This Privacy Statement was last updated on January 22, 2018.

KAJA FLASM, S.A. DE C.V. (hereinafter referred as the ‘Company’) may collect personal information to help you place and receive delivery orders and to improve the newmarket.app service. This Privacy Statement explains how KAJA FLASM, S.A. DE C.V. (“newmarket.app,” “we,” “us,” or “our”) handles your personal information when you visit or use www.newmarket.app (the “Site”), the newmarket.app mobile application, and any other website or mobile application that links to this Privacy Statement (collectively, the “Services”).

Please review this Privacy Statement carefully. By using our Services you consent to the use and sharing of your personal information as described in this Privacy Statement. If you do not agree with these practices, please do not use the Services, or otherwise provide us with your personal information.

Your access to and use of our Services are subject to our Terms and Conditions, which define some of the terms used throughout this Privacy Statement.

1. Collection of information

When you use our Services we may collect or receive information about you.

1.1 Information You Provide Directly

You may provide information to us when you use our Services, including when you register with newmarket.app, search within or place orders through our Services, contact us with inquiries, respond to surveys, or otherwise access our Services. This information may include your name, email address, phone number, delivery address, and payment information, including credit card information and billing address used to complete the purchase transaction, and other information that may identify you. When you place an order through our Services we collect information related to that order, including the products or services purchased, and the date and time of the purchase and delivery. You may also choose to provide ratings for your Rider and for the Food Service Provider or merchant you ordered from.

1.2 Information We Collect Automatically

We also may receive and store certain information about you and your device(s) automatically when you access or use our Site and Services. This information may include:

• Information related to the device you use to access our Services;
• The type of web browser and operating system you use to access our Services;
• Your IP address;
• The domain name of your Internet service provider;
• The specific newmarket.app pages you visit, content you view, features you use and the date and time of your visits; and
• Your search terms, the website you visited before you came to our Services, and other clickstream data.

1.3 Customer chat messages

Messages sent through the circle-shaped 'Messenger widget' in the right bottom corner of the website are fully anonym and only stored temporarily on our server. The feature provides the option for quick chat with the 'Company's support staff. You are solely and fully responsible for all activities that occur under your session. No communication conducted under this channel can be considered as official offer or basis of agreement between you, the company or any other third-party. The messages may disappear in a short timeframe and are not recoverable. The Company has no liability to store the customer chat messages.

2. Use of information (submitted by the user)

We may use the information we collect or receive about you:

• Connect your orders to a Rider and complete your deliveries
• Complete your purchase transactions
• Contact you in connection with your orders and deliveries
• Contact you with promotional offerings or other communications that may be of interest to you
• Respond to your questions and assist with problems with our Services
• Personalize the content and features you see when you visit our Services
• Serve advertisements tailored to your interests
• Improve the content and functionality of our Services
• Help the Food Service Providers on our platform improve their offerings
• Better understand our users’ demographics, interests and behaviors
• Enhance other information we have about you to help us better understand you and determine your interests
• Provide recommendations to you
• Manage our everyday business needs, such as auditing, administration of our Services, forum management, fulfillment, analytics, fraud prevention, and enforcement of our corporate reporting obligations and Terms of Service, or to comply with the law
• Calculate the total number of visitors to our Services and to each page or feature of our Services
• Provide help and support for the Customer

We may use your information for any other purpose disclosed to you at the time we collect or receive the information, or otherwise with your consent.

Any communication or material you transmit to us via e-mail or otherwise, including any data, questions, comments, suggestions or the like, but not including your personal information and any requests, comments or concerns regarding your personal information, will be treated as non-confidential and non-proprietary.

3. Use of cookies and other information

We use cookies, web beacons, pixels, and similar technologies (“Cookies”) to collect information and personalize your experience with our Services. Cookies are small web files that a site or its provider transfers to your device’s hard drive through your web browser that enables the site’s or provider’s system to recognize your browser and remember certain information. We use Cookies to improve your convenience, for example, to recognize you when you return to newmarket.app and to remember information you have already provided, such as items already in your order cart. We also use Cookies to collect information about your activities over time and across third party websites or other online services in order to deliver content and advertising tailored to your interests. You may disable the use of Cookies by modifying your browser settings. If you choose to disable cookies you may not be able to fully experience the interactive features of our Services.

4. Location information

When you use the Services, we may collect precise location data about the progress of your order from the newmarket.app app used by the Rider. If you permit the Services to access location services through the permission system used by your mobile operating system (“Platform”) or browser, we may also collect the precise location of your device when the newmarket.app app is running in the foreground or background of your device while we are processing your order. We may also derive your approximate location from your IP address. We use your location information to provide more accurate deliveries of your orders. You can choose whether to enable the location tracking feature through the settings on your device or Platform or when prompted by the newmarket.app mobile app. If you choose to disable the location feature, the Rider will not receive precise location information from your device, which may compromise the accuracy of deliveries in some situations, for instance, if you are located in a large area, such as a park.

5. Sharing with third parties

To help us run our business, we may share your information, including your contact information, ratings, other information you provide directly, and information collected automatically, with entities that provide services to us, including third parties that provide payment processing, advertising services, web analytics, data processing, IT services, customer support and other services. To help provide you with a high quality delivery we also may share your information, including your personal information, with the Rider, who complete your requested deliveries. Similarly, we may share your name, phone number, order information, customer feedback and other information related to your orders with newmarket.app Food Service Providers and riders. We may also disclose aggregate, anonymous information to these third party service providers.

5.1. When Required By Law

We recognise that information related to your orders could contain private information. However, we may be required to disclose your information to third parties including law enforcement agencies when required to protect and defend our legal rights, protect the safety and security of users of our Services, prevent fraud, comply with the law, respond to legal process, or a request for cooperation by a government entity.

5.2. Corporate Transactions

In the event of sale, transfer, merger, reorganization, dissolution, or similar event we may transfer your information to one or more third parties as part of that transaction.

6. Accessing and collecting your personal information

Keeping your personal information current helps ensure that we provide you with the most relevant offers. You can access and update your personal information via your Account profile. While we are ready to assist you in managing your subscriptions, deactivating your account, and removing your active profile and data, we cannot always delete records of past interactions and transactions. For example, we are required to retain records relating to previous purchases through our Services for financial reporting and compliance reasons. In addition, because of the way we maintain certain services, after you delete certain information, we may temporarily retain backup copies of such information before it is permanently deleted.

6.1. Data Retention

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. We will also retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

newmarket.app may retain aggregate or anonymized data indefinitely.

7. Third party sites

Some of the functionality on our Services may be provided by third parties that are not affiliated with newmarket.app. These entities may collect or receive certain information about your use of our Services and your activities over time and across different websites, including through the use of cookies, web beacons, and similar technologies. For example, we use services like Google Analytics to help us see traffic patterns on newmarket.app. newmarket.app is not responsible for the privacy practices of these entities. In addition, our Services may contain links to other websites not operated or controlled by newmarket.app. Such websites are not under our control and we are not responsible for their privacy policies or practices. If you provide any personal information through any such third party website we recommend that you familiarize yourself with the privacy policies and practices of that third party.

8. Social networking

You may choose to enable or log in to our Services via various online services, including social networking services like Facebook. Our Services also may enable you to access social networking services such as Facebook, Twitter, or Instagram (collectively, “Social Network”) directly or indirectly through our Services.

When you link a Social Network account to newmarket.app or log into our Services using your Social Network account, we may collect relevant information necessary to enable our Services to access that Social Network and your data contained within that Social Network. We also may share your information with the operator of that Social Network to facilitate or enhance delivery of that Social Network or other services to you. A Social Network may provide us with access to certain information that you have provided to them, and we will use, store, and disclose such information in accordance with this Privacy Statement. Additionally, a Social Network may collect personal information and information about your use of our Site or Services automatically. The manner in which a Social Network collects, uses, stores, and discloses your information is governed by the policies of such third parties and newmarket.app shall have no liability or responsibility for the privacy practices or other actions of any Social Network that may be enabled within our Services.

You may also have the option of posting your activities on our Services and other content to a Social Network when you access content through our Services. For example, you may post to Facebook that you placed an order with newmarket.app. Keep in mind that your activity on a Social Network is governed by that Social Network and not by newmarket.app, and may be visible or accessible to the public.

9. Your choices

If you are a registered newmarket.app user you may access or modify your personal information by logging into our Site using your username and password and visiting the “Account” page. You may also contact us at now.it24@gmail.com to access, modify, or request deletion of your personal information or delete your account. You may disable our ability to use cookies by using the cookie controls in your web browser (see “Use of Cookies” section above).

If we send you marketing emails about services that may interest you, each email will contain instructions permitting you to “opt-out” of receiving future marketing or other communications.

10. Children’s information

Our Services are not intended for children under 13 years of age and we do not knowingly collect personal information from children under the age of 13. If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed personally identifiable information to us please contact us at now.it24@gmail.com. A parent or guardian of a child under age 13 may review and request deletion of the child’s personal information.

11. Referral programme

newmarket.app allows users to invite friends to sign up for our Services by submitting a friend’s name and email address to newmarket.app. Sometimes we offer a promotional value for every friend that signs up and places an order through your referral link. By choosing to invite a friend you represent that you have received the friend’s consent to provide his or her name and email address to us. newmarket.app will use that information to send an email inviting him or her to visit the site and will store that information to track the success of the referral program.

12. International users

newmarket.app is based in Tulum, Q.R., Mexico and, regardless of where you use our Services, the information collected as part of that use will be transferred to and maintained on servers located in the United States. Any information we obtain about you will be stored in accordance with U.S. privacy laws, regulations, and standards, which may not be equivalent to the laws in your country of residence. By using our Services, you consent to this collection, transfer, storage, and processing of information to and in the United States.

13. Security

newmarket.app has implemented commercially reasonable administrative, technical, and physical security controls that are designed to safeguard personal information. However, no online activity is ever fully secure or error-free. Therefore, newmarket.app does not guarantee that your personal information is absolutely secure. Please keep this in mind when disclosing any personal information or other information to newmarket.app.

You are responsible for safeguarding your username and password.

14. Changes to this privacy policy statement

Our Services may change from time to time. As a result, we reserve the right to update or modify this Privacy Statement at any time and from time to time without prior notice. If we make any material changes to the way we use or disclose your personal information, we will notify you by email, at the email address you have provided to us. If you object to any changes you must cease using our Services. Please review this Privacy Statement periodically by visiting this webpage. This Privacy Statement was last updated on the date indicated at the top of this page. Your continued use of our Services after any changes or revisions to this Privacy Statement indicates your agreement to the terms of the revised Privacy Statement.

15. Contact information

newmarket.app welcomes your questions or comments regarding the Terms:

KAJA FLASM, S.A. DE C.V.

Email Address: now.it24@gmail.com