We are the data controller in respect of any personal data we collect about you. We are responsible for monitoring our data protection compliance.
1) COLLECTION OF YOUR PERSONAL DATA
We collect and process the following information about you; this is for the purposes explained in sections 2 and 3.
Information you give us:
- Name, email address (personal and/or work), postal (delivery) address(es), encrypted password(s), telephone number(s), date of birth, gender, interests, preferences, and competition entry details and answers
Information automatically collected from you
- When you visit or use any of our websites, we automatically collect certain information from you (the majority of which is from a server log), including:
— geo-location data
— operating system and browser type
— domain name requested
— server log details
— browser language
— access times
— application version, platform, and settings
— URL of the website you visited before browsing to our website(s)
— time you spent on each page visited
— URLs of the pages you visited on our websites
— IP address used to connect your computer or mobile device to the internet
— other information about your use of and actions on our websites
- We may record or monitor calls, emails, text messages and other correspondence for training purposes to improve the quality of our offering and to prevent and detect fraud
- We may use DoubleClick (data collection for Google AdWords) which collects information about how visitors use our websites
- Authentication information – see section 9
2) USE OF YOUR PERSONAL DATA
We may use your personal data for any or all the following purposes:
- to provide a high level of customer service (including assisting with any enquiries and product orders) and to notify you of any security and data breach alerts, and technical notices (including service messages and updates to our online platforms and terms)
- to provide you news about us or that of our selected partners – this may be via email, telephone, text message and/or push notification - you can change your marketing preferences (including the way in which we contact you) by logging in to your account and navigating to “Communication Preferences”[LC1] – see section 11
- to facilitate profiling, segmentation, and personalization – these may be based on location, preferences, interests, and past actions (including, but not limited to in-restaurant and online purchases)
3) SHARING OF YOUR PERSONAL DATA
We sometimes need to share the personal information we process with other organizations and, where necessary or required, we may share your personal data with the following categories of third parties:
- service providers and suppliers assisting us with our business activities, business associates, customers, payment services providers, hosting providers, providers of IT support, advertising platforms, providers of booking systems, providers of cloud-based software or services used by us, accounting firms and law firms;
- government watchdogs, regulators, public authorities, and security organizations, such as the Revenue Department or police to the extent required by law, regulation, court order or if necessary, to establish, exercise or defend our legal rights, including if we suspect fraud or attempted fraud;
- financial organizations and advisors, credit reference agencies, debt collection and tracing agencies
We will never sell your personal data.
4) TRANSFER OF YOUR PERSONAL DATA OUTSIDE OF THAILAND
Some third parties to whom we may transfer your personal data may be located outside of Thailand. In the event of a transfer, we will seek to ensure that appropriate safeguards to protect your data are in place which may include entering into a data transfer agreement with such third parties to ensure adequate protection for your information. Examples of the types of contractual clauses we may use can be found at the following link: https://ec.europa.eu/info/law/law-topic/data-protection_en
5) LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
We will process your personal data where it is necessary:
- for or entering into a contract or performance of a contract with you, including to provide our product and service offering, process your payment and to respond to enquiries and orders made by you
— to improve our offering and online platforms
— to operate our online platforms efficiently and effectively
— to carry out behavioral advertising and
— to prevent, detect and investigate fraud or illegal activity
We may also process your personal data based on any consent given by you. This consent may be updated by logging in to your account and navigating to “Communication Preferences”[LC2] – see section 11
6) PROTECTION OF YOUR PERSONAL DATA
We are committed to protecting your personal data and keeping it safe and confidential. We will therefore ensure that appropriate technical and organizational, physical, electronic, and procedural safeguards are implemented to protect it. Access to your personal data will also be limited to our employees and certain third parties who process it on our behalf.
7) STORAGE OF YOUR PERSONAL DATA
Your personal data will generally be stored for up to 5 years. We may, however, keep your personal data for longer than 5 years if we need it to fulfil our contractual obligations to you, the law requires us to maintain it for a longer period or you have not withdrawn your consent.
8) YOUR RIGHTS
You have the following rights, albeit some of them only apply under certain circumstances:
- to have a copy of the personal data we have collected about you and to send a copy of it to another data controller;
- to update or amend the personal data we have collected about you if it is inaccurate or incomplete;
- respect of any data processed for direct marketing purposes;
- to withdraw any consent you have provided us in relation to our processing of your personal data; and
- to lodge a complaint with the relevant authority
To exercise any of these rights, please contact us – see section 11
If you want to amend your personal data or preferences, please log in to your account and navigate to “User Profile” or “Communication Preferences”[LC3] – see section 11
9) CONNECTING TO THIRD PARTY SERVICES INCLUDING SOCIAL NETWORKS
Our offering may contain links to third-party apps, services, tools and websites that are not affiliated with, controlled or managed by us (including Facebook, Instagram, LinkedIn and Twitter®) and these services and links may also include social networking features (such as the Facebook® “Like” button and widgets, “Share” buttons, and other interactive mini-programs). Additionally, you may be able to use your own social networking logins from, for example, Facebook or LinkedIn® to log into some of our services. If you choose to connect using a social networking or similar service, we may receive and store authentication information from that service to enable you to log in and other information that you may choose to share when you connect with these services. These services may collect information, such as the web pages you visited and IP addresses, and may set cookies to enable features to function properly. We are not responsible for the security or privacy of any information collected by these third parties. You should review the privacy statements or policies applicable to the third-party services you connect to, use or access as the privacy practices of these third parties will be governed by their own privacy statements. If you do not want your personal information shared with your social media account provider or other users of the social media service, please do not connect your social media account with your account for the services we provide and do not participate in social sharing.
We collect data about how you interact with our online platforms using cookies and other similar technology.
What is a cookie?
Cookies are small text files containing small amounts of information which are downloaded to your computer or mobile device when you access our online platforms. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie.
Cookies are useful because they allow our online platforms to recognize your device. We use them to make our online platforms and digital applications work, or work more efficiently, as well as to store information about your preferences or past actions. You can find out more information about cookies at https://www.allaboutcookies.org/
What types of cookies do we use and how?
We use the following types of cookies:
- ‘session cookies’: these are allocated to your device only for the duration of your visit to our online platforms – they are deleted automatically once you close your browser;
- ‘permanent cookies’: these survive after your browser is closed and can remain on your device for a period – they can be used by our online platforms and digital applications to recognize your computer or mobile device when you open your browser and browse the internet
These cookies may be served directly by us to your computer or mobile device (so-called ‘first-party cookies’) or by one of our service providers (so-called ‘third-party cookies’). A first-party cookie is only used by us to recognize your computer or mobile device when you revisit, or access content via, our online platforms. Third-party cookies can be used to recognize your computer or mobile device across different websites (and are most often used for analytical and advertising purposes).
- essential cookies: these are essential to provide you with products and services available through our online platforms and digital applications and to use some of their features, such as access to secure areas – without these, providing core functionality, such as transactional pages and secure login accounts, would not be possible.
- analytics cookies: these are used to collect information about how you and others use our online platforms and digital applications – the information gathered does not identify you and is aggregated – this includes the number of visitors to our online platforms, the websites or other applications that referred them to our online platforms and the pages that they visited on our online platforms – we use this information to help operate our online platforms and digital applications more efficiently, to gather broad demographic information and to monitor the level of activity on our online platforms.
- functionality cookies: these allow our online platforms and digital applications to remember choices you make (such as your user name or the region you are in) and provide enhanced, more personal features – they can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize – they may also be used to provide services you have asked for, such as downloading a menu or commenting on a blog – the information these cookies collect may be anonymized and they cannot track your browsing activity on other websites.
- performance cookies: these collect information about how you and others use our online platforms and digital applications, for example, which pages are most visited, if error messages come up and how effective our online promotions are – they are only used to help us improve how our online platforms and digital applications work and to ensure ease and speed of use.
- marketing cookies: these facilitate online advertising – for instance our online platforms may use remarketing with Google – third-party vendors, including Google, use these cookies to tailor adverts based on someone's past visits to our online platforms and serve these across the web – you can set preferences for how Google advertises to you using your Google Ads Settings which can be found here: https://adssettings.google.com/authenticated; and
- social media cookies: these are used when you share information using a social media sharing button or “like” button on our online platforms or you link your account or engage with our content on or through a social networking site such as Facebook, Instagram, Twitter, or Google+ – the social network will then record that you have done this, and the information may be linked to advertising activities such as targeted advertising
What cookies do we use?
The following are our own cookies; they are controlled by us and used to provide information about usage of our online platforms and digital applications. These are all session cookies and automatically expire when you close your browser:
- crumb / BWFiaSd+fh7VMDVkY2Q5MjZiOWZlNzQ4NGRhYTIxYjhlM2UxNzkx
- ss_cid / c76bdd31-2ef5-45de-bf8c-4dd1e9bd94b4
- ss_cpvisit / 1592382220208
- ss_cvr / eab25d57-eec4-407e-828d-da58404a5398|1591956126332|1592298764956|1592382221504|4[LC4]
We use third party services who may also set cookies on their websites on their behalf. We do not control the use of these cookies, so you should check the third-party websites for more information about them. The suppliers we use may from time to time include the following:
Provider Name - Purpose
Other cookies are used to collect information about how you use our online platforms and digital applications. We use the information to compile reports and to help us improve the online platforms and digital applications. The cookies collect information in an anonymous form, including the number of visitors to the online platforms, where visitors have come to online platforms from, and the pages they visited:
How to manage cookies?
You have the right to choose whether to accept cookies or not. However, if you do not accept our cookies, you may not be able to use the full functionality of our online platforms and digital applications.
You can find more information about how to manage and remove cookies at https://www.allaboutcookies.org/manage-cookies/ or by visiting the websites relevant to the browser you are using.
11) CONTACT INFORMATION AND UPDATING YOUR PREFERENCES
If you have any comments or questions, please write to us at our head office at 4/F Srisothorn Place, 47 Sukhumvit Soi 23, Klongtoey Nuea, Wattana, Bangkok 10110, Thailand, call us at (insert phone number here) or via email (email@example.com)[LC7]
If at any time you wish to change how we communicate with you or what we communicate with you about, please let us know. You can change your preferences by logging in to your account and navigating to “Communication Preferences”[LC8]
To unsubscribe from any of our marketing-related activities, please follow the link at the bottom of any of our e-communications. Alternatively, please contact us at firstname.lastname@example.org and we will process your request
12) CHANGES TO THIS POLICY
We may change this policy from time to time without notice. Use of our online platforms constitutes your acceptance of this policy. Please check this policy regularly to ensure that you understand how we collect and use your personal data and cookies when accessing and using our online platforms and digital applications.
[LC1]Indicate here how a user can update their communication preferences
[LC2]Indicate here how a user can update their communication preferences
[LC3]Indicate here how a user can update their personal data or communication preferences
[LC4]These are samples. List (copy & paste) the actual session cookies here
[LC5]Please list third party services providers here
[LC6]List other cookies here
[LC7]Insert proper contact details here
[LC8]Indicate here how a user can update their communication preferences