Privacy Policy

This Pointer Privacy Policy (“Privacy Policy”) describes the types of information Pointer Group Inc. and any of its subsidiaries or affiliates (collectively, “Pointer,” “we,” “us,” or “our”) collects, uses, and shares about you when you visit or use our mobile application(s) and our website www.joinpointer.com (the “Site”) and all related websites, products, services, features, tools, web applications, and content offered by Pointer, or when you otherwise contact or interact with us (collectively, the “Services”). The terms “you” and “your” refer to you, the user. This Privacy Policy also explains how Pointer may use and share your Personal Information (as defined in Section 1), as well as the choices available to you. By using or continuing to use the Services, you acknowledge you have read, understand, and agree to the collection, storage, use, and disclosure of your Personal Information as described in this Privacy Policy, and you agree to our Terms of Service, which are incorporated by reference. If you do not agree, do not access or use the Services. If you choose to access or use the Services, your access and use, and any dispute over privacy, is subject to this Privacy Policy and our Terms of Service, including limitations on claims and damages and resolution of disputes. Eligibility to Use the Services To use the Services, you must be at least eighteen (18) years of age. Users under eighteen (18) years of age are not permitted to create an account or use the Services in any capacity.

Generally, we collect four (4) types of information about you: (A) information and content you give us directly; (B) information we obtain automatically when you use our Services; (C) information we get about you from other sources; and (D) demographic information. When we talk about “Personal Information” in this Privacy Policy, we are talking about any information collected in accordance with this section. Please see below for more information on each category.

A. Information and Content You Give Us Directly

(i) Personal and Profile Information. Personal information such as your name, email address, username, password, date of birth, bio, profile photo, location, travel destination, categories of expertise or interest, pricing preferences, availability settings, and any other information you directly provide on or through the Services when creating or updating your account. You may also provide optional profile and preference information, such as gender and matching or compatibility preferences.

(ii) Recommendation Request Content. Information you provide when submitting a recommendation request, including what you are looking for, your location or travel destination, budget, timing, personal preferences, what you want to avoid, who the recommendation is for, and any other context you share to help a Pointer provide a better recommendation.

(iii) Messages, Communications and User Content. Messages exchanged between Pointees and Pointers as part of the recommendation request and response process, including follow-up messages where permitted. Photos, voice notes, and other content shared through the Services. Records and copies of your email messages together with your email address and our responses, if you choose to correspond with us through email. We may access, review, and moderate user messages, photos, voice notes, recommendation requests, recommendation responses, and related communications where necessary for support, safety, fraud prevention, dispute resolution, refunds, enforcement of our Terms of Service, legal compliance, and platform integrity.

(iv) Transaction Information. We or service providers working on our behalf may collect information and details about any purchase, payment, payout, tip, refund, or other transaction made on or through the Services. This includes payment information such as your credit or debit card number and other card information; other account and authentication information; and billing and contact details. We do not collect or store payment card information ourselves; rather, we rely on third-party payment processors (e.g., Stripe) to store and process this information as part of the Services.

(v) Feedback and Ratings. Information you provide when leaving feedback, star ratings, or other evaluations following a recommendation interaction. Star ratings are kept private and are not publicly displayed.

(vi) Support Communications. Information you provide when you contact our support team, submit a report, or communicate with us regarding your account or the Services.

B. Information We Obtain Automatically When You Use Our Services

(i) Activity Information. Details of your visits to our Services, including the types of content you view or engage with; the features you use; the actions you take; the Pointers or Pointees you interact with; recommendation requests submitted, completed, or abandoned; response times; completion rates; the time, frequency, and duration of your activities; and other information about your use of and actions on the Services.

(ii) Pointer Status and Performance Data. For Pointers, we automatically collect and calculate performance metrics used to determine Pointer Status levels (Standard, Pro, Legend, Icon, and Platinum), including completed recommendation requests, response speed, feedback scores, repeat interactions, refund rates, dispute history, complaints, account activity, profile quality assessments, and category expertise indicators and other platform activity.

(iii) Equipment Information. Information about your computer, mobile device, and internet connection, including your device or computer operating system, IP address, browser type, browser language, device identifiers, and mobile network information.

(iv) Location Information. Information about the location of your device, including GPS location, for purposes of enhancing or facilitating the Services, such as matching Pointees with relevant Pointers based on geographic proximity or the location relevant to a recommendation request. If you do not want to share your precise location, you can disable location sharing in the settings on your device.

(v) Cookies, Pixel Tags/Web Beacons, and Other Technologies. Cookies, pixel tags, web beacons, clear GIFs, JavaScript, entity tags, HTML5 local storage, resettable device identifiers, or other similar technologies (collectively, the “Technologies”) may be used by us, as well as third parties that provide content, advertising, or other functionality on the Services, to automatically collect information through your use of the Services. Please see Section 8 for more information on the Technologies we may use for this automatic data collection.

C. Information We Get About You from Other Sources We may receive information about you from other sources and add it to our information, including from third-party services and organizations who have the right to provide us with such information. We protect this information according to the practices described in this Privacy Policy, plus any additional restrictions imposed by the source of the data. These sources may include: publicly available sources such as open government databases or social networks; service providers who provide us with information and updates to that information based on their relationship with you; identity verification providers; payment processors who provide transaction status or verification information; analytics providers; and users who interact with the Services. By gathering additional information about you, we can correct inaccurate information, enhance the security of your transactions, and give you product or service recommendations and special offers that are more likely to interest you.

D. Demographic Information We may collect demographic, statistical, or other aggregate information that is about you but individually does not identify you. Some of this information may be derived from Personal Information, but it is not Personal Information and cannot be tied back to you. Examples of such aggregate information include age range, general geographic region, and category interests. We may use aggregated, de-identified, or anonymized data to analyze trends, category demand, user engagement, matching quality, recommendation performance, advertising or sponsored content performance, platform growth, safety, and product improvement.

We may use the information we collect about you in a variety of ways, to provide our Services, for administrative purposes, and to market and advertise our Services and products.

A. We Use Your Personal Information to Provide Our Services We may use your Personal Information to:

(i) Provide the Services and their content to you, including operating and maintaining the recommendation marketplace.

(ii) Match Pointees with relevant Pointers based on category, location, interests, availability, profile information, pricing, and other relevant signals.

(iii) Facilitate recommendation request submissions, Pointer responses, and follow-up communications between Pointees and Pointers.

(iv) Process payments, payouts, tips, refunds, and other transactions through third-party payment processors.

(v) Evaluate and calculate Pointer Status levels (Standard, Pro, Legend, Icon, and Platinum) based on performance metrics, quality indicators, feedback, and trust signals.

(vi) Respond to comments, questions, reports, and provide customer service.

(vii) Communicate with you about your account, transactions, and important changes to the Services.

(viii) Fulfill any other purpose for which you provide Personal Information.

B. We Use Your Information for Administrative Purposes We may use your Personal Information to:

(i) Operate, maintain, improve, personalize, and analyze the Services.

(ii) Evaluate quality, trust, and safety, including through internal ratings, feedback analysis, and performance metrics.

(iii) Enforce platform rules, community standards, and policies, including investigating conduct that may violate those rules.

(iv) Investigate safety concerns, including inappropriate conduct, harassment, fraud, and other harmful behavior.

(v) Detect, prevent, or investigate security breaches, fraud, spam, manipulation of platform systems, and other unauthorized or illegal activity.

(vi) Review messages, photos, voice notes, recommendation content, and platform activity when necessary to operate the service, resolve disputes, process refunds, enforce policies, investigate safety concerns, prevent fraud, maintain platform quality, or comply with legal obligations.

(vii) Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

(viii) Maintain appropriate records for internal administrative purposes.

(ix) Improve our matching algorithms, recommendation quality tools, and platform features. Note: Pointer is built around human recommendations and personal judgment, not AI-generated content. Any algorithmic tools are used to facilitate connections between Pointees and Pointers, not to replace human recommendations.

C. We Use Your Information to Communicate About Our Services We may use your Personal Information to: i. Send transactional communications, such as order confirmations, request notifications, response alerts, payment confirmations, and payout updates. ii. Send promotional communications, such as information about features, newsletters, offers, promotions, and events. iii. Develop, test, and improve new products or services, including by conducting surveys and research and testing and troubleshooting new products and features. iv. Personalize your experience, including providing content, recommendations, offers, sponsored content, and advertising that may be relevant to you based on your profile, preferences, activity, and interactions on the Services.

We may share or disclose aggregated or anonymized information about our users to third parties for a variety of business purposes without restriction, including to provide our Services and/or to protect us or others. We may also share or disclose information in the event of a major business transaction such as a merger, sale, or asset transfer. The following circumstances describe in additional detail the ways we may share or disclose your Personal Information that we collect or that you provide under this Privacy Policy:

A. We Disclose Your Information to Provide Our Services

(i) Between Pointees and Pointers. When a Pointee submits a recommendation request, certain information (such as the Pointee’s request content, preferences, and relevant profile information) is shared with the selected Pointer to facilitate the recommendation. Similarly, Pointer profile information (such as name, bio, categories, and pricing) is visible to Pointees. Star ratings are not shared with Pointers or publicly displayed.

(ii) Payment Processors. We share your Personal Information with third-party payment processors (e.g., Stripe) to facilitate payments, payouts, tips, refunds, identity verification, tax reporting, and other financial transactions related to the Services.

(iii) Subsidiaries and Affiliates. We may share your Personal Information with our parent companies, subsidiaries, joint ventures, and affiliated companies for purposes of management and analysis, decision-making, and other business purposes, consistent with this Privacy Policy.

(iv) Service Providers. We may share your Personal Information with our third-party service providers, contractors, and any other similar third parties that help us provide our Services. This may include service providers that help us with analytics services, website and app hosting, email delivery, safety and content moderation, customer support, location services, and product and service delivery. Service providers are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.

(v) Consent or to Fulfill the Purpose that Information was Provided. We may share your Personal Information to ful fill the purpose for which you provide that information, with your consent, or for any other purpose disclosed by us when you provide the information.

(vi) Improvement of Artificial Intelligence (“AI”). We may share your Personal Information with our third-party service providers of products, features, and/or tools powered by AI, machine learning, or similar technologies to assess, develop, improve, train, and exchange predictive/generative modeling and data analytics for purposes of improving outcomes. For example, we may use your Personal Information as a part of a data set that will be used to improve the accuracy of our product outcomes predictive/generative modeling algorithms (e.g., AI search functionality).

B. We May Disclose Your Information in the Event of a Merger, Sale, or Other Asset Transfers If we become involved in a merger, acquisition, financing due diligence, divestiture, restructuring, reorganization, bankruptcy, dissolution, sale, or transfer of some or all of our assets (whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding), or transition of Services to another provider, your Personal Information may be sold or transferred to business entities or people involved in such process.

C. We Disclose Your Information to Protect Us or Others

(i) When Required by Law. We may share your Personal Information to comply with any court order, law, or legal process, including to respond to any government or regulatory request.

(ii) To Enforce Our Rights. We may share your Personal Information to enforce or apply this Privacy Policy, our Terms of Service, and other agreements, including for billing and collection purposes.

(iii) To Protect Lawful Interests. We may share your Personal Information if we believe disclosure will help us protect the rights, property, or safety of Pointer, our users, partners, agents, and others. This includes exchanging information with other companies and organizations for fraud protection and spam and malware prevention.

(iv) To Protect Users and Others. We may disclose Personal Information when we believe in good faith that disclosure is necessary to protect the safety of users of the Services or others, including sharing information with law enforcement or other appropriate authorities.

You have certain choices and rights with respect to your privacy. For example, you may be able to opt out of receiving marketing messages from us, make choices regarding cookies, and exercise other privacy rights under applicable law.

A. Mechanisms to Control Your Information

(i) Cookies and Other Tracking Technologies. You may be able to set your browser to reject cookies and certain other technologies by adjusting the appropriate settings in your browser. Each browser is different, but many common browsers have preferences that may be adjusted to allow you to either accept or reject cookies and certain other technologies before they are set or installed, or allow you to remove or reject the use or installation of certain technologies altogether. We recommend that you refer to the “Help” menu in your browser to learn how to modify your browser settings. If you disable or refuse cookies, please note that some parts of the Services may become inaccessible or may not function properly.

(ii) Communications from Pointer. If you do not wish to have your contact information used by Pointer to promote our own products or services, you can opt out by: (1) informing us of your preference at the time you sign up for your Services account (if applicable); (2) modifying your user preferences in your account profile by checking or unchecking the relevant boxes (if applicable); (3) following the opt-out instructions at the bottom of the promotional emails or text messages we send you; or (4) sending us an email at hello@joinpointer.com stating your request. Please note that we may also send you non-promotional communications (e.g., transactional communications, including emails about your account, recommendation requests, payments, and updates to this Privacy Policy and the Terms of Service), and you will not be able to opt out of these communications.

(iii) “Do Not Track”. “Do Not Track” (“DNT”) is a privacy preference you can set in certain web browsers. When you turn on this preference, it sends a signal or message to the websites you visit indicating that you do not wish to be tracked. Please note that we currently do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the  Network Advertising Initiative, the Digital Advertising Alliance , the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.

B. Accessing and Correcting Your Information In accordance with applicable law, you may have the right to:

(i) Access Personal Information. You may access Personal Information about you, including: (1) confirming whether we are processing your Personal Information; (2) obtaining access to or a copy of your Personal Information; and (3) receiving an electronic copy of Personal Information that you have provided to us, or asking us to send that information to another company (the “right of data portability”).

(ii) Request Correction of Personal Information. You may request correction of your Personal Information where it is inaccurate, incomplete, or improperly possessed.

(iii) Request Deletion/Erasure of Personal Information. You may request deletion/ erasure of your Personal Information held by us about you. Please note: we cannot delete your Personal Information except by also deleting your account. Additionally, deletion requests may be subject to legal, financial, fraud-prevention, dispute- resolution, safety, and recordkeeping requirements as described in our Terms of Service.

(iv) Restrict/Opt-out of Processing. You may request to restrict or opt out of the processing of your Personal Information, including for the purpose(s) of: (1) targeted advertising; (2) sale or sharing of personal information; or (3) pro filing to make decisions that have legal or other significant effects on you.

(v) Withdraw Consent. You may have the right to withdraw consent where such consent is required to share or use Personal Information. If you would like to exercise any of these rights, you may send us an email at hello@joinpointer.com to request access to, correction of, or removal of any Personal Information that you have provided to us. We will process such requests in accordance with applicable law. The following are additional consumer privacy rights:

(vi) Non-Discrimination. Residents have the right not to receive discriminatory treatment by covered businesses for the exercise of their rights conferred by the applicable privacy law.

(vii) Verification. To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative, which may include asking you to answer questions regarding your account and use of our Services.

C. State-Specific Privacy Rights A number of states require us to provide residents of those states with additional information and rights. Please see the California Privacy Notice, Multi-State Privacy Notice, and Nevada Privacy Notice below for state-specific disclosures and rights.

D. Your Right to Appeal If you are dissatisfied with the refusal of Pointer to take action in accordance with the exercise of your rights in the “Accessing and Correcting Your Information” section above, you may request reconsideration by Pointer by sending a written request for reconsideration to hello@joinpointer.com. Within sixty (60) days (or such shorter period of time as required by applicable law) of Pointer’s receipt of such written request, Pointer shall inform you in writing of any action taken or not taken in response to your request for reconsideration, including a written explanation of the reasons for the decision. In addition, if your request for reconsideration is denied, you have the right to appeal to the applicable supervisory authority in your jurisdiction of residence. E. Complaints to Data Protection Authority You have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

We have implemented safeguards reasonably designed to secure your Personal Information. Such safeguards include the implementation of various technical, physical, administrative, and organizational security measures intended to reduce the risk of loss, misuse, unauthorized access, disclosure, or modification of your information. All information you provide to us is stored on our secure servers behind firewalls. The safety and security of your information is also dependent on you. If we have given you (or where you have chosen) a password for access to certain parts of the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. While we have employed security technologies and procedures to assist safeguarding your Personal Information, no system or network can be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

If you provide Personal Information through the Services, you acknowledge and agree that such Personal Information may be transferred from your current location to the offices and servers of Pointer and the other third parties referenced in this Privacy Policy located in the United States and other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of such laws, where applicable.

We keep your information for the length of time needed to carry out the purposes outlined in this Privacy Policy and to adhere to our policies on keeping records (unless a longer period is needed by law). Our records policies reflect applicable laws. We will retain and use your information to the extent necessary to manage your relationship with us, personalize and improve your overall experience, and to comply with our legal obligations. Where we retain data, we do so in accordance with our record retention policies and any limitation periods and records retention obligations that are imposed by applicable law.

A. Description of the Technologies We, as well as third parties that provide the content, advertising, or other functionality on the Services, may use Technologies to automatically collect information through your use of the Services. The following describes some of these Technologies we may use for this automatic data collection:

(i) Cookies. A cookie is a small data file stored on the hard drive of your computer either for (1) the duration of your visit on a website (“session cookies”) or (2) for a fixed period (“persistent cookies”). Cookies contain information that can later be read by a web server. We may use cookies to provide you with a more personal and interactive experience on the Services.

(ii) Web Beacons. Web beacons are small files that are embedded in webpages, applications, and emails (also known as “clear gifs”, “pixel tags”, “web bugs”, and “single-pixel gifs”) that collect information about engagement on our Services.

(iii) JavaScripts. JavaScripts are code snippets embedded in various parts of websites and applications that facilitate a variety of operations including accelerating the refresh speed of certain functionality or monitoring usage of various online components.

(iv) Entity Tags. Entity Tags are HTTP code mechanisms that allow portions of websites to be stored or “cached” within your browser and validates these caches when the website is opened, accelerating website performance.

(v) HTML5 Local Storage. HTML5 local storage allows data from websites to be stored or “cached” within your browser to store and retrieve data in HTML5 pages when the website is revisited.

(vi) Resettable Device Identifiers. Resettable device identifiers (also known as “advertising identifiers”) are similar to cookies and are found on many mobile devices and tablets, and certain streaming media devices. Like cookies, resettable device identifiers are used to make online advertising more relevant.

B. Our Uses of the Technologies We may also use these Technologies for security purposes, to facilitate navigation, to display information more effectively, and to better serve you with more tailored information, as well as for Site administration purposes (e.g., to gather statistical information about the usage of the Site in order to continually improve the design and functionality), to understand how users use the Site, and to assist us with resolving questions regarding use of the Site.

C. Mechanisms to Control Cookies and Other Technologies You may be able to set your browser to reject cookies and certain other technologies by adjusting the appropriate settings in your browser. Each browser is different, but many common browsers have preferences that may be adjusted to allow you to either accept or reject cookies and certain other technologies before they are set or installed, or allow you to remove or reject the use or installation of certain technologies altogether. We recommend that you refer to the “Help” menu in your browser to learn how to modify your browser settings. ’If you disable or refuse cookies, please note that some parts of the Services may become inaccessible or may not function properly.

D. Third-Party Technologies This Privacy Policy covers the use of cookies by Pointer and does not cover the use of tracking technologies by any third parties. The Services may contain links, content, advertising, or references to other websites or applications run by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies or other tracking technologies to collect information about you when you interact with their content on the Services. The information they collect may be associated with your Personal Information or they may collect information about your online activities over time and across different websites. Please be aware that we do not control these third parties’ tracking technologies or when and how they may be used. Therefore, Pointer does not claim nor accept responsibility for any privacy policies, practices, or procedures of any such third party. We encourage you to read the privacy statements and terms and conditions of linked or referenced websites you enter. We do not endorse, screen, or approve, and are not responsible for the practices of such third parties or the content of their application or website. Providing Personal Information to third-party websites or applications is at your own risk. If you have any questions about an ad or other targeted content, you should contact the responsible provider directly. E. Google, Meta, and Other Analytics The Services may use Google Analytics, Meta Pixel, and other analytic service providers, which use cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. These services may also collect information regarding the use of other websites, apps, and online resources. You can learn about Google’ practices by going to www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/ dlpage/gaoptout. You can learn about Meta’s practices by going to https://www.facebook.com/ privacy/center/.

The Services are not directed to, and Pointer does not knowingly collect personal information from, anyone under the age of eighteen (18). Users under eighteen (18) are not permitted to create an account or use the Services under any circumstances. No Collection from Users Under 13 Pointer does not knowingly collect personal information from children under the age of thirteen (13) (“Child” or “Children”). Users under 13 are not permitted to create an account or use the Services under any circumstances. If we learn that we have inadvertently collected or received Personal Information from a Child under 13 without veri fied parental consent, we will use reasonable efforts to immediately delete such information, unless we have a legal obligation to retain it. If you are a parent or legal guardian and believe your Child under 13 has provided us information without your consent, please contact us immediately via the information in the “Contact Information” section below.

We reserve the right to update this Privacy Policy from time to time in order to reflect changes to our practices or for other operational, legal, or regulatory reasons. When we do update this Privacy Policy, we will post the updates and changes on the Site. We may elect to notify you of material changes by mail, email, posting of the modified Privacy Policy, or some other similar manner. However, it is your responsibility to check the Site regularly for changes to this Privacy Policy. Your continued use of or access to the Services following the posting of any changes to this Privacy Policy constitutes acceptance of those changes.

Our Services may offer links to websites or applications that are not run by us but by third parties. These third-party services, websites, or applications are not controlled by us and may have privacy policies that differ from our own. We encourage our users to read the privacy policies and terms and conditions of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for the practices of such third parties or the content of their application or website. Providing Personal Information to third- party websites or applications is at your own risk.

For more information about our privacy practices, if you have questions, or if you would like to make a complaint or exercise any of your privacy rights, please contact us at hello@joinpointer.com. California Privacy Notice California law requires us to disclose certain information related to our privacy practices. This California Privacy Notice (the “CA Notice”) supplements the information contained in the Pointer Privacy Policy (the “Privacy Policy”) and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and California Privacy Rights Act of 2020 (CPRA) (together, the “CCPA”) and any terms defined under the CCPA have the same meaning when used in this CA Notice. Capitalized terms used but not de fined herein shall have the respective meanings set forth in the Privacy Policy. As used in this CA Notice only, “personal information” has the meaning set forth in the CCPA. To understand our privacy practices, you should refer to our Privacy Policy in addition to this supplement applicable to California residents.

The CCPA provides California residents with the right to know what categories of personal information covered businesses have collected about them and whether such businesses have disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve (12) months. This information can be found in the table below: Category of Personal Information Collected Category of Third Parties Personal Information is Disclosed to for a Business Purpose Identifiers. A real name, email address, username, Internet Protocol address, or other similar identifiers. ●Service providers (hosting, analytics, email) ●Business partners Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) A name, email address, telephone number. ●Service providers ●Business partners Commercial information Records of services purchased or considered, recommendation requests submitted, payments made, tips, and transaction histories. ●Service providers ●Business partners Internet or other electronic network activity Browsing history, search history, information on a consumer’s interaction with the Pointer application or website. ●Service providers (analytics, hosting) Geolocation data We may collect your IP address and, with your permission, precise location ’data to facilitate matching with relevant Pointers. ● Service providers Audio, electronic, visual, or similar information Profile photos, uploaded photos, and voice notes shared through the Services. ●Service providers ●Business partners Sensitive Personal Information Date of birth and age information; government- issued ID verification information for users applying to become Pointers; selfie/liveness or face-match verification information where supported or required by our verification provider, payment processor, or risk review process. Optional sensitive profile or preference information such as gender, sexual orientation, or compatibility-related preferences. ●Service providers ●Business partners We may use any of the categories of information listed above for other business or operational purposes compatible with the context in which the personal information was collected. The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in  ”Personal Information We Collect” and “How We Use Your Information” of the Privacy Policy, respectively. We may share any of the information listed above with service providers, which are companies that we engage for business purposes to conduct activities on our behalf. Service providers are restricted from using personal information for any purpose that is not related to our engagement. 2. “Sales” or “Sharing” of Personal Information under the CCPA California residents have the right to opt out of the “sale” or “sharing” of their personal information to third parties. The CCPA de fines “sale” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a consumer’s personal information to a third party for monetary or other valuable consideration. The CCPA defines “sharing” to mean sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a consumer’s personal information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration. We have “sold” or “shared” personal information with the following third parties in the preceding twelve (12) months: Inferential data Inferences drawn from other personal information profile reflecting a consumer’s preferences, characteristics, behavior, or interests based on recommendation requests, categories selected, and platform activity. ●Service providers Category of Personal Information Sold or Shared by Pointer Category of Third Parties Personal Information is Sold or Shared to Identifiers. A real name, postal address, Internet Protocol address, email address, or other similar identifiers. ●Service providers ●Business partners Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) A name, address, telephone number. ●Service providers ●Business partners

California residents have additional rights regarding their personal information. This section describes those additional rights and explains how to exercise those rights.

A. Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. To designate an authorized agent, please contact us as set forth in “Contact Information” in the Privacy Policy and provide written authorization signed by you and your designated agent.

B. California Shine the Light. The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. If you are a California resident and would like to exercise any of your rights under the law, please contact us as set forth in the “Contact Information” section of the Privacy Policy. We will process such requests in accordance with applicable laws.

C. Opt-out of “Sales or Sharing”. California residents may opt out of the “sale or sharing” of their personal information by contacting us as set forth in the “Contact Information” section of the Privacy Policy. California residents (or their authorized agent) Commercial information Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. ●Service providers ●Business partners Internet or other electronic network activity Browsing history, search history, information on a consumer’s interaction with an internet website, application, or advertisement. ●Service providers ●Business partners Geolocation data As described above, we may collect your IP address automatically when you use our Services. We may be able to determine your general location based on your device’s IP address. ●Service providers ●Business partners Category of Personal Information Sold or Shared by Pointer Category of Third Parties Personal Information is Sold or Shared to may also exercise your right to limit the disclosure of your sensitive personal information by clicking on this “Limit the Use of My Sensitive Personal Information” link. Please note: You may also broadcast an Opt-Out Preference Signal, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). MULTI-STATE PRIVACY NOTICE Residents of Colorado, Connecticut, Delaware, Iowa, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia may have additional rights under relevant privacy laws, including under the Colorado Privacy Act (CPA), Connecticut Data Privacy Act (CTDPA), Delaware Personal Data Privacy Act (DPDPA), Iowa Consumer Data Protection Act (ICDPA), Minnesota Consumer Data Privacy Act (MNCDPA), Montana Consumer Data Privacy Act (MTCDPA), Nebraska Data Privacy Act (NDPA), New Hampshire Consumer Data Privacy Act (NHCDPA), New Jersey Data Protection Act (NJDPA), Oregon Consumer Privacy Act (OCPA), Tennessee Information Protection Act (TIPA), Texas Data Privacy and Security Act (TDPSA), Utah Consumer Privacy Act (UCPA), and Virginia Consumer Data Protection Act (VCDPA), as applicable. The following additional information is required to be provided by covered businesses under applicable state laws. This Multi-State Privacy Notice (the “ Multi-State Notice”) supplements the information contained in the Pointer Privacy Policy (the “Privacy Policy”) and applies solely to all visitors, users, and others who reside in the States of Colorado, Connecticut, Delaware, Iowa, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia (“consumers” or “you”). We adopt this notice to comply with relevant privacy law. Capitalized terms used but not defined herein shall have the respective meanings set forth in the Privacy Policy. To understand our privacy practices, you should refer to our Privacy Policy in addition to this supplement.

The CPA, CTPDA, DPDPA, ICDPA, MNCDPA, MTCDPA, NDPA, NHCDPA, NJDPA, OCPA, TIPA, TDPSA, UCPA and VCDPA requires covered businesses to provide residents of their respective states with the right to know the categories of “personal data” (as de fined under applicable law) covered businesses shared with /disclosed to third parties and the categories of third parties with whom such personal data has been shared / disclosed. Residents of Colorado, Connecticut, Delaware, Iowa, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah and Virginia can find this information below: Category of Personal Data Shared Category of Third Parties Personal Data is Shared With / Disclosed to Identifiers A real name, email address, username, Internet Protocol address, or other similar identifiers. ●Service providers ●Business partners 2. “Sales” or Processing for Targeted Advertising Residents of Colorado, Connecticut, Delaware, Iowa, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia have the right to opt out of the “sale” of their personal data to third parties or the processing of their personal data for targeted advertising (see the “Accessing and Correcting Your Information” section above). For purposes of this paragraph, the definition of “targeted advertising”, “sale”, “sell”, or “sold” has the meaning set forth in applicable privacy law. Pointer does not currently sell personal data or process personal data for targeted advertising. If this practice changes, Pointer will provide appropriate notice and opt-out mechanisms as required by applicable law. Commercial information Records of services purchased or considered, recommendation requests, payments, tips, and transaction histories. ●Service providers ●Business partners Internet or other electronic network activity Browsing history, search history, information on a consumer’s interaction with the Pointer website or application. ●Service providers (analytics, hosting) Geolocation data We may collect your IP address and, with your permission, precise location data. We may determine your general location based on your ’device’s IP address. ●Service providers Category of Personal Data Sold to Third Parties or Processed for Targeted Advertising Category of Third Parties Personal Data is Sold to or Processed by for Targeted Advertising Identifiers A real name, postal address, Internet Protocol address, email address, or other similar identifiers. ●None Commercial information Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. ●None

A. Colorado, Connecticut, Delaware, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, and Virginia . Residents of these states (or an authorized agent thereof) may request to opt out of the processing of your personal data for the purpose(s) of: (i) targeted advertising; (ii) sale of personal data; or (iii) profiling to make decisions that have legal or other significant effects on you. If you would like to exercise this right, you may send us an email to hello@joinpointer.com to request to opt out. We will process such requests in accordance with applicable law. Please note: You may broadcast an Opt-Out Preference Signal, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal).

B. Iowa and Utah. Iowa and Utah residents may request to opt out of the processing of your personal data for the purpose(s) of: (i) targeted advertising; or (ii) sale of personal data. If you would like to exercise this right, you may send us an email to hello@joinpointer.com to request to opt out. We will process such requests in accordance with applicable law.

If you are a resident of the State of Connecticut and your request for reconsideration of Pointer’s refusal to take action in accordance with the exercise of your rights in the “Accessing and Correcting Your Personal Information” section of the Privacy Policy is denied, you have the right Internet or other electronic network activity Browsing history, search history, information on a consumer’s interaction with an internet website, application, or advertisement. ●None Inferences drawn from other personal information to create a profile about a consumer Profile reflecting a consumer ’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. ●None Geolocation data As described above, we may collect your IP address automatically when you use our Services. We may be able to determine your general location based on your device’s IP address. ●None Category of Personal Data Sold to Third Parties or Processed for Targeted Advertising Category of Third Parties Personal Data is Sold to or Processed by for Targeted Advertising to file a complaint with the Connecticut Office of the Attorney General by visiting the “File a Complaint” page at https://portal.ct.gov/AG/Common/Complaint-Form-Landing-page or contacting the Consumer Assistance Unit at 860-808-5420.

If you are a resident of the State of Minnesota, you have the right to: (a) request the speci fic third parties to whom Pointer has disclosed Personal Information; and/or (b) question the results of ’Pointer’s profiling to the extent it produced legal effects.

Several state privacy laws provide enhanced protections for minors. Because the Services are available only to users aged eighteen (18) and older, Pointer does not knowingly collect or process the personal data of minors. If Pointer becomes aware that a user is under 18, it will take steps to delete such user’s personal data and terminate access. NEVADA PRIVACY NOTICE Nevada law requires us to provide all visitors, users, and others who reside in the State of Nevada (“you”) certain additional privacy rights. This Nevada Privacy Notice supplements the information contained in the Pointer Privacy Policy and applies solely to you. If you are a resident of Nevada, you have the right to opt out of the sale of certain Personal Information to third parties who intend to sell or license that Personal Information, even if your Personal Information is not currently being sold. If you would like to exercise this right, please contact us via the information found in the ““Contact Information”“ section of the Privacy Policy.