ALOTE-Pay Per Click Platform

ALOTE.IO understands that our users care about their personal data and how it is collected, used, shared, and cared for. We are committed to handling your personal data in accordance with the applicable laws when you use any of the features, or functions on our Platform or Services, interact with us via an external service, or application or through our customer service agents, or access our Services or our Platform through your computer, mobile device, or any other device with Internet connectivity.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY CLICKING OR CHECKING “SIGN UP”, “I AGREE TO ALOTE.IO’S PRIVACY POLICY”, “I AGREE AND CONSENT TO THE COLLECTION, USE, DISCLOSURE, STORAGE, TRANSFER AND/OR PROCESSING OF MY PERSONAL DATA FOR THE PURPOSE STATED IN, AND UNDER THE TERMS OF, ALOTE.IO’s PRIVACY POLICY” OR SIMILAR

STATEMENTS AVAILABLE AT THE ALOTE.IO REGISTRATION PAGE OR IN THE COURSE OF PROVIDING YOU WITH THE SERVICES OR ACCESS TO THE PLATFORM, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THE TERMS OF THIS PRIVACY POLICY AND THAT YOU HAVE AGREED AND CONSENTED TO THE COLLECTION, USE, DISCLOSURE, STORAGE, TRANSFER AND/OR PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED AND UNDER THE TERMS HEREIN.

1. Introduction

Alote.io, operated by Thingaha International Co., Ltd. (hereinafter referred to as "We," "Our," or "Us"), is firmly committed to safeguarding and respecting your privacy rights. We endeavor to consistently comply with the requirements laid down by the Personal Data Protection Act B.E. 2562 (2019), Thailand (hereinafter referred to as "PDPA").

This Privacy Policy concerns the personal data we collect, process, use and disclose, while you utilize our services, interact with us, or browse our website. By visiting our website and using our services, you agree to the data practices, as described in this policy.

It is important that you read this Privacy Policy together with any other applicable notices we may provide for special applications where when we are collecting, using, disclosing and/or

processing personal data about you, so that you are fully aware of how and why we are using your personal data.

We may update this Privacy Policy from time to time. Any changes we make to this Privacy Policy in the future will be reflected on this page and material changes will be notified to

you. Where permissible under local laws, your continued use of the Services or access to the Platform, including buying packages (as defined in the Employer and Employee Policy) on the Platform, or express consent thereto, following the modifications, updates, or amendments to this Privacy Policy (whether or not you have reviewed such document) shall constitute your acknowledgment and acceptance of the changes we make to this Privacy Policy. You agree that it is your responsibility to review and check the Privacy Policy frequently to see if any updates or changes have been made to this Privacy Policy.

This Privacy Policy applies in conjunction with other notices, contractual clauses, and consent clauses that apply in relation to the collection, storage, use, disclosure, and/or processing of your personal data by us and is not intended to override them unless we state expressly otherwise.

All of these terms apply to ALOTE.IO users, whether or not the users have created an account as employer and/or employee unless otherwise stated specifically to apply only to employers or only

to employees.

2. Collection and Purpose of Personal Data

We may collect personal data through automated means like cookies, in addition to data you voluntarily provide to us. The personal data collected may include contact details, account-related information, business information, preferences, or other personal or identifiable data. This collected data aims to provide optimum services, ensure security, personalize experiences, resolve disputes, prevent illegal activities, communicate, comply with legal obligations, or as otherwise stated.

We assure you that these actions will be done pursuant to PDPA laws, ensuring the relevance and necessity of the collected data to the means for which it was gathered.

2.1. We collect the personal data described below in accordance with applicable local laws and, if required, upon obtaining your consent.

2.2. Personal data means any information about an individual, whether recorded in a material form or not and whether true or not, who can be identified from that data (whether directly or indirectly), or from that data and other data to which we have or are likely to have access.

2.3. Depending on your use of our Platform and/or your interaction with our Services (such as when registering for our Services and/or logging into our Platform), you may be asked to provide us with certain information. While you can choose not to provide us with certain information, you might not be able to take advantage of many of our Services that are provided to you. The personal data that you may opt to provide to us are as follows

(a) Identity and Profile Data, which may include your name, date of birth, gender, username and password, email address, telephone number, your interests, and any personal data in any photographs, videos, or audio recordings that you upload onto our Platform.

(b) Account and Transaction Data, which may include your credit card details, bank account details, bank statements, delivery/billing address, payments and orders to and from you, and other details of products and services that you have supplied to or purchased through the Platform.

(c) Usage Data, such as information about how and when you use the Platform, products, and Services or view any content on the Platform, as well as websites you were visiting before you came to the Platform and other similar statistics.

(d) Location data and age range whether your specific regions and your age group to important to us for marketing purposes.

2.4. During the course of your use of the Platform and our provision of the Services, we may receive personal data from you in the following situations:

(a) When you browse our websites (both mobile and web versions);

(b) When you create an account with us (as employer or employee or otherwise);

(c) When you apply for, subscribe to, or otherwise use any of the Services on our Platform and/or on the platforms of our affiliates;

(d) When you make a transaction regarding the products available on the Platform;

(e) When you activate or use any payment-related functions available on the Platform or provided by our third-party service providers (such as payment gateway)

(f) When you use the chat function on the Platform;

(g) When you subscribe to our publications or marketing collaterals;

(h) When you enter a competition, promotion, or survey;

(i) When you participate in any activity or campaign on the Platform;

(j) When you log in to your account on the Platform or otherwise interact with us via an external service or application, such as Google;

(k) When a third party lodges a complaint against you or the content you have posted on the Platform; and

(l) When you interact with us offline, including when you interact with our outsourced customer service agents.

2.5. We may collect personal data from you, third parties (including but not limited to agents, vendors, contractors, partners, and any others who provide services to us, who collect

your personal information and/or perform functions on our behalf, or with whom we collaborate, including but not limited to payment service providers, government sources of data, financial services providers, credit bureaus, delivery, marketing, and other service partners), our affiliates, or such data may be collected automatically when you use the Platform or the Services, asset out in this section. Please see also Sections 2.11 to 2.16 on the collection of computer data.

2.6. During the course of your use of the Platform and our provision of the Services, you agree that you have provided your consent (whether to us, the third party, or our affiliates) to the transfer of your personal data from third parties and/or our affiliates to Alote.io for the purposes set out in this Privacy Policy or any other terms.

2.7. You agree to only submit personal data that is accurate and not misleading to keep it up to date and to inform us of any changes to the personal data that you have provided to us.

We shall have the right to request documentation and carry out the necessary checks to verify the personal data provided by you as part of our user verification processes or as required under law.

2.8. We will only be able to collect certain categories of personal data if you voluntarily provide the personal data to us or as otherwise provided for under this Privacy Policy. If you choose not to provide your personal data to us or subsequently withdraw your consent to our use of your personal data, we may not be able to provide you with certain features or functionality on the Services or access to the Platform.

2.9. In some situations, you may provide personal data of other individuals to us (such as your family members or friends or persons in your contact list), when you use the “RELATED WITH ME" or similar function, or when you add them as recipients or beneficiaries of any use of our Services. You represent and warrant that you have obtained the necessary consent, license, and permissions from such individuals to share and transfer his/her personal data to us, and for us to collect, store, use, disclose, or otherwise process that data in accordance with this Privacy Policy.

2.10. If you sign up to be a user on our Platform using your social media account, or link your Alote.io account to your social media account or use certain other Alote.io social media features, we may access personal data about you that you have voluntarily provided to your social media provider in accordance with the provider's policies and we will manage your personal data in accordance with this Privacy Policy.

Collection of Computer Data

2.11. Our authorized service providers may use cookies, web beacons, and other similar technologies in connection with your use of the Services of the access of the Platform.

2.12. When you visit the Platform through your computer, mobile device, or any other device with Internet connectivity, our company servers will automatically record data that your browser sends whenever you visit a website, such as the technical data and usage data outlined in Section 2.2 above.

2.13. This data is collected for analysis and evaluation in order to help us improve our website and the services and products we provide, as well as to help us to personalize the content to match your preferred interests more quickly. The data is also collected to make the Services and the Platform more convenient and useful to you and to provide more relevant advertising related to market products, services, and features to you.

2.14. Cookies are small text files (typically made up of letters and numbers) placed in the memory of your browser or device when you visit a website or view a message. They allow us to recognize a particular device or browser. Web beacons are small graphic images that may be included in our Services and the Platform. They allow us to count users who have viewed these pages so that we can better understand your preferences and interests.

2.16. You may be able to manage and delete cookies through your browser or device settings. However, certain cookies are required to enable core functionality (such as adding items to your shopping basket), so please note that changing and deleting cookies may affect the functionality available on the Platform or through our Services.

3. Consent and Rights Concerning Personal Data

We only collect and process personal data after obtaining explicit consent, except for circumstances permitted by law. You possess the right to withdraw consent, be informed, access, rectify, erase, limit the use or disclosure, transfer, and object to your personal data processing. Any change in consent can be communicated to us, and we will respect and swiftly act on your requests.

3.1. You have the right to obtain personal data about you that we hold in a format that is readable or commonly used by ways of automatic tools or equipment and can be used or disclosed by automated means.

3.2. You are also entitled to:

make a request for us to send or transfer the personal data in such formats to other organizations if it can be done by automatic means; and

request to directly obtain personal data in such formats that is sent or transferred to other organizations, unless it is impossible to do so because of technical circumstances.

3.3. You are entitled to restrict the processing of your personal data in the following circumstances if:

We are in the process of examining your rectification request;

When personal data is subject to the right of erasure and you request for its use to be restricted instead;

When it is no longer necessary for the personal data to be retained, but you request for its retention to establish, comply with, exercise, or defend against legal claims; or

When we are in the process of verifying or examining your objection request.

3.4. You have the right to object to the processing of your personal data in the following circumstances:

Where the personal data is processed based on our legitimate interest or that of other persons unless an exception applies;

Where the personal data is processed for the purpose of direct marketing; or

Where the processing is for the purpose of scientific, historical, or statistical research unless an exception applies;

3.5. You are entitled to request to have your personal data erased, destroyed or anonymized in the following circumstances:

(a) the personal data is no longer necessary in relation to the purposes for which it was collected;

(b) You withdraw your consent on which the processing is based so we have no legal grounds for such processing;

(d) Your personal data has been unlawfully processed.

3.6. If you believe that our processing of your personal data is unlawful or non-compliant with the applicable data protection laws, you also have the right to lodge a complaint with the competent authority.

4. Disclosure and transfer of Personal Data

Your personal data will not be disclosed to third parties without explicit consent or as per legal obligations, both under local laws and international treaties. In case of personal data transfer overseas, we ensure proper procedural safeguards to ensure the same level of protection as provided within Thailand.

4.1. We use and disclose personal data for the purposes described below in accordance with applicable local laws and, if required, upon obtaining your consent.

4.2. Depending on your relationship with us (for example, whether you are an employee, an employer, a visitor to our websites, or a user of our mobile applications), the personal data that we collect from you or via third parties may be used for certain purposes, as follows:

To facilitate your use of the Services or access to the Platform.

To administer the online account that you may have set up with us.

To conduct analytics, research, business, and development:

To better understand user experience with the Services and the Platform;

To improve the layout or content of the pages of the Platform and customize them for users;

To identify visitors on the Platform;

To conduct surveys, including carrying out research on our users’ demographics and behavior to improve our current technology (e.g. voice recognition tech, etc.) via machine learning or other means;

To derive further attributes relating to you based on personal data provided by you (whether to us or third parties), in order to provide you with more targeted and/or relevant information;

To conduct data analysis, testing and research, monitoring and analyzing usage and activity trends; and

To further develop our products and services.

(d) Legal and operational purposes

To ascertain your identity in connection with fraud detection purposes;

To compare information, and verify with third parties in order to ensure that the information is accurate;

To process any complaints, feedback, enforcement action, and take-down requests in relation to any content you have uploaded to the Platform;

To produce statistics and research for internal and statutory reporting and/or record-keeping requirements;

To store, host, and back up your personal data for operational, legal, or business purposes;

To share personal data in connection with any proposed purchase, merger, or acquisition of any part of our business, provided that we satisfy the requirements of applicable data protection law when disclosing your personal data;

To prevent or investigate any actual or suspected violations of our Terms of Use, Privacy Policy, or any of our policies, fraud, unlawful activity, omission, or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us;

To perform due diligence checks;

To comply with legal and regulatory requirements (including, where applicable, the display of your name, contact details, and company details), including any law enforcement requests, requests by any governmental or regulatory authority having jurisdiction over Alote.io, in connection with any legal proceedings, or as otherwise deemed necessary by us; and

To protect the life, health, or personal safety of our employees, its users, and/or the public.

(e) Any other purpose for which your consent has been obtained, in compliance with our obligations under applicable laws, including notifying you at the time of obtaining your consent.

4.3. Where you are an employee and/or you have signed in or registered with us, the personal data that we collect from you or via third parties may be used for other purposes, as follows:

Processing your order to top up

To process orders you submit through the Platform;

To verify and carry out payment transactions (including any credit card payments, bank transfers, offline payments, remittances, or e-wallet transactions) in relation to payments related to you, promotions participated in by you, and/or Services used by you. In order to verify and carry out such payment transactions, payment information, which may include personal data, will be transferred to third parties such as our payment service providers.

(b) Providing Services

To display your name, username, or profile on the Platform (including on any reviews, and feedback you may post);

To respond to your queries, feedback, claims, or disputes, whether directly or through our third-party service providers;

To display on scoreboards on the Platform in relation to campaigns or any other activity;

To allow other users to identify you (via the “Find user name" or any other similar function) as a user of the Service, to allow you to find other users and to connect with them on the Platform, and to support the socializing function or transfer to the wallet of the Services (where applicable);

To assess your application for loan facilities and/or to perform credit risk assessments in relation to applications for financial services and products, such as credit or loan facilities, insurance, or credit cards (where applicable); and

To provide you with information we think you may find useful or which you have requested from us;

To send you marketing or promotional information about us;

To help us conduct marketing and advertising; and

To promote the Services and use the information that you give to us, such as user-generated content (including video content) that you can choose to upload or broadcast on our Platform and will be accessible on the Internet and may be shared by the public (the latter of which is not within our control), as part of our advertising and marketing campaigns to promote the Platform.

(d) Other

To know our buyers better; and

To conduct automated decision-making processes in accordance with any of the above purposes, which will be carried out in compliance with our obligations under applicable laws, including notifying and obtaining your consent to the same.

5. Data Retention and Security

We retain your personal data as long as it is necessary for the purposes, in compliance with PDPA and other applicable laws. We have implemented appropriate technological and organizational measures to safeguard your personal data from unlawful or unauthorized processing and accidental loss, destruction or damage, thus ensuring its integrity and confidentiality.

To safeguard your personal data from unauthorized access, collection, use, disclosure, processing, copying, modification, disposal, loss, misuse, modification, or similar risks during the course of your use of our Platform and/or Services, we have introduced appropriate administrative, physical and technical measures such as:

(a) Restricting access to personal data to individuals who require access;

(b) Maintaining technology products to prevent unauthorized computer access;

(d) implementing other security measures as required by applicable law.

7.2. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to

protect the security of your information and are constantly reviewing and enhancing our information security measures. You are also advised to exercise caution with respect to the sharing of your personal data and your authentication/security details (such as passwords, credit card details, and transaction details) outside of our Services.

6. Child's Privacy

Minors under the age of 20 are not eligible to use our services. We do not knowingly collect or solicit information from anyone under 20 or knowingly allow such persons to provide us with their personal information.

7. Changes to The Privacy Policy

We reserve the right to modify this Privacy Policy at any time. Any changes will be posted on our website with an updated revision date.

8. Contact Information

You are free to exercise any of your rights stated in the PDPA or if you have queries or complaints related to the use of your personal data. Please contact us at [email protected]

This Privacy Policy is governed by and shall be construed in accordance with Thai law. Any dispute arising under this Policy shall be submitted to the exclusive jurisdiction of the Thai courts.

By continuing to use our platform, we assume your explicit consent and acceptance of this Privacy Policy. Your continued use of the services after changes have been posted constitutes your acceptance of such changes. Let's work together to ensure a secure and reliable environment at Alote.io.

Last updated: 11.Sep.2023