Personal Data Protection Policy

Article 1: General provisions

1. Clients are fully aware that, in using the service rendered by the Company through both normal and online channels, the Company may collect, use, or disclose clients’ personal data directly and indirectly upon clients’ consent. If clients do not wish to give consent for such collection, usage, or disclosure of their personal data, please avoid using the Company’s service.
2. In giving the consent, collection, usage, and disclosure of clients’ personal data, the Company may request clear consent in written or electronic form through the website or application. However, clients shall be notified of the clear objectives of collection, usage, and disclosure of the personal data further in the this article.
3. The Company shall take account of clients’ independence in giving consent to the Company for collection, usage, and disclosure of their personal data without condition and request for unnecessary data for collection, usage, or disclosure of personal data that are irrelevant to the objectives.
4. Clients who have given their personal data to the Company and given consent to the Company for collection, usage, and disclosure of their personal data may withdraw their consent at any time by sending the request for consent withdrawal through the Company’s channels. However, clients may not receive convenient and quick service because the Company does not have their database anymore.
5. The Company does not have the intention to collect personal data of minors. Any minors without consent from their parents or guardians are advised to avoid using the Company’s service and refrain from giving any data to the Company. If minors’ parents or guardians are aware that your minors have given their personal data to the Company, please contact the Company and request for withdrawal of their personal data and consent at any time.
6. The Company shall not collect, use, and disclose personal data for any other purposes, except:
   • a.
     There are new objectives and the Company has notified such objectives to clients who own the personal data as well as obtaining their consent for collection, usage, or disclosure of their personal data.
   • b.
     The Company is requested by the competent persons or organizations to collect, use, or disclose clients’ personal data to the extent permitted by the law.

Article 2: Objectives of collection, usage, and disclosure of personal data

1. For making the transactions required by clients such as registration for service usage, request for information, request for benefits, for which only basic information, including first name, last name, address, and telephone number, is required for contact and issuance of important documents about the benefits.
2. For enhancing the efficiency of the Company’s operation, marketing planning, service assessment analysis, and product and service improvement and development.
3. For commination and notification of updates about the Company’s products and services, benefits, promotions, or changes about the personal data protection policy.
4. For performing in accordance with the contracts in which clients are the parties and/or the parties of which service is used by the Company such as data sharing.
5. For compliance with the law such as preventing and suppressing danger to life, body, or health of persons, education, research, or statistics, for which appropriate preventive measures shall be provided to protect clients’ rights and freedom.

Article 3: Methods of personal data collection

1. The Company shall collect clients’ personal data directly and indirectly, including:
   • a.
     Personal data e.g., first name, last name, sex, age, nationality, marital status, address, occupation, workplace, email, phone number, credit card, monthly personal income
   • b.
     Data of clients’ interests e.g., types of products and services of clients’ interest, hobbies, social media activities, sports, or travel
   • c.
     Data of decision to choose or not to choose products and services e.g., reasons for purchasing products or using services, budgets, objectives, comparative products and services, opinions on products and services, data of product and service views
   • d.
     Data identifying location of clients while using the website or application: In case of activating GPS system, clients’ communication devices shall be considered as the consent given to the Company in collecting and processing the location of clients while using the website or application.
   • e.
     Data of searching the website or application: The Company may use cookies as the tool to collect data such as IP address, types of web browser, access to web page visited, time of visit of the referred website or application or the Company’s website or application.
   • f.
     Necessary data to be given to the Company and the Company may process such personal data as permitted by the law without requesting the consent such as giving data in compliance with the law or contracts or it is necessary to give data to enter into the contracts or any other data determined by the law, or giving necessary data for the lawful benefit of the Company e.g., collection of clients’ images in any activities arranged by the Company.
   • g.
     Other personal data which requires clients’ consent
2. The Company shall collect clients’ personal data as necessary or for the objectives of collection and as required by the law only. However, the Company may collect clients’ personal data by converting it into de-identified data.
3. In case of continuous usage and link to other websites or applications or other advertising which do not belong to the Company, Personal Data Protection Policy of such websites or applications shall apply without the Company’s involvement.
4. Methods of personal data collection through the Company’s channels include electronic form, document form, verbally on occasion, or through the channels of other service providers such as online social media leading to generation of personal data.

Article 4: Usage and disclosure of personal data

1. The Company represents not to use clients’ personal data for other purposes apart from those specified herein and for the Company’s business operation in the following cases:
   • a.
     For the Company’s business operation, for the benefit of education, research, statistics, service improvement, marketing, public relations, notification of products and services, promotions related to the Company’s products and services in several occasions
   • b.
     For improvement, development, enhancement of the Company’s business operation
   • c.
     For acceptance of complaints from service providers
   • d.
     For contacting clients via telephone, chat box, email, or post, or any other channels to ask or notify or examine, or confirm the information about clients or survey of opinions as deemed necessary
   • e.
     For monitoring service usage of clients to ensure effectiveness and compliance with the relevant laws and regulations applicable at the present or to be amended in the future. The Company shall not sell, transfer, or disclose personal data to the third party unless the consent has been obtained.
2. The Company may disclose clients’ personal data if such data has been legally disclosed to the public or in compliance with the order of the court or government agencies for the benefit of investigation of the law enforcement or court hearing.
3. If the Company hires other persons to perform any tasks related to clients’ personal data controlled by the Company, the Company shall determine the persons in charge shall keep confidentiality and security of clients’ personal data. The Company shall also determine that clients’ personal data will not be used for other purposes except for those specified by the Company.

Article 5: Rights of personal data owners

1. Clients who own personal data have the right to request for access and obtain the copy of their personal data given to and controlled by the Company or request for disclosure of the method of collection of their personal data if such data has been obtained without the owners’ consent unless it is the case of protection of personal data owners or the third party’s rights or freedom or a breach or conflict with the provisions of law or court order, or other cases determined by the law.
2. Clients may notify cancellation of their consent for the Company’s usage of their personal data or disclosure of their personal data for which they have given their consent. However, after such cancellation, the Company may not be able to provide the best service to clients or as to the extent notified by the Company. However, the Company may retain the data for monitoring of service provision or in compliance with the law. The Company shall not use their personal data for other purposes any longer.
3. If the Company fails to maintain the personal data as determined by the Company, clients may request the Company to destroy, delete, or suspend the usage of such data temporarily or permanently or change the personal data into de-identified data.
4. Clients may exercise the rights specified by the law e.g., the right to correct the personal data, suspend the personal data, object the personal data processing for certain reason by notifying their intention through “Contact Us” on our website or application. The Company shall consider and notify the result within 30 days from the date of acceptance of such request.
5. If the Company sends the information about marketing and marketing campaigns, including interesting products, services, and businesses, to clients, if clients do not wish to receive such updates any longer, they may notify their intention through “Contact Us” on our website.

Article 6: Miscellaneous

1. Other persons who may receive clients’ personal data The Company may disclose clients’ personal data to the Company’s partners, employees, or agents, or any other persons as deemed appropriate and necessary since clients’ personal data is part of the Company’s service provision. The persons receiving personal data from the Company shall treat rely on this Personal Data Protection Policy in the same manner as the Company.
2. Data security To ensure safety and appropriateness of clients’ personal data management, the Company has created the personal data storage system with appropriate mechanisms and techniques, as well as prioritizing and limiting access to clients’ personal data from directors, executives, employees, workers, and agents of the Company to prevent unauthorized usage, disclosure, destruction, or access to clients’ personal data.
3. Period of data retention The Company shall retain clients’ personal data for appropriate period to provide the service or to perform in accordance with the determined objectives.
4. Contact us In case of any queries about this policy, clients may contact We Care International Group Public Company Limited, Head Office: No. 99/84 Village No. 5, Lam Luk Ka Road, Khu Khot Sub-district, Lam Luk Ka District, Pathum Thani Province 12130 and www.wecareinternationalgroup.com or “WE CARE” Line.
5. Review of Personal Data Protection Policy The Company may improve or revise the policy without a prior notice to clients to enhance effectiveness of the service. The Company advises clients or stakeholders to read the Company’s Personal Data Protection Policy each time they visit the Company’s website.