1. DEFINITIONS

Undefined terms in this Privacy Policy have the same definition as in our Terms of Service (“Terms”).

2. PERSONAL INFORMATION WE COLLECT

2.1 Information needed to use the Horse Races Now Platform.

We collect personal information about you when you use the Horse Races Now Platform. Without it, we may not be able to provide you with all services requested. This information includes:

• Contact Information, Account, Profile Information. Such as your first name, last name, phone number, postal address, email address, date of birth, and profile photo, some of which will depend on the features you use.

2.2 Information you choose to give us.

You can choose to provide us with additional personal information. This information may include:

• Additional Profile Information. Such as gender, preferred language(s), city, and personal description. Some of this information as indicated in your account settings is part of your public profile page and will be publicly visible.
• Address Book Contact Information. Address book contacts you import or enter manually.
• Other Information. Such as when you fill in a form, add information to your account, respond to surveys, post to community forums, participate in promotions, communicate with our customer care team and other Members, or share your experience with us. This may include health information if you choose to share it with us.

2.3 Information Automatically Collected by Using the Horse Races Now Platform.

When you use the Horse Races Now Platform and Payment Services, we automatically collect personal information. This information may include:

• Geo-location Information. Such as precise or approximate location determined from your IP address or mobile device’s GPS depending on your device settings. We may also collect this information when you’re not using the app if you enable this through your settings or device permissions.
• Usage Information. Such as the pages or content you view, searches for Listings, bookings you have made, and other actions on the Horse Races Now Platform.
• Log Data and Device Information. Such as details about how you’ve used the Horse Races Now Platform (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Horse Races Now Platform. We may collect this information even if you haven’t created an Horse Races Now account or logged in.
• Cookies and Similar Technologies as described in our Cookie Policy.
• Payment Transaction Information. Such as payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address and other related transaction details.

2.4 Personal Information We Collect from Third Parties.

We collect personal information from other sources, such as:.

• Third-Party Services. If you link, connect, or login to the Horse Races Now Platform with a third party service (e.g. Google, Facebook, WeChat), you direct the service to send us information such as your registration, friends list, and profile information as controlled by that service or as authorized by you via your privacy settings at that service.
• Background Information. For Members in the United States, to the extent permitted by applicable laws, we may obtain reports from public records of criminal convictions or sex offender registrations. For Members outside of the United States, to the extent permitted by applicable laws and with your consent where required, we may obtain the local version of police, background or registered sex offender checks. We may use your information, including your full name and date of birth, to obtain such reports.
• Enterprise Product Invitations and Account Management. Organizations that use our Enterprise products may submit personal information to facilitate account management and invitations to use enterprise products.
• Referrals and co-travelers. If you are invited to the Horse Races Now Platform such as a co-traveler on a trip, the person who invited you can submit personal information about you such as your email address or other contact information.
• Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as references, demographic data or information to help detect fraud and safety issues from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results or fraud warnings from identity verification service providers for use in our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Horse Races Now Platform, or about your experiences and interactions from our partners. We may receive health information, including but not limited to health information related to contagious diseases.

3. HOW WE USE INFORMATION WE COLLECT

3.1 Provide, Improve, and Develop the Horse Races Now Platform. We use personal information to:

• enable you to access the Horse Races Now Platform and make and receive payments,
• enable you to communicate with other Members,
• perform analytics, debug and conduct research,
• provide customer service,
• send you messages, updates, security alerts, and account notifications,
• personalize and customize your experience based on your interactions with the Horse Races Now Platform, your search history, your profile information and preferences, and other content you submit, and

3.2 Create and Maintain a Trusted and Safer Environment. We use personal information to:

• detect and prevent fraud, spam, abuse, security and safety incidents, and other harmful activity,
• study and combat discrimination consistent with our Nondiscrimination Policy,
• conduct security investigations and risk assessments,
• verify or authenticate information provided by you,
• conduct checks against databases and other information sources, including background or police checks,
• comply with our legal obligations, protect the health and well-being of our Guests, Hosts, Hosts’ employees and members of the public,
• resolve disputes with our Members,
• enforce our agreements with third parties,
• comply with law, respond to legal requests, prevent harm and protect our rights (see section 4.5)
• enforce our Terms and other policies (e.g. Nondiscrimination Policy), and
• in connection with the activities above, we may conduct profiling based on your interactions with the Horse Races Now Platform, your profile information and other content you submit to Horse Races Now, and information obtained from third parties. In limited cases, automated processes could restrict or suspend access to the Horse Races Now Platform if such processes detect activity that we think poses a safety or other risk to Horse Races Now, our community, or third parties. If you would like to challenge the decisioning based on the automated process, please contact us via the Contact Information section below.

3.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing. We may use personal information to:

• send you promotional messages, marketing, advertising, and other information based on your preferences and social media advertising through social media platforms,
• personalize, measure, and improve our advertising,
• administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Horse Races Now or its third-party partners,
• analyze characteristics and preferences to send you promotional messages, marketing, advertising and other information that we think might be of interest to you, and
• invite you to events and relevant opportunities.

3.4 Provide Payment services. Personal information is used to enable or authorize third parties to use Payment Services:

• Detect and prevent money laundering, fraud, abuse, security incidents.
• Conduct security investigations and risk assessments.
• Comply with legal obligations (such as anti-money laundering regulations).
• Enforce the Payment Terms and other payment policies.
• With your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences.
• Provide and improve the Payment Services.

4.1 Sharing With Your Consent or at Your Direction.

Where you provide consent, we share your information as described at the time of consent, such as when authorizing a third-party application or website to access your Horse Races Now account or participating in promotional activities by Horse Races Now partners or third parties.

Where permissible with applicable law, we may use certain information about you, such as your email address, de-identify it, and share it with social media platforms, to generate leads, drive traffic to Horse Races Now or otherwise promote our products and services.

4.2 Complying with Law, Responding to Legal Requests, Preventing Harm and Protecting our Rights.

We may disclose your information to courts, law enforcement, governmental or public authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or where disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with a valid legal request or to respond to claims asserted against Horse Races Now, (iii) to respond to a valid legal request relating to a criminal investigation to address alleged or suspected illegal activity, or to respond to or address any other activity that may expose us, you, or any other of our users to legal or regulatory liability (more information on Horse Races Now’s Law Enforcement Guidelines here), (iv) to enforce and administer our agreements with Members, or (v) to protect the rights, property or personal safety of Horse Races Now, its employees, its Members, or members of the public. For example, if permitted due to the foregoing circumstances, Host tax information may be shared with tax authorities or other governmental agencies.

Where appropriate, we may notify Members about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon or harm to Horse Races Now, our Members, or expose Horse Races Now to a claim of obstruction of justice.

For jurisdictions where Horse Races Now facilitates the collection and remittance of Taxes where legally permissible according to applicable law, we may disclose Hosts’ and Guests’ information about transactions, bookings, Accommodations and occupancy Taxes to the applicable tax authority, such as Host and Guest names, Listing addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received (or due) by Hosts from Guests, and contact information.

In jurisdictions where Horse Races Now facilitates or requires a registration, notification, permit, or license application of a Host with a local governmental authority through Horse Races Now in accordance with local law, we may share information of participating Hosts with the relevant authority, both during the application process and, periodically thereafter, such as the Host’s full name and contact details, Accommodation address, tax identification number, Listing details, and number of nights booked.

4.3 Service Providers.

We share personal information with affiliated and unaffiliated service providers to help us run our business, including service providers that help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background or police checks, fraud prevention, and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of the Horse Races Now Services through third-party platforms and software tools (e.g. through the integration with our APIs), (vi) provide customer service, advertising, or payments services, (vii) process, handle or assess insurance claims or similar claims, or (viii) facilitate non-profit and charitable activities consistent with Horse Races Now’s mission. These providers are contractually bound to protect your personal information and have access to your personal information to perform these tasks.

4.4 Business Transfers.

If Horse Races Now undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

4.5 Corporate Affiliates.

To support us in providing, integrating, promoting and improving the Horse Races Now Platform, Payment Services, and our affiliates’ services, we may share personal information within our corporate family of companies that are related by common ownership or control. Some examples are:

• Sharing with Horse Races Now, Inc. Even if your country of residence is not the United States, your information will be shared with Horse Races Now, Inc. which provides the technical infrastructure for the Horse Races Now Platform.
• Sharing with Horse Races Now Payments. In order to facilitate payments on or through the Horse Races Now Platform, certain information as described in the “Outside of the United States” section, will be shared with the relevant Horse Races Now Payments entity.
• Sharing with Horse Races Now GSL. Even if your country of residence is not Japan, your information may be shared with Horse Races Now GSL which provides customer support and other business operation services to other Horse Races Now entities.
• Sharing with Horse Races Now China. Even if your country of residence is not China, some of your information will be shared with Horse Races Now China in the following circumstances:
• Public data. Information you share publicly on the Horse Races Now Platform.

The data sharing described above is necessary for the performance of the contract between you and us to enable you to list or book Host Services in China and connect with Members in China, and vice versa. Where required under law or if you have expressly granted permission, Horse Races Now China will disclose your information to Chinese government agencies without further notice to you. We’ll notify you in advance in specific situations where we apply any practices that differ from what is described in this Privacy Policy (including practices pertaining to disclosures to government agencies).

5. OTHER IMPORTANT INFORMATION

5.1 Analyzing your Communications.

We may review, scan, or analyze your communications on the Horse Races Now Platform for reasons outlined in the “How We Use Information We Collect” section of this policy, including fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, enforcing our Terms of Service, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other sites. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. Occasionally we may need to manually review communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your messaging communications to send third-party marketing messages to you and we will not sell reviews or analyses of these communications.

5.2 Linking Third-Party Accounts.

You can link your Horse Races Now account with certain third-party services like social networks. Your contacts on these third-party services are referred to as “Friends.” When you direct the data sharing by creating this link:

• some of the information provided to us from linking accounts may be published on your public profile,
• your activities on the Horse Races Now Platform may be displayed to your Friends on the Horse Races Now Platform and/or that third-party service,
• a link to your public profile on that third-party service may be included in your Horse Races Now public profile,
• other Horse Races Now users may be able to see any Friends that you may have in common with them, or that you are a Friend of their Friend if applicable,
• other Horse Races Now users may be able to see any schools, hometowns or other groups you have in common with them as listed on your linked social networking service,
• information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes, and
• publication and display of information that you provide to the Horse Races Now Platform through this linkage is subject to your settings and authorizations on the Horse Races Now Platform and the third-party service.

5.3 Third-Party Partners & Integrations.

Parts of Horse Races Now may link to third-party services, not owned or controlled by Horse Races Now, such as Google Maps/Earth. Use of these services is subject to the privacy policies of those providers, such as Google Maps/Earth Additional Terms of Use, Google Privacy Policy (see here for more information on how Google uses information), and Citi Privacy Policy. Horse Races Now does not own or control these third parties and when you interact with them you are providing your information to them.

6. YOUR RIGHTS

You can exercise any of the rights described in this section consistent with applicable law. Contact us for information on data subject rights requests and how to submit a request. Please note that we may ask you to verify your identity and request before taking further action on your request.