This Loyalty Rewards Policy explains guidelines and practices of Loyalty Program under UMO Rewards™, a service provided by Cubic Transportation Systems, a division of Cubic Corporation (“Cubic”) and its subsidiaries. By joining UMO Rewards™, you are accepting the guidelines, practices, terms and conditions stated in this policy.

1. Overview

Stars are a proprietary digital loyalty currency owned and operated by Cubic and its subsidiaries, intended for use on transit systems. UMO Rewards™, a service provided by Cubic Transportation Systems, implements advertising and Star loyalty management solutions. In this regard, UMO Rewards™ provides loyalty program management services on behalf of Transit Agencies and participating loyalty partners.

Transit riders, herein referring as Consumers, engage with advertising content or offers and earn loyalty points and value in the form of Stars that they may use to subsidize or pay for transit services or other product and service offerings.

Each Star may be turned into a product or service value.

2. Star Reward Prerequisites

2.1 Consumer Registration

A Consumer must have an existing account in the Transit Agency mobile app, or if not, the Consumer must set up an account with the Transit Agency as the first step in registering for the Star loyalty program to be eligible for the Star loyalty reward and redemption. This registration process is independent of UMO Rewards™.

2.2 Opt in to Star Program

Once the Consumer has a Transit Agency account and downloads Transit Agency app, the Consumer may opt in to the Star loyalty program. This is independent of any other Star loyalty programs that the Consumer has previously opted into through other Transit Agency apps. 

Ads will automatically be served on the Consumer’s Transit Agency app disregard of the Consumer’s Star loyalty program status. 

The Transit Agency mobile app may include opting in to the Star loyalty program as part of the process of registering for a Transit Agency account to combine both registrations into a single step. Additionally, Transit Agency will provide the option for Consumers who have not yet opted in to the Star loyalty program to opt in separately.

2.3 Link Existing Star Accounts

If a Consumer has one or more existing Star loyalty accounts with other Transit Agencies, the Consumer cannot link the existing accounts to a new Transit Agency account.

2.4 Consumer Profile

A Consumer may view their account profile in the Transit Agency mobile app. The account profile includes contact information such as name, e-mail address, street address, phone number, and demographic information. The Consumer may edit their profile and view their Star account balance and recent transactions. However, the e-mail address may not be edited by Consumer. The Consumer must create a new account if they want to change their email address.

2.5 Opt out of Star Program

A Consumer may opt out of the Star loyalty program in the Transit Agency mobile app at any time. Once the opt out is complete, the Consumer will no longer be eligible for the Star rewards, and the Consumer will forfeit all accumulated Stars. Once Stars are forfeited, the Star cannot be reinstated, but the Consumer can earn new Stars by opting in the Star program again.

The costs of all forfeited Stars will be subtracted from UMO Rewards™’ Stars liabilities and will not be eligible for revenue share with loyalty and advertising partners.

3. Loyalty Reward Management

3.1 Star Pool Management

Star pools are primarily retained and managed by UMO Rewards™. There are 2 types of star pools:

• Silo star pool: A Transit Agency operates in a silo Star pool, whereby a Consumer who earns Stars with a Transit Agency can only redeem Stars with that Transit Agency. In this case, Transit Agency, as the issuer of the pool of Stars, has its own dedicated pool of Stars which is not shared with any other Transit Agency.
• Foreign currency star pool: A Transit Agency operating outside the United States, using a different currency from that of the Transit Agencies located and registered in the United States. The Transit Agency with a foreign currency must use a separate pool of Stars and cannot share Stars with the other Transit Agencies using US dollars.

3.2 Star Reward Options

There are four ways a Consumer can earn Stars while using a Transit Agency’s mobile apps and/or devices:

• Video ad view
• Ad response
• Stars awarded by Transit Agency
• Third party’s card-linked offer acceptance (future product release)

A Consumer will be credited with Stars to their account if they take one of the above engagement actions.

For video ad view and ad response, Consumers must stay logged in to execute the reward criteria in order to be credited with Stars. 

For Stars awarded by Transit Agency or purchases using linked payment card with participating merchants as part of the available card-linked offers, consumers do not have to log in to their transit account in order to be credited with Stars.

A Consumer must be logged-in in order to redeem Stars earned.

3.2.1. Video Ad View

Each time a Consumer completes a video ad view, the Consumer will be awarded with Stars. A Consumer can watch a video more than one time but will only be awarded with Stars once for each qualified view of the same video ad within each session. If a Consumer completes a qualified view of more than one video ad, they will be awarded with Stars for the corresponding number of unique video ads that they watch. The number of Stars awarded varies depending on the Ad View Stars Percentage and Cost Per View specified in each advertising contract. Ad View Stars Percentage or the percentage of the ad revenue allocated to Star reward varies depending on the length of the video. Consumers will be able to see the number of Stars they will get for watching each video.

Each time a video ad plays continuously up to 30 seconds or a full duration of the ad of less than 30 seconds, it’s counted as a view. UMO Rewards™ allocates a percentage of the ad revenue to Star reward, whereby the number of Stars awarded for each qualified video view will be calculated as follow:

Round Down (((CPM / 1000) * Ad View Stars Percentage) / Stars Settlement Price) or

((CPV * Ad View Stars Percentage) / Stars Settlement Price)

Whereby

Star Settlement Price is the price Cubic pays a Transit Agency for each Star that a consumer redeems.

Cubic does not bill the Advertiser for the Stars awarded, but only for the price of ad views.

Below is an example of how Stars are awarded for an ad campaign that uses the Ad View Stars Percentage approach.

Each time a Consumer completes an ad response offer, the Consumer will be awarded with Stars. An advertiser can specify a dollar amount to award in Stars for each ad response from Consumers, such as answering a survey, joining a contest, signing up for newsletters, or purchasing an item, besides the ad delivery fees, whereby the number of Stars awarded for each qualified engagement action will be calculated as follow:

3.2.2. Ad Response

Round Down (Ad Response Stars Fee / Stars Settlement Price)

The number of Stars awarded for each qualified engagement action varies depending on the type of ad response. Consumers will be able to see the number of Stars they will get for each ad response.

Cubic bills the Advertiser the actual Stars awarded multiplying with the Star Purchase Price, plus the price of the ad responses.

3.2.3. Stars Awarded by Transit Agency

Transit Agencies may award Stars to Consumers for various activities and allow Consumers to redeem Stars for transit tickets or other transit services offered by Transit Agency. The number of Stars awarded for each activity varies at Transit Agency’s own discretion. Consumers will be able to see the number of Stars they will get for taking each activity offered by Transit Agency.

Cubic bills Transit Agency for each Star that Transit Agency awards to Consumers. The Star Purchase Price for Transit Agency will be defined in an addendum or scope of work (SOW) agreed and signed between Cubic and Transit Agency.

3.2.4 Third Party’s Card-linked Offer Acceptance

Financial services providers may award Stars to a Consumer if the Consumer accepts to link their card issued by a financial service provider with the Consumer’s transit account and/or Star account. Additionally, the Consumer may also be awarded with Stars for using their card to pay for other qualified expenses defined by the financial services providers. The number of Stars awarded for each activity varies at the financial services provider’s own discretion. Consumers will be able to see the number of Stars they will get for accepting the card-linked offer.

Cubic bills the financial services provider for each Star that the financial services provider awards to Consumers. The Star Purchase Price for the card issuer will be defined in a contract, an addendum, or a scope of work (SOW) agreed and signed between Cubic and Transit Agency.

3.3 Promotional Stars

3.3.1. Transit Agencies’ Owned Promotional Stars

Transit Agencies have the option to promote their loyalty program in the form of transit service value converted into promotional Stars upon written agreement with UMO Rewards™.

Specifically, Transit Agencies may release some transit service products to UMO Rewards™ for free. In return, these transit service products will be converted into an equivalent number of promotional Stars at the current Star redemption price. UMO Rewards™ will then use the promotional Stars to award Consumers based on a valid, pre-approved behavior such as a successful opt-in to the loyalty program or to increase ad engagement star award such as a valid video ad view. The star award will end immediately after the promotional stars are used up.

UMO Rewards™ will not be liable for any Stars redeemed for the free transit service products given by Transit Agency as part of the promotion program, from the star promotional start date until the end date or until the total number of stars redeemed during that period reaches the total equivalent number of Stars converted from the free transit service products given to UMO Rewards™ within the promotion period.

The Stars redeemed by Consumers, however, may come from the above promotional Stars awarded by UMO Rewards™, or may come from Consumers’ other engagement activities on the apps and/or devices. UMO Rewards™ is not responsible for defining the source of the redeemed Stars during all financial settlements with Transit Agency.

3.3.2. Cubic’s Owned Promotional Stars

Similarly, UMO Rewards™ may co-promote the loyalty program in the form of promotional Stars upon written agreement with Transit Agency.

UMO Rewards™ will use its own fund to award Consumers based on a valid, pre-approved behavior or to increase ad engagement star award. UMO Rewards™ will notify Transit Agency of the promotion plan and period in advance.

UMO Rewards™ will be liable for any Stars redeemed in this case unless indicated differently. If UMO Rewards™ and Transit Agency co-fund the promotional Stars. UMO Rewards™ will deduct redeemed Stars from Transit Agency’s promotional Star pool for redemption first until depletion before switching to UMO Rewards™’ promotional Star pool for redemption.

The redeemed Stars will be calculated as Star costs burdened by UMO Rewards™ in corresponding financial settlements with Transit Agencies.

3.4 Star Reward Value

Each Star awarded to a Consumer has a value of US$0.005.

3.5 Star Redemption Price

Star Redemption Price is the dollar value ratio that UMO Rewards™ uses to calculate the number of Stars required for a redemption option that a loyalty user selects. The Stars Redemption Price has a value at $0.005 per Star applied for all Stars redemption activities.

3.6 Star Settlement Price

Star Settlement Price is the price Cubic pays a Transit Agency for each Star that a consumer redeems. The Stars Settlement Price will be equal to or less than the Stars Redemption Price.

3.7 Star Transfer

Stars cannot be transferred from one Consumer’s Star account to another Consumer’s Star account.

3.8 Star Expiration

Consumers must remain active in the Star Loyalty Program to retain Stars they accumulate. If a Consumer’s loyalty account is inactive for twelve (12) consecutive months, that Consumer will forfeit all accumulated Stars. Once Stars are forfeited, the Stars cannot be reinstated, but Consumer can earn new Stars, unless that Consumer’s account has been deactivated.

An inactive loyalty account status is when a Consumer does not participate in any loyalty point earning and redemption with their loyalty account. Periods impacted by uncontrollable events or force majeure events that directly or indirectly prevent a Consumer from participating in the above loyalty engagement activities will not be counted toward the account inactive status duration.  Cubic and Transit Agency will together reasonably determine the length of the period impacted by such events. UMO Rewards™, Transit Agency and/or UMO Rewards™’ authorized loyalty partners will make necessary adjustments to the loyalty account status in such cases.

The costs of all forfeited Stars will be subtracted from Cubic’s Stars liabilities and will not be eligible for revenue share with loyalty and advertising partners.

3.9 Star Reward and Redemption Workflow

3.9.1 Star Reward Workflow

After a Consumer completes a qualified Star earning activity, the Consumer will be awarded with a set number of Stars in their Star account. The Consumer’s Star account balance will be updated accordingly, depending on the update frequency rules of the Transit Agency’s mobile apps and/or devices.

Loyalty Program Eligibility for Cubic and its Publishers’ Employees and Family Members

Cubic and its Publishers’ employees and their family members are eligible for the Star loyalty program and may participate in the program if they wish.

3.9.2 Star Redemption Workflow

Stars may be redeemed for product or service value or transit service value such as a mobile pass, which will be credited to the consumer’s transit account. Availability of transit card types varies by Transit Agency. Consumers may redeem Stars upon logging into their transit account or at a local Transit Agency’s physical booth. Consumers may NOT purchase or redeem Stars for cash.

Consumers may see their past Star transaction history, including Star transaction type, Star transaction date, Star transaction amount, Star transaction balance, transit account ID, transit redemption value, and transit redemption currency. Offering such information availability to Consumers in the apps and/or devices is at Transit Agency’s own discretion.

3.10 Consumer Star Settlement

A Consumer may be credited with Stars manually by the Star Pool issuer. However, the credit amount should not exceed the Star Credit Limit per Transaction or Star Credit Limit per Day set by the Star Pool issuer.

Similarly, a Consumer may redeem Stars at any time. However, the Star redemption amount should not exceed the Star Debit Limit per Transaction or Star Debit Limit per Day set by the Star Pool issuer.

Whether in a case of a siloed Star pool or a shared Star pool, Consumers must meet a Star Redemption Minimum in their Star account in order to redeem Stars. Besides, there is a Star Redemption Increment requirement for each transaction. For example, if the Star Redemption Minimum is 500 and the Star Redemption Increment is 100, then Consumers can only redeem 500 stars, 600 stars, or 700 Stars and cannot redeem 550 Stars or 610 Stars.

3.11 Star Adjustment

A Consumer may be credited with Stars manually by Transit Agency. In such cases, it will be deemed as Stars Awarded Directly by Transit Agency option.

Cubic bills Transit Agency for each Star that Transit Agency awards to Consumers. The Star Purchase Price for Transit Agency will be defined in an addendum or scope of work (SOW) agreed and signed between Cubic and Transit Agency.

3.12 Star Redemption Testing

Any Stars redemption testing activities by Cubic and Transit Agency will not be counted and recorded as Cubic’s Stars liabilities.

Employees who conduct the above testing are responsible for reporting such activities to Cubic Operations Manager and Transit Agency’s main point of contact for UMO Rewards™ program at the earliest convenience. The redeemed stars and redeemed tickets will be removed off the tester’s Star accounts. Redeemed Stars may also be credited back to the tester’s Star accounts if specifically requested.

3.13 Star Reward and Redemption Reporting

Star reward and redemption activities and total accumulative balance will be updated in UMO Rewards™’ admin portal dashboard near real time.

3.14 Termination of UMO Rewards™ in a Specific Region

If UMO Rewards™ is terminated in a specific region, UMO Rewards™ shall notify consumers of the loyalty program termination in their region by digital or written communications means unless indicated otherwise by participating transit agencies. Consumers will then have 30 days since receipt of the termination notification to redeem Stars for transit value from the transit agencies within that region.

The consumers’ loyalty account shall remain active as long as the loyalty account is under an active Star pool that is not deactivated due to the termination of a region and its transit agencies under the Star pool. Consumers may still earn Stars and redeem Stars with other participating transit agencies from other regions by switching their original region to other desired region in their account setting.

4. Star Loyalty Reward Program Policy Disclaimers

UMO Rewards™ is made available on an “As is, where is” basis and Cubic and its subsidiaries make no warranty or representation, whether express or implied in fact or in law, of merchantability, fitness for any UMO Rewards™ purpose, functionality or availability.

Cubic and its subsidiaries do not give, and expressly disclaims, any warranty (express or implied) as to the fitness for purpose, accuracy, compliance with law, policies, regulations, or any other judicial or administrative orders of the loyalty and advertising content. Sponsors will be solely responsible for said nature and messaging of the advertising and loyalty content to any claims of any nature from third parties.

The Star loyalty reward program and its benefits are offered at the discretion of Cubic, its subsidiaries, and its loyalty partners and are subject to change at any time. Consumers are responsible for being knowledgeable of the program policy and its latest updates. Loyalty partners shall provide loyalty terms and conditions to its consumers and shall cooperate with Cubic and its subsidiaries if Cubic and its subsidiaries require loyalty partners to enforce applicable terms. Loyalty partners shall operate their loyalty programs in compliance with all applicable laws, rules and regulations. 

Cubic, its subsidiaries, and its loyalty partners reserve the right to terminate the program, or modify the program policy, reward criteria, and benefits of the program with or without notice to Consumers even though such changes may affect Consumers’ reward value and benefits accumulated. 

Cubic and its subsidiaries reserve the right to ask loyalty partners, with or without notice to a consumer, to withdraw Star loyalty points redeemed items or values, or update consumers’ star loyalty balance if the consumer is seen to have acted against the loyalty reward program policy or if Stars are erroneously credited to a consumer’s account.

Other than where liable under law, Cubic and its subsidiaries shall have no liability whatsoever to Transit Agencies to or consumers in respect of the services provided under this loyalty rewards policy including but not limited to the nature and availability of the advertising and loyalty program; any content obtained from the services; unauthorized alteration or use of the services; the ability of UMO Rewards™ to generate revenue for the agency, or the availability or functionality of Umo services.

Acronyms and Definitions of Terminology

Ad Click Through Price Per Thousand: The price in the Advertiser’s currency of 1,000 ad clicks.

Ad Response Price Per Thousand: The price in the Advertiser’s currency of 1,000 ad responses (i.e. survey responses).

Ad Response Stars Fee: The amount in the Advertiser’s currency to award in Stars to each Consumer who views the ad.

Ad Response Stars Percentage: The percentage of the ad response price that UMO Rewards™ allocates to star awards.

Ad View Stars Percentage: The percentage of the ad revenue that UMO Rewards™ allocates to star rewards, which counts as a cost to UMO Rewards™.

Advertiser / Advertisers: Organization (or its agency) that has hired UMO Rewards™ for its services in the applicable contract. Advertisers produce ads and place ads via UMO Rewards™ to be displayed to Consumers. Advertisers may sell goods or services to Consumers in physical storefronts.

Consumer / Consumers: Individual persons who use transit services provided by Transit Agencies and who shop at Retailers. Consumers view and interact with ads placed in the Transit Agency’s mobile apps and/or devices. Consumers earn Stars for viewing and interacting with ads, or for events governed by the Transit Agency, and may redeem these Stars at a Transit Agency.

Cost Per Thousand Impressions (CPM): An ad price for 1,000 impressions.

Cost per Thousand Viewable Impressions (vCPM): An ad price for 1,000 viewable impressions that are measured as viewable.

Cost Per View (CPV): An ad price for each view of the ad.

Impressions: Each time 50% of an ad is shown and viewable on the screen for 1 second or longer, it’s counted as one impression.

Sponsor / Sponsors: An advertiser, a Transit Agency, or a third party who pays for advertising or loyalty content to be served on Transit agencies’ device(s).

Star Credit Limit Per Day: The maximum number of stars that a Consumer can be awarded each day.

Star Credit Limit Per Transaction: The maximum number of stars that a Consumer can be awarded for each transaction.

Star Debit Limit Per Day: The maximum number of stars that a Consumer can apply for star redemption each day.

Star Debit Limit Per Transaction: The maximum number of stars that a Consumer can apply for a star redemption transaction.

Star Redemption Increment: The star increments above the Star Redemption Minimum a Consumer must apply for the star redemption. E.g., if the Star Redemption Minimum is 500, and the Star Redemption Increment is 100, then the next valid star redemption amount will be 600, 700, 800…

Star Redemption Minimum: The minimum number of stars a Consumer must have to redeem for dollar value.

Star Redemption/Redeeming Stars: Consumer exchanges Stars for dollar value using Consumer’s Star account inside Transit Agency’s apps and/or mobile devices.

Star Rewards: Stars awarded to Consumer for their qualified loyalty-based ad engagement activities or as per Transit Agency’s own discretion.

Star Wallet: UMO Rewards™’ liability for pools of Stars until redemption.

Stars Purchase Price: The price an Advertiser, or a Transit Agency, or a Third-party partner pays UMO Rewards™ for each star they award to a Consumer.

Stars Settlement Price: The price UMO Rewards™ pays a Transit Agency for each Star that a Consumer redeems.

Transit Agency / Transit Agencies: Organizations that operate transit services. Transit Agencies provide mobile apps and devices whereby UMO Rewards™ can serve display ads on. Transit Agencies award Stars to Consumers for various activities and allow Consumers to redeem Stars for transit services or other products offered by the Transit Agency. Transit Agencies provide tier one customer support to Consumers for their star accounts.

View (Video Ad View): Each time a video ad plays continuously up to 30 seconds or a full duration of the ad of less than 30 seconds, it’s counted as a view.

Viewable Impression: Each time 50% of a video ad is shown and viewable on the screen for 2 seconds or longer, it’s counted as one impression.