1) WHAT PERSONAL DATA WE WILL COLLECT

We will collect personal data, including but is not limited to:

1.1 Identification information (e.g., name, gender, nationality, etc.); information.
1.2 Contact information (e.g., home address, telephone number, email address);

2) THE PURPOSES OF PERSONAL DATA PROCESSING

We may collect, use, disclose and/or process your personal data for one or more of the following purposes:

2.1 to fulfill the service contract agreement, enforce our terms of service and provide your use of services and/or access to the Site;
2.2 to administer our services for internal operations
2.3 to conduct research, analysis and development activities, behaviors of yours using products and services to create a database and to provide services (including, but not limited to, data analytics, surveys, technology development and/or profiling), and to offer you with better products or services and/or benefits of the Company
2.4 to inform and offer privileges, information, promotions and offers relating to application
2.5 to carry out our marketing analysis, plans and activity campaigns of the Company
2.6 to comply with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction and/or any other necessity for the legitimate interests of us;
2.7 as the purposes for which the applicable law allows us to collect, use, disclose and/or process your personal data without your consent;
2.8 to facilitate service payments related to product and service usages or purchases;
2.9 to provide after sales services, respond to your questions/concerns, facilitate any enquiries, suggestions, requests or complaints in respect of our services, compensation and resolve the issues;
2.10 to notify you of updates or announcements from the regulator and government agencies;
2.11 to manage and fulfill your orders, send you invoices and purchase orders, notify the payment, prepare the receipts and tax invoices, collect payment for our services, ask for payment, and exercise rights of claim;
2.12 to protect and keep our services and network secure, to protect your personal safety and rights, safety of others and the Company;

3) HOW AND HOW LONG WE KEEP YOUR PERSONAL DATA

The Company has information security measure to maintain and the period of retention of your personal data as follows:

3.1 Collection characteristics: We keep your personal data either in printed document (hard copy) or in electronic document system (soft copy) with appropriately secured measures to prevent the loss, unauthorized access, change, and disclose of your personal data.
3.2 Retention period: We will not keep your personal data for any longer than we seem necessary for the purposes for which we collect and process it, or within the effective period of contract, or within the period of the exercise, or defense of legal claims.
3.3 When your personal data for which we collect, use and process it, is no longer required for the purposes and by applicable laws, we will erase or destroy or aggregate and/or anonymize your personal data to an extent that it no longer identifies you within a reasonable time.

4) YOUR RIGHTS AS A DATA SUBJECT

You, as the data subject, have the following rights in relation to personal data according to PDPA:

4.1 Right to consent and withdraw consent
4.1.1 In case that the processing of personal data requires consent, you have the right to give consent to the Company to process personal data for the purposes informed specifically.
4.1.2 When you give us your consent for personal data processing, you have the right to withdraw the consent for your specific purposes at any time, unless there are restrictions on legal rights or in connection with the contract that benefits to you.
4.1.3 You have the right to withdraw the consent about processing your personal data at any time that your personal data is with the Company.
4.1.4 If exercise the right to withdraw consent prevents the Company from delivering products or providing some services to you, the Company will inform you about the effect of withdrawing the consent.

4.2 Right to access (or “Rights to be informed”)
4.2.1 You have the right to request access to and obtain copy of your personal data to and obtain which is being processed by us.

4.3 Right to data portability
4.3.1 You are entitled to request us to send or transfer your personal data to other data controllers or directly receive your personal data for some reasons. However, the right to data portability applies only to the personal data that you submit to the Company and the collection, use and/or disclose of such personal data is done with your consent or where such personal data is necessary to be collected, used and/or disclosed in order to fulfill its obligations under a contract.

4.4 Right to erasure
4.4.1 You have the right, in certain circumstances, to request the erasure of your personal data which is being processed by the Company.

4.5 Right to restriction of processing
4.5.1 You are entitled to have the right, in certain circumstances, to restrict the processing of your personal data by our Company.

4.6 Right to rectification
4.6.1 You have the right to ask for any inaccurate personal data held or processed by us to be corrected, and any incomplete data to be completed. For those inaccurate personal data or incomplete personal data, we will investigate and correct them.
4.6.2 Where a request to rectify inaccurate personal data is received, we may, in some circumstances, request you to provide proof of your identity or to provide additional documents and/or required information.

You may contact the staff of the Company to file a request to proceed with the above rights, as detailed above, or contact by email. However, you do not have to pay a fee to use your rights. However, a fee may be charged accordingly if your request is found to be unfounded, repetitive or excessive.

The Company has the right to refuse that is a dishonest exercise of the right, unreasonable requests, requests that are not provided by law and/or requests that cannot be fulfilled. In addition, the Company has the right to reject your request in accordance with the rules stipulated by the law.

5) IF YOU REFUSE TO GIVE US YOUR PERSONAL DATA

The Company is legally obligated to collect personal data or in order to make a contract between you and the Company. If you choose not to provide personal data, the Company may not be able to provide services to you.

Besides the case that the Company processes personal data for performing of the contract and complying with the laws, in some cases, the Company may require your consent for the collection, use or disclosure of your personal data in accordance with the purposes of personal data processing specified in section 5 to provide you with the best benefits and/or for the Company to be able to provide services that meet to your needs appropriately.

6) CHANGES TO OUR PRIVACY POLICY

The Company may review and revise this Privacy Policy in order to update, amend, or alter the policy as deemed appropriate without prior notice for the policy to be compatible with our business operations, the changing laws, regulations, other relevant practices. In this regard, the Company will inform you of the current policy on the Company websites