Personal Data Protection Policy  

The Company, with a prior consent from the Data Subject, will collect, process and use the personal data for the following purposes:

Purposes of Collection and Usage of Personal Data

       •  Communications, notification of news and information about products and services of the Company and for presentation of projects to        potential customers;
       •  Preparation of marketing plans, analysis and processing of data usage, improvement and development of products and for provision of services by the Company; and
       .  Disclosure to an authorized third party or a business alliance of the Company in terms of products and/or services of the Company 
 
Personal Data Security and Protection Policy

                 •  Residential projects: condominiums, single homes, townhomes, commercial buildings and other projects of Sarithorn Co., Ltd. and its affiliates;
                 •  Line ITD property/Facebook ITD property;
                 •  News and information about the sales promotions for products and services given through SMS;
                 •  Any other business activities related to products and services.

This Policy will be applied for the security and protection of all personal data given to Sarithorn Co., Ltd. and its affiliates and/or joint ventures (“Company”) by all Data Subjects through both offline and online processing channels, when Data Subjects visit the Company’s projects, fill in questionnaires, answer questions via phone calls from the Marketing Department and/or when the Company receives the personal data from its business partners related to the following business activities. The personal data will include, but not limited to, all data related to following issues and activities:

Prior to filling in this Questionnaire, please provide your reasonable cooperation by reading all terms, conditions and policy on security and protection of the personal data. If you do not agree to accept them, please immediately stop filling in it. If you agree to fill in the Questionnaire, both through the offline and online processing channels, it will be deemed that you have agreed to accept all terms, conditions and policy on security and protection of the personal data. The Company has the policy to provide security and protection of the personal data, as follows:

1. Definition
“Personal Data” means any information relating to a person that enables the identification of such person, whether directly or indirectly.  Through the following information, you will receive the explanation about various cookies the Company has used and your option for management and setting of the said cookies for data collection by the Company. 

2. Collection of Personal Data
2.1  The Company will collect the following personal data from you, whether directly or indirectly:
       •  Your basic personal data, such as, name, family name, sex, age, nationality, birthday, marital status, address, occupation, working place, postal code, postal address, email address, telephone number, credit card no., and monthly income; 
        • Your favorites, such as, products, services, hobbies, activities, social networks, sports or traveling;
        • Your reasons for making decision to choose or for not choosing of certain products and services, such as, your reasons for buying or choosing residential projects, budget, purposes, other comparative products, opinions about products and services, experiences in visiting of products (properties) and receiving of services;
         • Your search for information on websites:
         • The web browser you uses for accessing websites;
         • The websites you visit
         •  The important information you are required to provide to the Company and the Company can process such information as permitted by law without your prior consent:
         • The information you are obliged to provide as required by law or agreement/contract, or the information you are required to provide for making an agreement/contracts, or any other information you are obliged to provide as required by law, failing which the Company cannot take any or all actions for you as you wished, or the information you are required to provide after the Company has earlier informed or the information you are required to provide for a legal effect; 
          • The information essential for legal benefits, such as, your photos taken while attending the Company’s various activities and your photos on CCTV cameras inside the Company’s projects and sales offices collected for the security purpose only.
           • Other personal information the Company may collect with your prior consent.

2.2 The Company will collect your personal data only when seen necessary or only for taking actions under the purposes of collection and as permitted by law. The Company may collect your personal data and anonymization of them when they are on websites or offline advertisements or other advertisement not produced by the Company. The personal data protection policy for those personal data will be as published on such websites or as prescribed on such offline media. The Company will not get involved with it.

2.3 Methods for Personal Data Collection: Following are some methods for collection of the personal data by the Company:
            • From electronics media, documents, conversation in different circumstances, or
            • From its business partners/other service providers, such as, Facebook, Line Application, banks for creation of your profiles or agents, etc.
     

 2.4 Minors

               • The Company does not have a true intention to collect any personal data from any children aged lower than the limit as restricted by law (“age limit”). If your age is lower than the age limit, please do not use the Company’s services, nor provide any of your personal data to the Company.
               •  If you are a father or mother of a child aged lower than the age limit, and know that your child has given his/her personal data to the Company, please contact the Company and request for exercise of your right.
               •  If you are aged lower than the age limit and have some necessities to receive some of the Company’s services and use its products, you are required to receive a consent from your parents prior to giving your personal data to the Company.

3.  Purposes of Collection, Usage and Disclosure of Personal Data3.1   For the purpose of doing some activities as wished: For example, when you register to receive the required information and sales promotion from the Company, the Company will collect and use only your basic personal data, such as, name, family name, email address and telephone number for feedback. 

3.2 For development and improvement of working efficiency, preparation of marketing plans, analysis of data usage, evaluation of services, and for improvement and development of products and services of the Company.

3.3 For communications and contacts, notification of news and information about the Company’s products and services, receiving benefits from sales promotion activities for such products and services of the Company or for future changes of the policy on security and protection of personal data of the Company.

3.4 For taking actions under an agreement/contract to which you are a party or under which its contractual party is a provider of services to the Company when, for example, it is necessary for the Company to share your location while the Company is using its service for  identification of locations of other persons.

3.5 For taking certain legal actions, such as, for prevention or elimination of risks in life, body or health of an individual, for study, research or collection of statistics for preparation of suitable protection measures in order to protect your rights and freedom.

3.6 For any other purposes as informed while the Company is collecting your personal data or for either of the purposes mentioned above.

3.7 The Company will neither use nor disclose your personal data, unless it is necessary for such purposes as specified above, or the disclosure is made for use by an authorized person of the Company or a person involved under an agreement/contract or it is necessary for disclosure as required by law, government authority, regulatory organization or after receiving a consent from you.

4.   Persons Entitled to Receive Your Personal Data

4.1 Business partners of the Company and authorized officials of the Company
4.2 Authorized agents of the Company for selling of the Company’s products and provision of services and representatives of those agents
4.3 Other persons, including, their agents and contractors employed to take certain actions in relation to the Company’s products and services, to organize marketing activities, to present news and information about the Company, to develop the quality of products and services of the Company pertaining to receiving of payments, preparation of documents, development of technological system, sending documents, research, etc.
4.4 Condominium juristic persons or housing estate juristic persons and/or administrators of those condominiums or housing estates.
4.5 Government authorities or regulators or any persons to whom the Company is required to disclose the personal data as required by law, regulation and order involved with the Company or as agreed by the Company with any other government authorities or persons.

5.   Security of Personal Data

5.1 The Company will encrypt all personal data for accessing to prevent the data sniffing by an unauthorized person. The Company’s Marketing Department will be responsible for the data encryption. 
5.2 The Company will improve and test run its technological system regularly to ensure your personal data are highly secured and always reliable. In this regard, the Company reserves its right to change its tools and equipment for the best security of your personal data if the Company considers such tools and equipment are of high standards and can protect the security of your personal data better.

6.   Rights of Data Subjects
6.1 You, as a data subject, are entitled to get access to and obtain a copy of the personal data related to you that you have given and are under control by the Company. You are also entitled to request for disclosure of the acquisition of personal data obtained without your prior consent, unless it is for the protection of data subject or freedom of other persons, it is contradictory to or inconsistent with the provisions of law or court order or other cases as required by law.
6.2 You are entitled to withdraw your consent for usage of your personal data by the Company or the disclosure of your personal data by the Company after you have given a prior consent to the Company. Following such withdrawal, the Company may not be able to provide its services to you as much as it can or as earlier represented to you. The Company may collect the data to check the provision of services to you or for taking a legal action. In this regard, the Company will not use your personal data for other purposes at all.
6.3 If the Company fails to protect your personal data as required by law, you are entitled to request the Company to destroy, erase or temporarily stop using of them or to anonymize them. 
6.4 You will have all other rights as provided by law, such as, the right to rectification of your personal data, the right to stop using of your personal data and the right to object the processing of your personal data for some reasons. 
6.5 You are entitled to take actions under your rights as mentioned above through the Call Center at 02-716-0707 from Monday-Friday during 9.00-17.00 hours. You are not allowed to exercise your rights on Saturdays, Sundays and public holidays. The Company will consider and inform you about the consideration result of your request within 30 days after receiving your request.

7.   Business Activities Related to Marketing and Marketing Promotion
In the case where the Company sends its news and information about the marketing and marketing promotion, including, its interesting products, services and business activities to you after receiving your prior consent to receive them, and if you want to withdraw your such consent, you can withdraw your consent through the Call Center  at 02-716-0707 from Monday-Friday during 9.00-17.00 hours. No Call Center service is provided on Saturdays, Sundays and public holidays. 

8.  Exceptions for Protection of Personal Data
The Personal Data Protection Policy will not be deemed as breached under the following cases:
8.1 Such personal data are already on public domains when you are disclosing your personal data to the Company or they are disclosed to the public without any faults of the Company.
8.2 Such personal data are disclosed with a prior consent from you, regardless of whether in writing or through any other means whatsoever.
8.3 Such personal data are disclosed as seen necessary as required by law, order, rule, regulation, court order, government authority or under any other necessities. 

9.  Duration for Collection and Keeping of Personal Data
The Company will collect and keep your personal data for a period as seen necessary for provision of its services to you or for taking actions under the above-mentioned purposes.

10.  Improvement of the Personal Data Protection Policy/Contact with the Company

10.1 The Company may improve and rectify any or all details of the Personal Data Protection Policy. In this regard, the Company will publicize all details about such improvement and rectification on its official website.

10.2  All users can express their opinions about the Personal Data Protection Policy through the Call Center at 02-716-0707 from Monday-Friday during 9.00-17.00 hours. No Call Center service is provided on Saturdays, Sundays and public holidays. All users agree that the Company’s discretion is final.