Legal

Last updated: January 13, 2026

This Marketing & Communications Policy (the "Policy") describes how Oshi Technologies, Inc. ("Oshi," "we," "us") facilitates customer communications on behalf of participating merchants through the Oshi platform (the "Platform").

This Policy applies to merchants using Oshi to issue rewards, operate loyalty programs, or communicate with customers regarding rewards-related activity. This Policy supplements and is incorporated into the Oshi Merchant Agreement and Terms of Service.

1. Role of Oshi

Oshi acts as a technology service provider that facilitates rewards-related and loyalty program communications on behalf of merchants.

Oshi does not independently market merchant products or services and does not initiate customer communications without merchant authorization and customer opt-in.

All communications sent through the Platform are:

• merchant-authorized,
• programmatic in nature, and
• directly related to a customer's participation in a merchant's rewards or loyalty program.

2. Types of Communications Sent

Oshi may send communications on behalf of a merchant that are directly related to rewards and loyalty program participation, including without limitation:

• notifications that rewards were earned
• instructions to claim rewards
• reminders to claim rewards (including follow-ups at defined intervals)
• notices of reward expiration or forfeiture
• information on how rewards may be redeemed at the merchant
• confirmations of reward redemption or withdrawal
• prompts to earn additional rewards through referrals, social engagement, or merchant-defined actions
• loyalty program status updates

These communications may be delivered via email or SMS depending on customer opt-in preferences and merchant configuration.

Oshi does not send:

• unrelated advertising,
• third-party promotions,
• cross-merchant marketing messages, or
• discretionary campaigns outside the scope of the rewards program.

3. Customer Opt-In and Consent

Oshi only sends communications to customers who have opted in through a participating merchant.

Opt-in may occur through:

• a merchant's point-of-sale system,
• checkout or ecommerce flow,
• account creation or loyalty enrollment,
• explicit consent captured by the merchant,
• confirmation links used to claim rewards.

If a customer does not complete required claim or confirmation steps, rewards may expire and communications may cease.

Merchants are responsible for ensuring that customer opt-in is collected in compliance with applicable law. Oshi relies on opt-in signals and customer data provided by merchants.

4. Merchant-Provided Customer Data

Merchants may provide Oshi with customer identifiers (such as email address or phone number) and transaction data solely for purposes of operating the rewards program and associated communications.

Merchants represent and warrant that:

• they have the right to provide such data to Oshi, and
• customer consent has been obtained where required.

Oshi uses this data only to operate the Platform and facilitate merchant-authorized communications.

5. Message Content and Templates

By default, communications are sent using Oshi-provided templates that are branded on behalf of the merchant and tailored to the merchant's loyalty program configuration.

Merchants may have limited customization options depending on integration or configuration, but may not use the Platform to send:

• free-form marketing campaigns,
• cold outreach,
• unrelated promotional messages, or
• content outside the rewards program scope.

Oshi reserves the right to approve, modify, or restrict messaging content to ensure compliance with law and platform standards.

6. Uploads and Retroactive Reward Notices

Merchants may, in limited circumstances, upload transaction records for the purpose of issuing rewards for prior qualifying activity (e.g., historical purchases or backfill).

Any resulting communications:

• use standard Platform templates,
• are limited to rewards-related notifications, and
• are sent only where the merchant has determined appropriate customer consent exists.

Oshi does not permit cold outreach or prospecting through transaction uploads.

7. Opt-Outs and Communication Preferences

Recipients may opt out of receiving communications at any time by following the unsubscribe or opt-out instructions included in a message (such as replying STOP to an SMS) or by contacting Oshi support.

Opt-outs are enforced on a merchant-program basis. If a recipient opts out of communications related to a particular merchant's rewards or loyalty program, Oshi will no longer send messages on behalf of that merchant through the same communication channel.

Opting out of communications from one merchant does not automatically opt a recipient out of communications from other merchants with whom the recipient has a separate relationship and has provided a separate opt-in.

Oshi enforces opt-out signals consistently across all Oshi-facilitated communications for the applicable merchant and channel, including transactional, rewards-related, and loyalty program messages.

Merchants are responsible for ensuring that their customer records, consent signals, and opt-out statuses are accurate and compliant with applicable law. Oshi relies on merchant-provided opt-in and opt-out information when sending communications on behalf of merchants.

8. Sender Identification

Communications may appear to originate from the merchant based on branding, sender name, or domain configuration.

However, messages are sent by Oshi as a service provider acting on behalf of the merchant.

9. Compliance

This Policy is designed to support compliance with applicable laws and regulations, including but not limited to:

• CAN-SPAM
• TCPA
• applicable state marketing and consumer protection laws

Merchants remain responsible for their own compliance obligations and customer relationships.

10. Policy Updates

Oshi may update this Policy from time to time. Continued use of the Platform constitutes acceptance of the updated Policy.

11. Contact

Questions regarding this Policy may be directed to:

Email: support@oshi.tech

Mail:

Oshi Technologies, Inc.
621 E 6th St
Austin, TX 78701