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Red Anchor Trading Co. Ltd

PRIVACY STATEMENT

Last Updated: September 12, 2016

This Privacy Statement (“Privacy Statement”) explains how Red Anchor Trading Co. Ltd (“Red Anchor,” “us,” “our,” and “we”) uses your information and applies to all who use our Web site – www.hot-now.com, www.hot-now.net mobile applications - HotNow, electronic services, social networking sites, interactive features, online services, or any of our described online activities we own or control (collectively, “HotNow”). This Privacy Statement is incorporated in our Terms of Use, which also apply when you use HotNow.

By using HotNow, you agree to the terms of this Privacy Statement. If you do not agree with the practices described in this Privacy Statement, please do not provide us with your personal information or interact with HotNow.

We may modify this Privacy Statement at any time. If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of notice on HotNow prior to the change becoming effective. You can determine when this Privacy Statement was last revised by referring to the date it was “Last Updated” above. You can review the last version of this Privacy Statement here.

1. Types of Information We Collect

We will collect information, including personal information and non-identifying Information, when you interact with us and HotNow, for example when you:

access or use HotNow;

register, subscribe, or create an account with HotNow;

open or respond to our e-mails and notifications;

contact customer service or use other customer support tools;

provide information to enroll or participate in other programs provided on behalf of, or together with, business partners;

visit any page online that displays our ads or content;

purchase products or services on or through HotNow;

connect or link to HotNow via social networking sites;

post comments, create companies, create promotions, review companies or promotions to HotNow; and provide information to our vendors.

This Privacy Statement does not apply to the collection of information in any way other than as listed above.

2. Your Choices

We think that you benefit from a more personalized experience when we know more about you and what you like. However, you can limit the information you provide to HotNow, and you can limit the communications that HotNow sends to you.

(a) Commercial E-mails

You may choose not to receive commercial e-mails from us by following the instructions contained in any of the commercial e-mails we send. Please note that even if you unsubscribe from commercial email messages, we may still e-mail you non-commercial e-mails related to your account and your transactions on HotNow.

(b) Cookies and Tracking

You may manage how your browser handles Cookies by adjusting its privacy and security settings. Browsers are different, so refer to instructions related to your browser to learn about cookie-related and other privacy and security settings that may be available. Currently, we do not alter our data collection and use practices in response to Do Not Track signals.

We use non-identifiable information to directly serve you interest-based ads on third party websites. If you prefer not to receive interest-based ads from HotNow on third party sites, you can click on the AdChoices icon in the ad, which will direct you to the your HotNow AdChoices page where you can opt-out of receiving interest-based ads served by HotNow.

(c) Device Data

You may manage how your mobile device and mobile browser share certain device data with HotNow, by adjusting the privacy and security settings on your mobile device. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.

(d) E-mails from Business Partners

If you wish to opt out of receiving offers directly from our business partners, you can follow the opt-out instructions in the emails that they send you.

3. How HotNow Uses Information

We (or our vendors on our behalf), use information collected as described in this Privacy Statement to:

Operate, maintain and improve HotNow and our services, and other programs;

Provide you with interest-based ads and offers for products and services from us and participating business partners;

Facilitate and fulfill orders placed on HotNow and other programs, including tracking redemption of credits;

Evaluate your eligibility for certain types of offers, products or services that may be of interest to you, and analyze advertising effectiveness;

Answer your questions and respond to your requests;

Perform analytics and conduct customer research;

Communicate and provide additional information that may be of interest to you about HotNow and our business partners, sometimes by combining your information with information from other sources;

Send you reminders, technical notices, updates, security alerts, support and administrative messages, service notifications, marketing messages, and requested information, including on behalf of business partners;

Administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored by us or our business partners;

Manage our everyday business needs, such as administration of HotNow, administrative management, fulfillment, analytics, fraud prevention, and enforcement of our corporate reporting obligations and Terms, or to comply with the law;

Allow you to post content or sign up for special offers from merchants, business partners, or third parties through HotNow and other programs, and to

Enhance other information we have about you directly or from other sources to help us better understand you and determine your interests.

We also may use information collected as described in this Privacy Statement with your consent or as otherwise required or permitted by law.

4. When and Why HotNow Discloses Information

We (or our Vendors on our behalf) may share your personal information as required or permitted by law:

with any HotNow affiliate who may only use the personal information for the purposes described in this Privacy Statement;

with our vendors to provide services for us and who are required to protect the personal information;

to report or collect on debts owed to us or our business partners;

with relevant business partners:

with whom we jointly offer products and services;

to facilitate a direct relationship with you, including in connection with any program we administer on behalf of the business partner;

to enable electronic communications with you as part of purchase, reward, offer, contest, program, or other activity in which you have elected to participate;

to the extent you have purchased or saved and redeemed a HotNow promotion, goods or services offered by HotNow or a business partner or participated in an offer, reward, contest, credits or other activity or other programs sponsored or offered through HotNow or behalf of that business partner;

with a purchaser of HotNow or any of the HotNow affiliates (or their assets);

to comply with legal orders and government requests, or as needed to support auditing, compliance, and corporate governance functions;

to combat fraud or criminal activity, and to protect our rights or those of our affiliates, users, and business partners, or as part of legal proceedings affecting HotNow;

in response to a subpoena, or similar legal process, including to law enforcement agencies, regulators, and courts in Thailand and other countries where we operate; or with your consent.

We encourage business partners to adopt and post privacy policies. However, their use of personal information obtained through HotNow is governed by their privacy policies and is not subject to our control.

We may also disclose non-Identifiable information:

for the same reasons we might share personal information;

with business partners for their own analysis and research;

to facilitate targeted content and ads; or

with third-party ad-servers to place our ads and/or ads of our merchants or business partners on HotNow and on third-party sites, and to analyze the effectiveness of those ads.

We do not share personal information with third-party ad-servers; however, third-party ad-servers may automatically collect non-identifying information about your visit to HotNow and other websites, your device address, your internet service provider and the browser you use to visit HotNow. They do this by using cookies, clear gifs and other technologies. Information collected may be used, among other things, to deliver advertising targeted to your interests and to better understand the usage and visits to HotNow and the other websites tracked by these third parties. This Privacy Statement does not cover the collection methods or use of the information collected by third-party ad-servers, and Red Anchor is not responsible for Cookies or clear gifs in third party ads.

5. How HotNow Collects Information

You provide us with your personal information when you register, subscribe, create an account, make a purchase, or otherwise when you provide us with your personal information during your interaction with HotNow and other programs. We also collect personal information when you contact us online for customer service and other support using self-help tools, such as email, text, or by posting to HotNow.

We also receive personal information and other online and offline information from other sources. HotNow will use such information in accordance with applicable laws. Such information, when combined with personal information collected as provided in this Privacy Statement, will also be handled in accordance with this Privacy Statement. We also use cookies, tags, web beacons, local shared objects, files, tools and programs to keep records, store your preferences, improve our advertising, and collect non-identifying information, including device data and your interaction with HotNow and our business partners' web sites. Device data may be collected when your device interacts with HotNow, even if you are not logged into HotNow using your device.

6. Security of Personal Information

HotNow has implemented an information security program that contains administrative, technical and physical controls that are designed to reasonably safeguard personal information. No method of transmission over the internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security, you can contact us at support@hot-now.com.

7. Accessing and Correcting Personal Information

You can access, update and delete your, information, you provided to us by managing this information through your HotNow account or sending us an email at support@hot-now.com. Keeping your personal information current helps ensure that we, our affiliates and business partners offer you the offers that are most relevant to you.

We will retain your personal information for as long as your account is active or as needed to provide you services and to maintain a record of your transactions for financial reporting purposes.

If you want to deactivate your HotNow account or have other questions or requests, please contact us at support@groupon.com. While we are ready to assist you in managing your subscriptions, deactivating your account, and removing your active profile, we cannot always delete records of past interactions and transactions. We will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

8. Social Networks

You may log in to HotNow using certain social network credentials. To manage the sharing of certain personal information with us when you connect with us through social networking platforms or applications refer to the privacy policy and settings of the social networking website or application.

By proceeding the above steps, you grant HotNow permission to access all of the elements of your social network profile information that you have made available to be shared and to use it in accordance with the social network’s terms of use and this Privacy Statement.

9. Privacy Practices of Third Parties

This Privacy Statement only addresses the use and disclosure of information by Red Anchor through your interaction with HotNow. Other websites that may be accessible through links from HotNow and other programs may have their own privacy statements and personal information collection, use, and disclosure practices. Our business partners may also have their own privacy statements. We encourage you to familiarize yourself with the privacy statements provided by these other parties prior to providing them with information or taking advantage of a sponsored offer or promotion.

10. Notice to Residents of Countries outside of Thailand

If you live outside of Thailand (including in the European Economic Area (“EE”) and Switzerland (“CH”) collectively the “EEA/CH”), and you use HotNow or provide us with personal information directly via HotNow, your information will be handled in accordance with this Privacy Statement. By using HotNow or giving us your personal information, you are directly transferring your personal information and non-identifiable Information to us in Thailand. Thailand may not have the same level of data protection as your jurisdiction. However, you agree and consent to our collection, transfer, and processing of your personal information and non-identifiable information in accordance with this privacy statement. You are solely responsible for compliance with any data protection or privacy obligations in your jurisdiction when you use HotNow or provide us with personal information. Regardless of where we transfer your information, we still protect your information in the manner described in this Privacy Statement.

11. Children’s Privacy

Red Anchor does not intend that any portion of HotNow will be accessed or used by children under the age of thirteen, and such use is prohibited. HotNow is designed and intended for adults. By using HotNow, you represent that you are at least thirteen years old and understand that you must be at least thirteen years old in order to create an account. To purchase the goods or services advertised through HotNow . We will promptly delete information associated with any HotNow account be obtain actual knowledge is associated with a registered user who is not at least thirteen years old.

HotNow Merchant does not intend that any portion of HotNow Merchant will be accessed or used by a registered user who is under the age of eighteen, and such use is prohibited. HotNow Merchant is designed and intended for adults. By using HotNow Merchant, you represent that you are at least eighteen years old and understand that you must be at least eighteen years old in order to create an account and purchase the goods or services advertised through HotNow. We will promptly delete information associated with any HotNow account be obtain actual knowledge is associated with a registered user who is not at least eighteen years old.

12. Glossary of Terms

Affiliate means an entity owned, directly or indirectly, by Red Anchor Trading Co. Ltd or that is controlled by or under common control with Red Anchor Trading Co. Ltd and also includes joint ventures entered into by Red Anchor Trading Co. Ltd and/or its Affiliates.

Business Partners means, collectively, third parties with whom we conduct business, such as merchants, co-marketers, distributors, and resellers.

Cookie means a unique identifier, usually made up of small bits of text or code.

Device Data means information concerning a device you use to access, use, or interact with HotNow, such as operating system type or mobile device model, browser type, domain, and other system settings, the language your system uses and the country and time zone of your device, geo-location, unique device identifier or other device identifier, mobile phone carrier identification, and device software platform and firmware information.

Non-Identifying Information means information that alone cannot identify you, including data from Cookies, Pixel Tags and Web Beacons, and Device Data. Non-Identifying information may be derived from personal information.

Other Programs means special programs, features and functionality on HotNow or other co-branded websites with Business Partners that we reasonably control and that have special use terms applicable to such special programs, features and functionality.

Other Sources means sources of information that legally provide Red Anchor with your information, and which are outside the scope of this Privacy Statement at the time of collection.

Personal Information means information about you that specifically identifies you or, when combined with other information we have, can be used to identify you. This includes the following types of information:

Contact Information: your name, postal addresses, email addresses, social networking user account names, telephone numbers, or other addresses at which you are able to receive communications.

Relationship Information: information you provide that enables us to determine lifestyle, interests, and activities, including location information related to your state/province, city, or neighborhood; areas of interest, the types of promotions that interest you, information collected through your interactions with social networks, demographic information (e.g., birth date, age, gender); information about persons for whom you have shared or gifted promotions with or who have shared or redeemed promotions that were shared or given to them as gifts from you; and information about friends who refer you or whom you have referred;

Transaction Information: information you provide when you interact with us and HotNow, such as the promotions you are interested in, save, redeem or gift; email and other communications; and how you interact with business partners and our vendors; and

Third-Party Ad-Servers means Vendors and other third parties that provide the technology to place ads on websites and track ad performance.

Vendors means, collectively, third parties that perform business operations on behalf of Red Anchor, such as transaction processing, billing, mailing, communications services (e-mail, direct mail, etc.), marketing, data processing and analytics, servicing, collections, or ad management.

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