Sponsors;

  • comply with legal and regulatory requirements;

  • establish, exercise, or defend legal claims; and

  • otherwise operate our business.

Where permitted by law, we may also use information to communicate with you about products, services, events, promotions, or other information that may be relevant to you.

You may opt out of marketing communications as described below.

3. Cookies and Similar Technologies

Tier Rewards may use cookies and similar technologies to:

  • keep the Services functioning properly;

  • remember preferences;

  • maintain sessions;

  • authenticate users;

  • protect against fraud and unauthorized access;

  • understand how users interact with the Services;

  • measure performance; and

  • improve the user experience.

You may be able to control cookies through your browser settings. Disabling certain cookies may affect the functionality of the Services.

4. How We Share Personal Information

We may disclose personal information in the following circumstances.

Program Sponsors

We may share information with the casino, gaming operator, employer, promotional sponsor, or other organization sponsoring the program in which you participate.

For example, we may provide a Program Sponsor with information concerning reward redemptions, order status, fulfillment, customer-service activity, or program administration.

Service Providers

We may share information with vendors and service providers that perform services on our behalf, including providers of:

  • cloud hosting and infrastructure;

  • product sourcing;

  • warehousing;

  • order fulfillment;

  • shipping and delivery;

  • payment processing;

  • email and communications;

  • customer support;

  • analytics;

  • fraud prevention;

  • information security; and

  • other technology or operational services.

We provide these parties with information only as reasonably necessary for them to perform services for us or in connection with the applicable Tier Rewards program.

Suppliers and Fulfillment Partners

Where necessary to fulfill a reward or product order, we may provide relevant information, including shipping information, to manufacturers, suppliers, distributors, fulfillment providers, or shipping carriers.

Legal and Safety Requirements

We may disclose personal information when we reasonably believe disclosure is necessary to:

  • comply with applicable law, regulation, court order, subpoena, or legal process;

  • respond to lawful governmental or regulatory requests;

  • enforce our agreements or policies;

  • investigate fraud or security incidents;

  • protect the rights, property, security, or safety of Comp Trading, Tier Rewards, our users, Program Sponsors, or others; or

  • establish, exercise, or defend legal claims.

Business Transactions

Personal information may be disclosed or transferred in connection with an actual or proposed merger, acquisition, financing, reorganization, sale of assets, corporate transaction, or similar business event involving Comp Trading.

5. Sale and Sharing of Personal Information

Comp Trading does not sell personal information for monetary compensation.

We may use analytics, advertising, or similar technologies that could be considered “sharing,” “targeted advertising,” or a “sale” under certain state privacy laws.

Where required by applicable law, you may have the right to opt out of such activities.

6. Data Security

We use administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, disclosure, alteration, destruction, loss, or misuse.

These measures may include access controls, authentication mechanisms, encryption, monitoring, security procedures, employee training, vendor controls, and other safeguards appropriate to the nature of the information being processed.

No system or method of transmission or storage can be guaranteed to be completely secure. Accordingly, we cannot guarantee the absolute security of personal information.

7. Data Retention

We retain personal information for as long as reasonably necessary to:

  • provide the Services;

  • administer the applicable rewards or promotional program;

  • fulfill orders and provide support;

  • comply with our agreements with Program Sponsors;

  • maintain appropriate business and transaction records;

  • meet legal, accounting, regulatory, and tax obligations;

  • resolve disputes;

  • prevent fraud and abuse; and

  • enforce our agreements.

Retention periods may vary depending on the type of information, the applicable Program Sponsor, contractual requirements, and applicable law.

When information is no longer reasonably necessary, we may delete, anonymize, or otherwise securely dispose of it.

8. Your Privacy Rights and Choices

Depending on where you live and applicable law, you may have certain rights regarding your personal information.

These may include the right to:

  • request access to personal information we maintain about you;

  • request correction of inaccurate personal information;

  • request deletion of personal information;

  • request information about the categories of personal information collected, used, or disclosed;

  • obtain a copy of certain personal information;

  • opt out of certain sales, sharing, or targeted advertising activities;

  • limit certain uses of sensitive personal information where applicable;

  • withdraw consent where processing is based on consent; and

  • appeal certain privacy-rights decisions where provided by law.

These rights are subject to exceptions and limitations under applicable law.

We may need to verify your identity before processing a privacy request.

If Tier Rewards is processing information solely on behalf of a Program Sponsor, we may direct your request to that organization where appropriate.

9. Marketing Communications

You may opt out of promotional or marketing emails by using the unsubscribe mechanism contained in the applicable communication or by contacting us.

Even if you opt out of marketing communications, we may continue to send non-promotional communications regarding transactions, rewards, orders, security, customer support, or other Service-related matters.

10. Information About Children

Tier Rewards is not intended to independently collect personal information from children under 13.

Our Services may be used in connection with family-oriented promotions administered by Program Sponsors. Where information concerning a minor is required for such a program, the Program Sponsor is responsible for establishing eligibility and obtaining any permissions required by applicable law.

If we learn that we have collected personal information from a child in violation of applicable law, we will take reasonable steps to delete it.

11. Third-Party Websites and Services

The Services may contain links to third-party websites, products, applications, or services.

Comp Trading does not control and is not responsible for the privacy practices, security, or content of third-party websites or services.

We encourage you to review the applicable third party's privacy policy before providing personal information.

12. Program Sponsor Privacy Practices

Tier Rewards frequently provides Services on behalf of casinos and other Program Sponsors.

A Program Sponsor may determine:

  • who is eligible for a reward;

  • what personal information is provided to Tier Rewards;

  • the purposes of a particular promotional program;

  • applicable eligibility rules; and

  • certain retention or reporting requirements.

In those circumstances, Comp Trading may process personal information at the direction of the Program Sponsor.

Questions relating specifically to a Program Sponsor's collection or use of personal information may need to be directed to that organization.

13. U.S. State Privacy Disclosures

Residents of certain U.S. states may have additional rights under state privacy laws.

Where applicable, those rights may include access, correction, deletion, portability, and the ability to opt out of certain uses or disclosures of personal information.

We will not unlawfully discriminate against an individual for exercising an applicable privacy right.

To submit a privacy request, contact us using the information below.

14. International Users

Tier Rewards is operated from the United States.

If you access the Services from outside the United States, information may be transferred to, processed, and stored in the United States or other jurisdictions where our service providers operate.

Data-protection laws in those jurisdictions may differ from those in your country of residence.

15. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes to our Services, business practices, legal requirements, or other circumstances.

When we make changes, we will update the effective date at the top of this Privacy Policy.

We encourage you to review this Privacy Policy periodically.

16. Contact Us

If you have questions about this Privacy Policy, our privacy practices, or would like to submit a privacy request, you may contact:

Comp Trading LLC
Operator of the Tier Rewards platform
2250 59th Street, 4th Floor
Brooklyn, NY 11204
Email: info@tierrewards.com

For privacy-related requests, please include enough information for us to reasonably identify you and understand your request.

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