PRIVACY POLICY

Effective as of June 1st, 2013

We at Hotelcloud, Inc. (“Hotelcloud,” “we,” “us,” or “our”) have created this privacy policy (this “Privacy Policy”) because we know that you care about how information that you provide to us is used and shared. This Privacy Policy relates to our information collection and use practices when you access and use the Website, the App, or the Services (collectively, the “Hotelcloud Offerings”) from any Device.

By visiting the Website and/or accessing or using the Hotelcloud Offerings, you are agreeing to be bound by the terms of this Privacy Policy and the accompanying Terms of Service, which are incorporated herein by reference. You also agree and acknowledge that you will be bound by any additional terms and conditions and/or privacy policy that participating Hotels and/or Vendors may impose, for which Hotelcloud is not responsible. In such case, you will be provided with such additional terms and conditions and/or privacy policy and will be required to accept them in order to access and use the Hotelcloud Offerings.

Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Service.

Important Notice to Non-U.S. Residents

If you are located outside of the United States, please be aware that any Information (as defined below) you provide to us and/or that we collect from you will be transferred to, processed, and used in the United States in accordance with the terms set forth in this Privacy Policy. By using the Hotelcloud Offerings and/or providing us with any Information, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States.

The Information We Collect

1. Personal Information

When you set up your Account or sign in to use the Hotelcloud Offerings with your Account, you will be prompted to provide us with, or you hereby authorize us to access from Hotels, Vendors, and our promotional partners, some personal information about you (collectively, the “Personal Information”). Such Personal Information may include your first and last name, e-mail address, and phone numbers. We do not collect any Personal Information from you when you use the Hotelcloud Offerings unless you provide us with the Personal Information voluntarily or unless we gain access to it through Hotels, Vendors, and our promotional partners. 2. Geolocational Information Certain features and functionalities of the Hotelcloud Offerings are based on your location. In order to provide these features and functionalities after you sign in to the Services, we may, with your consent, automatically collect geolocational information from your Device, your wireless carrier, and/or certain third-party service providers. Such information is collectively called the “Geolocational Information.” Collection of such Geolocational Information occurs only when the Services are running on your Device. 3. Order Information

When you wish to process an order for products and/or services through the Hotelcloud Offerings (each, an “Order”), you must provide us with certain information about the transaction you are seeking to execute, such as your Hotel room number, the particular products and/or services being ordered, the time of a reservation or appointment, and/or the number of guests in a party. Such information is collectively called the “Order Information.”

4. Other Information

In addition to the Personal Information, the Geolocational Information, and the Order Information, we may collect or gain access to additional information (collectively, the “Other Information”). Such Other Information may include:

a. From You. Additional information about yourself that you voluntarily provide to us, such as personal interests, age, gender, product and service preferences, and other information that does not identify you personally.

b. From Your Activity. Information that we automatically collect when you use the Hotelcloud Offerings, including, without limitation: • When you visit the Website, we may collect your IP address, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, sections of the Website visited, etc. • When you use the Services, we may collect the name of the Hotel in which you have authenticated and information regarding the offers from us, Hotels, Vendors, and our promotional partners. • When you use the Hotelcloud Offerings, we may collect information regarding the total data transferred or consumed, time logged in, and similar information. c. About Your Device. Information we may collect about your Device, including universally unique ID (“UUID”), MAC address, operating system and version (e.g., iOS, Android or Windows), carrier and country location, hardware and processor information (storage, chip speed, camera resolution, NFC enabled, and network type (WiFi, 2G, 3G, 4G). d. From Cookies. Information that we collect using “cookie” technology. Cookies are small packets of data that a website stores on your Device’s hard drive so that your Device will “remember” information about your visit. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your Device until you delete them) to help us collect Other Information and to enhance your experience using the Hotelcloud Offerings. If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your Device. Please consult your Internet browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from us, the Hotelcloud Offerings may not function properly.

e. From Other Sources. Information that we may collect or receive from Facebook, other third-party sites, Hotels, Vendors, and our promotional partners in accordance with their terms of use and privacy policies.

The Information Collected by or Through Third-Party Advertising Companies

We may share Other Information about your activity while using the Hotelcloud Offerings with third parties for the purpose of tailoring, analyzing, managing, reporting, and optimizing advertising you see on the Hotelcloud Offerings, and elsewhere. These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect such Other Information for such purposes. Pixel tags enable us, and these third-party advertisers, to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site.

Accessing and Modifying Information and Communication Preferences

Guests who have provided Personal Information to us may access, remove, review, and/or make changes to the same by following the instructions found on the Website and changing the settings in their Account. Similarly, Guests may manage their receipt of marketing and non-transactional communications by changing the settings in their Account. We will use commercially reasonable efforts to process such requested changes in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our databases. However, Guests cannot opt out of receiving transactional e-mails related to their Account, such as emails about their use of the Hotelcloud Offerings and updates to the Terms of Service and this Privacy Policy.

How We Use and Share the Information

We use the Personal Information, the Geolocational Information, the Order Information, and the Other Information (collectively, the “Information”) to provide and improve the Hotelcloud Offerings, process Orders, solicit your feedback, inform you about our products and services and those of Hotels and Vendors, and administer our promotional programs. Also, we may use the Information as described below.

• In order to provide the Services and process Orders, we need to share your Information with the applicable Hotel and/or Vendor, which may use such information to inform you about other products and services that they offer. If you would like them to stop sending you such marketing communications, please let them know.

• In order to administer our rewards, contests, sweepstakes, competitions, and promotional programs, we may share your Personal Information, Geolocational Information, Order Information, and Other Information with our third-party promotional and marketing partners, including, without limitation, businesses participating in our various programs.

• We may from time to time share your Information with Hotels, Vendors, our promotional partners, and other companies who may provide you information about the products and services they offer. However, to the extent required by law, you will be given the opportunity to opt-out of such sharing.

• With your permission, third-party applications or services may access your Personal Information to, for example, enable you to give permission to share your Personal Information with other websites and services, such as Facebook and Twitter.

• In an ongoing effort to better understand our users and our Hotelcloud Offerings, we might analyze the Information in aggregate form in order to operate, maintain, manage, and improve the Hotelcloud Offerings. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, Hotels, and Vendors. We may also disclose aggregated user statistics in order to describe the Hotelcloud Offerings to current and prospective Hotels and Vendors and to other third parties for other lawful purposes.

• We may employ other companies and individuals to perform functions on our behalf. Examples may include providing network services, information technology support, and customer service. These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law.

• We may share some or all of your Information with any of our subsidiaries or other companies under common control with us.

• As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.

• To the extent permitted by law, we may also disclose your Information when required by law, court order, or other government or law enforcement authority or regulatory agency, or whenever we believe that disclosing such information is necessary or advisable, for example, to protect the rights, property, or safety of Hotelcloud or others.

How We Protect Your Information

We take commercially reasonable steps to protect your Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such information, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. California Residents

Under California Civil Code Section 1798.83, California residents who have an established business relationship with Hotelcloud may choose to opt out of our sharing your Personal Information with third parties for direct marketing purposes. If you are a California resident and (1) you wish to opt out; or (2) you wish to request certain information regarding our disclosure of your Personal Information to third parties for the direct marketing purposes, please send an e-mail to privacy@hotelcloud.me or write to us at:

Hotelcloud, Inc. 120 West 97th Street New York, NY 10025

Children

We do not knowingly collect Personal Information from children under the age of 13 through the Hotelcloud Offerings. If you are under 13, please do not use the Hotelcloud Offerings or give us any Personal Information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide us Personal Information without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to us, please contact us, and we will use commercially reasonable efforts to delete that information from our databases, though there can be no assurance that we are able to do so.

External Websites

You may use the Hotelcloud Offerings to access third-party websites, and the Hotelcloud Offerings and the advertisements you receive through the Hotelcloud Offerings may contain links to third-party websites. Hotelcloud has no control over the privacy practices or the content of any of the third-party websites that you may access using Hotelcloud Offerings or the websites of Hotels, Vendors, our advertisers, sponsors, or other websites to which we provide links. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms of use when visiting any other websites.

Changes to This Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time, and will post any changes on the Website as soon as they go into effect. By accessing the Hotelcloud Offerings after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.

How to Contact Us

If you have questions about this Privacy Policy, please e-mail us at privacy@hotelcloud.me.