Military Connect® Privacy Policy

1. Scope and Who We Are

Military Connect provides members of the military community access to benefits, resources, eligibility confirmations, partner offers, discounts, loyalty opportunities, and other Military Connect-branded services. A significant portion of the Military Connect experience consists of connecting members to offers, products, subscriptions, and services supplied and operated by independent third parties.

This Policy applies to personal information processed by or on behalf of Military Connect. When you leave a Military Connect property and interact directly with an independent partner, merchant, or service provider, that third party generally determines how information you provide on its property is collected and used under its own privacy policy. Military Connect may receive referral, attribution, eligibility, transaction-confirmation, or commission-related information as described below.

2. Personal Information We Collect

The information we collect depends on how you interact with the Services. We may collect the following categories of personal information:

Identifiers and contact information: Name, email address, telephone number, mailing address, account or member identifier, username, and similar identifiers.

Military-community eligibility information: Information you provide, or information obtained through authorized eligibility processes, to determine or confirm eligibility as a service member, Veteran, military retiree, military family member, survivor, caregiver, or other eligible participant.

Commercial, referral, and transaction information: Offers viewed or clicked; referral source; campaign or affiliate identifiers; offer activation or redemption information; and, where provided by a partner, limited transaction-confirmation information such as whether a qualifying purchase or subscription occurred, transaction amount or category, cancellation or return status, and commission or reward attribution.

Payment and financial information: Military Connect generally does not collect payment-card information for purchases completed on independent partner websites. If Military Connect directly facilitates a transaction or offers a Service that requires payment information, the applicable checkout, merchant-of-record disclosure, or supplemental notice will explain the information collected and the parties responsible for processing it.

Internet, device, and usage information: IP address, device identifiers, browser type, operating system, pages viewed, clicks, referral URLs, session information, cookie or pixel identifiers, and similar usage data.

Approximate location information: General location inferred from IP address or device settings, where enabled.

Communications and support information: Emails, SMS preferences, customer-support requests, survey responses, call or chat records, and other communications with us.

Partner and referral information: Referral source, partner campaign, program affiliation, tracking identifiers, and information a partner provides when you request or use a co-branded or partner program.

Preferences and inferences: Communication preferences, offer interests, inferred interests based on activity, and account settings.

Sensitive personal information: Where necessary and permitted, information that may be treated as sensitive under applicable law, such as account credentials, precise geolocation if enabled, or information used in identity or eligibility verification.

Information we do not need. Please do not provide Social Security numbers, full financial-account credentials, medical records, or other highly sensitive information unless a specific Military Connect Service expressly requests it and provides an appropriate notice. Military Connect seeks to collect only information reasonably necessary for the applicable purpose.

3. How We Collect Information

• Information you provide directly, such as when you create an account, request eligibility confirmation, enroll in a program, contact us, participate in a promotion, or communicate with Military Connect.
• Information collected automatically through cookies, pixels, software development kits, server logs, analytics technologies, and similar tools when you use the Services.
• Information from partners and service providers, including referral partners, merchants, program operators, eligibility or identity-verification providers, communications providers, analytics providers, and other organizations involved in a Service you choose to use.
• Information generated through your interactions with Military Connect, such as account history, offer activity, support history, preference data, and fraud or security signals.

4. How We Use Personal Information

• Provide, operate, maintain, personalize, and improve the Services.
• Create and administer Military Connect membership and accounts.
• Determine or confirm eligibility for Military Connect or partner military-community programs.
• Provide access to benefits resources, offers, discounts, partner programs, marketplaces, loyalty or rewards opportunities, and other member services.
• Process, support, attribute, or reconcile transactions and redemptions where applicable.
• Authenticate users, protect accounts, detect and prevent fraud, abuse, security incidents, or unlawful activity.
• Communicate with you about your account, transactions, eligibility, service changes, customer support, and administrative matters.
• Send marketing, offers, newsletters, or promotional communications where permitted by law and consistent with your choices.
• Analyze usage, measure campaigns, perform attribution, improve products, conduct research, and develop new services.
• Comply with contracts, legal obligations, lawful requests, audits, tax and accounting obligations, and enforce our Terms of Use and other agreements.
• Establish, exercise, or defend legal claims; protect the rights, safety, property, or security of Military Connect, our members, partners, or others.
• Carry out other purposes disclosed to you at the time of collection or with your consent where required.

5. How We Disclose Personal Information

We may disclose personal information to the following categories of recipients as reasonably necessary for the purposes described in this Policy:

• Service providers and processors that perform hosting, cloud infrastructure, cybersecurity, analytics, communications, customer support, identity or eligibility services, payment support, fraud prevention, fulfillment, and other services for Military Connect.
• Program partners, merchants, and benefit providers when you choose to access, activate, redeem, purchase, enroll in, or otherwise use a partner offer or service, or when disclosure is necessary to provide the experience you requested.
• Advertising, analytics, and attribution providers that help measure, personalize, and market the Services, subject to applicable law and your privacy choices.
• Affiliates and corporate entities under common control, where permitted and consistent with this Policy.
• Professional advisors, auditors, insurers, financial institutions, and other parties necessary for legitimate business operations.
• Government, law-enforcement, regulatory, judicial, or other authorities when required by law or when we reasonably believe disclosure is necessary to comply with legal process, protect rights or safety, investigate fraud or security incidents, or enforce agreements.
• A buyer, successor, or other party in connection with an actual or proposed merger, financing, acquisition, reorganization, sale of assets, bankruptcy, or similar corporate transaction, subject to appropriate protections.
• Other parties when you direct us to disclose information or provide consent where consent is required.

Military Connect does not sell personal information in exchange for monetary payment. Military Connect does receive commissions, referral fees, or other compensation from some partners when a member follows a Military Connect offer or tracking link and later completes a qualifying action or transaction. Receiving a commission does not by itself mean that Military Connect has sold the member's personal information. However, some state privacy laws define "sale," "sharing," or targeted advertising broadly and may apply to certain cookies, pixels, advertising technologies, or data disclosures used for cross-site advertising or attribution. Where applicable law gives you an opt-out right, Military Connect will provide the required choice and honor legally recognized universal opt-out signals where required.

6. Partner Offers, Referral Links, Commissions, and Third-Party Transactions

Military Connect provides access to offers, discounts, products, subscriptions, benefits, and services made available by independent third-party partners. When you select a partner offer, you may be redirected to the partner's website, application, checkout, or other property. Unless Military Connect expressly states otherwise, the partner — not Military Connect — operates that experience and is responsible for the product or service, checkout, payment processing, fulfillment, subscription administration, returns or cancellations, customer service, and the personal information the partner collects directly from you.

Military Connect may receive a referral fee, commission, revenue share, or other compensation when you click on a Military Connect offer, visit a partner through a Military Connect tracking link, or complete a qualifying transaction or other action with that partner. Military Connect and its partners or service providers may use referral identifiers, promotional codes, cookies, pixels, or similar attribution tools to determine that a visit, enrollment, subscription, or purchase originated through Military Connect.

Unless otherwise disclosed for a particular Service, Military Connect generally does not receive the payment-card information you provide directly to an independent partner or merchant of record. Military Connect may receive limited reporting needed to attribute and reconcile activity, such as a referral or campaign identifier, date or status of a qualifying action, transaction amount or category, cancellation or return information, commission amount, or other program-performance information. Depending on the partner and program, that reporting may be aggregated, pseudonymous, or linked to a Military Connect member or account.

Information collected directly by an independent partner on the partner's website, application, or checkout is governed by that partner's privacy policy and terms. Military Connect is not responsible for an independent partner's privacy practices. Before providing personal information directly to a partner, you should review the privacy notice presented by that partner.

If Military Connect performs an eligibility confirmation for a partner, Military Connect may process eligibility-related information and provide the partner an eligibility result or limited related information necessary to deliver the requested offer or Service, consistent with the applicable program notice, contract, and law.

Where a particular Military Connect program involves a different data flow — including a marketplace, gift-card program, financial service, pharmacy-discount program, card-linked offer, or other embedded or co-branded experience — Military Connect may provide supplemental privacy disclosures describing the respective roles of Military Connect and the applicable partner.

7. Card-Linked Offers and Transaction Monitoring, If Offered

Military Connect may separately offer card-linked or transaction-linked programs. Those programs are not part of the standard affiliate/referral model described above and are not a condition of general Military Connect membership unless expressly stated. If you voluntarily enroll a payment card or participate in transaction monitoring, the applicable supplemental terms or privacy notice will identify the card-linking or payment-network provider, the categories of transaction information processed, the purposes of monitoring, and available opt-out methods. Participation in one such program does not authorize unrelated transaction monitoring.

8. Cookies, Analytics, Advertising, and Similar Technologies

Military Connect and authorized service providers or partners may use cookies, pixels, web beacons, local storage, server logs, and similar technologies to operate the Services, remember preferences, authenticate users, prevent fraud, understand usage, measure campaigns, and attribute referrals or commissions. Some technologies may also support personalization or advertising. Their use is subject to applicable law and your available privacy choices.

You can control many cookies through your browser or device settings. Blocking certain cookies may affect functionality. Where required by law, Military Connect provides consent or preference controls for non-essential cookies and recognizes applicable universal opt-out mechanisms, including Global Privacy Control (GPC), as described in Section 16.

Traditional browser "Do Not Track" signals are not standardized and may not be treated the same as legally recognized universal opt-out mechanisms. Military Connect will respond to legally required opt-out preference signals where applicable.

9. Email, SMS, and Other Communications

Military Connect may send service-related communications necessary to operate your account or provide requested Services. Where permitted, we may also send promotional emails, text messages, or other marketing communications. You may unsubscribe from marketing emails using the unsubscribe link in the message. For SMS, follow the opt-out instructions in the applicable message or SMS terms. Opting out of marketing does not prevent us from sending non-promotional account, security, transaction, legal, or service communications.

Military Connect does not sell mobile telephone numbers for monetary consideration. Mobile numbers may be disclosed to service providers or program partners as necessary to provide communications or a Service you requested, subject to applicable law and contractual restrictions.

10. Loyalty, Rewards, and Financial Incentive Programs

Military Connect may offer loyalty, rewards, VetBucks™, discounts, promotional benefits, or other programs that could be treated as a financial incentive or price or service difference under certain privacy laws. Participation in such programs is voluntary. Where a program is subject to a financial-incentive notice requirement, Military Connect will provide the required program-specific notice before enrollment, including the material terms, the categories of personal information implicated, how the incentive or benefit relates to the value of the information where required, how to opt in, and how to withdraw. Withdrawing from a program will not affect privacy rights, but may end benefits that depend on participation or information necessary to administer the program.

A loyalty or rewards program does not authorize Military Connect to use personal information for materially unrelated purposes unless separately disclosed and permitted by law. Program-specific terms may supplement this Privacy Policy.

11. Data Security

Military Connect uses reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, alteration, and disclosure. Safeguards may include access controls, encryption in transit where appropriate, system monitoring, vendor-management practices, incident-response procedures, and workforce confidentiality obligations. No system is completely secure, and Military Connect cannot guarantee absolute security.

Military Connect seeks to collect and retain only personal information reasonably necessary for legitimate business purposes and applicable legal obligations. We periodically review data-security and privacy practices and may require service providers to maintain appropriate safeguards through contract.

12. Data Retention

We retain personal information for no longer than reasonably necessary for the purposes described in this Policy, unless a longer period is required or permitted by law. Retention periods vary based on the type of information, the Service involved, account status, contractual obligations, fraud and security needs, legal or regulatory requirements, dispute resolution, and whether the information is needed to establish, exercise, or defend legal claims.

• Account and membership information may be retained while an account is active and for a reasonable period afterward to support reactivation, records, fraud prevention, and legal obligations.
• Eligibility records may be retained as needed to document or support eligibility determinations, prevent repeated verification, address fraud or disputes, and satisfy partner or legal requirements, subject to data-minimization principles.
• Transaction and financial-support records may be retained for accounting, tax, reconciliation, chargeback, fraud, contractual, and legal requirements.
• Marketing preferences and suppression records may be retained as necessary to honor opt-out requests.
• Security logs and fraud-prevention records may be retained for periods appropriate to the applicable security risk.

When retention is no longer reasonably necessary, we delete, de-identify, or otherwise dispose of information in accordance with applicable law and our data-management practices. Backups and archival copies may persist for a limited period before routine deletion.

13. Automated Tools and Eligibility or Fraud Decisions

Military Connect may use automated or algorithmic tools to assist with eligibility confirmation, fraud prevention, security, personalization, recommendations, analytics, or operational decision-making. Where applicable law provides rights relating to covered automated decision-making technology, profiling, or decisions producing legal or similarly significant effects, Military Connect will provide required notices, access, opt-out, appeal, or human-review mechanisms. We do not intend to use automated systems to make decisions producing legal or similarly significant effects without the safeguards required by applicable law.

14. Children and Minors

The general Military Connect Services are not directed to children under 13, and Military Connect does not knowingly collect personal information online from children under 13 without legally valid parental consent. If we learn that we collected personal information from a child under 13 in a manner not permitted by law, we will take reasonable steps to delete it. A parent or guardian who believes a child has provided personal information may contact privacy@militaryconnect.com.

Where applicable law requires affirmative authorization before selling or sharing the personal information of minors under 16, Military Connect will not knowingly engage in such activity without the required authorization.

15. International Users

Military Connect is based in the United States, and personal information may be processed in the United States and other countries where Military Connect or its service providers operate. Those countries may have data-protection laws different from the laws where you live.

If the European Economic Area (EEA), United Kingdom, Swiss, or another international data-protection law applies to our processing, Military Connect will process personal information under an applicable legal basis, such as performance of a contract, legitimate interests, compliance with legal obligations, or consent where required. Individuals may have rights to access, correct, erase, restrict or object to processing, obtain portability, withdraw consent, and lodge a complaint with a supervisory authority, subject to applicable law. Where required for international transfers, Military Connect will use a lawful transfer mechanism, such as approved contractual safeguards.

16. Your Privacy Rights and Choices

Depending on where you live and subject to legal exceptions, you may have some or all of the following rights:

• Access or know whether and how we process your personal information and receive information about categories or specific pieces of personal information.
• Correct inaccurate personal information.
• Delete personal information.
• Obtain a portable copy of certain personal information.
• Opt out of the sale of personal information, sharing for cross-context behavioral advertising, or targeted advertising where those rights apply.
• Opt out of certain profiling or covered automated decision-making activities where applicable.
• Limit certain uses or disclosures of sensitive personal information where applicable.
• Withdraw consent where processing is based on consent.
• Appeal a denial of a privacy-rights request where applicable.
• Receive equal service and not be discriminated against for exercising applicable privacy rights.

How to exercise your rights. You may submit a privacy request by emailing privacy@militaryconnect.com. Please identify the right you wish to exercise and provide enough information for us to reasonably verify the request and locate relevant records. We may request additional information only as reasonably necessary to verify identity, authority, or the scope of the request. We will respond within the time required by applicable law.

Authorized agents.Where permitted by law, you may designate an authorized agent to submit a request on your behalf. We may require proof of the agent's authority and may ask you to verify your identity directly unless applicable law provides otherwise.

Appeals. If applicable law provides a right to appeal and we deny your request, you may appeal by replying to our decision or emailing privacy@militaryconnect.comwith the subject line "Privacy Appeal." We will respond within the period required by applicable law and provide any further complaint options required by law.

Universal opt-out signals / Global Privacy Control. Where required by applicable law, Military Connect treats a recognized universal opt-out signal, including GPC, as a valid request to opt out of sale, sharing, or targeted advertising for the browser or device from which the signal is sent, and, where required and technically feasible, for the associated account or consumer. Because these signals operate at the browser or device level, you may need to enable the signal on each browser or device you use.

17. California Privacy Notice

This section supplements the remainder of this Privacy Policy for California residents to the extent the California Consumer Privacy Act, as amended (CCPA), applies to Military Connect.

The categories of personal information we may collect are described in Section 2. Depending on how you use the Services, those categories may correspond to CCPA categories such as identifiers; customer-record information; characteristics of protected classifications where voluntarily provided or necessarily implicated by eligibility; commercial information; internet or electronic network activity; geolocation data; audio, electronic, visual, or similar information; professional or employment-related information where relevant to military or program eligibility; inferences; and sensitive personal information. We collect these categories from the sources described in Section 3, use them for the purposes described in Section 4, and disclose them to the recipient categories described in Section 5.

Military Connect does not sell personal information for money. Certain disclosures involving advertising, analytics, or cross-context behavioral advertising may constitute "sharing" or "sale" under the CCPA. California residents may exercise applicable rights to know/access, correct, delete, opt out of sale or sharing, limit certain uses or disclosures of sensitive personal information, and receive non-discriminatory treatment. Where applicable, California residents may also have rights relating to covered automated decision-making technology under effective CCPA regulations.

For CCPA notice-at-collection purposes, the categories, purposes, and retention criteria are stated in Sections 2, 4, and 12. We do not retain personal information for longer than reasonably necessary for the disclosed purposes, subject to legal and operational exceptions.

To exercise California privacy rights, email privacy@militaryconnect.com. Where required, Military Connect will provide or maintain a clear method to opt out of sale/sharing and will honor qualifying opt-out preference signals. If Military Connect's practices trigger a California right to limit the use or disclosure of sensitive personal information, Military Connect will provide the required method for exercising that right.

18. Colorado and Other U.S. State Privacy Rights

To the extent Military Connect is subject to the Colorado Privacy Act, Colorado residents may have rights to access, correct, delete, and obtain a portable copy of personal data, and to opt out of targeted advertising, sale of personal data, and certain profiling. Military Connect will also honor a qualifying universal opt-out mechanism where required by Colorado law. Colorado residents may appeal a denial as described in Section 16.

Residents of other U.S. states may have similar rights under applicable comprehensive state privacy laws, including rights to access, correct, delete, obtain portability, opt out of targeted advertising or sale, limit certain sensitive-data processing, opt out of certain profiling or automated decisions, and appeal denials. Military Connect will honor applicable rights for residents of states in which the relevant law applies to Military Connect.

19. Sensitive Personal Information

Military Connect processes sensitive personal information only when reasonably necessary for a disclosed purpose, to provide a requested Service, to protect security and prevent fraud, to comply with law, or with consent where consent is required. We do not use sensitive personal information to infer characteristics about an individual for purposes unrelated to the requested Service unless separately disclosed and permitted by law. Where applicable law requires consent before processing sensitive data, or provides a right to limit or opt out of such processing, Military Connect will provide the required mechanism.

20. De-Identified and Aggregated Information

We may create or use aggregated, statistical, or de-identified information for analytics, research, service improvement, business planning, security, and other lawful purposes. Where information is treated as de-identified under applicable law, Military Connect will take reasonable measures to prevent re-identification, maintain the information in de-identified form, and not attempt to re-identify it except as permitted by law to test or validate de-identification practices.

21. Changes to This Privacy Policy

Military Connect may update this Privacy Policy from time to time to reflect changes in law, technology, Services, partners, or data practices. We will post the updated Policy and revise the "Last Updated" date. If a change materially affects how we use previously collected personal information, we will provide additional notice or obtain consent when required by applicable law. Continued use of the Services after an update does not override any consent or notice requirement imposed by law.

22. Legal Requests, Safety, and Corporate Transactions

Military Connect may preserve, use, or disclose personal information when reasonably necessary to comply with law, regulation, court order, subpoena, governmental or law-enforcement request, or other valid legal process; protect the rights, safety, property, or security of Military Connect, our members, partners, or others; investigate or prevent fraud, abuse, or security incidents; enforce agreements; or establish, exercise, or defend legal claims. We may also transfer personal information in connection with a merger, acquisition, financing, restructuring, sale of assets, bankruptcy, or similar transaction, subject to applicable law and appropriate protections.

23. Contact Us

If you have questions about this Privacy Policy, our privacy practices, or a privacy-rights request, contact:

For program-specific privacy questions, please also review any supplemental notice or partner privacy policy presented with the applicable Military Connect program or transaction.