Privacy Policy
We appreciate your interest in our Privacy Policy. This Privacy Policy applies to www.term.in.th (our “website”). We would like to ask you to read this policy along with our Cookie Policy.
General Information
1) What law applies?
In principle, we will only use your personal data in accordance with the applicable data protection laws, in particular Thailand's Personal Data Protection Act (“PDPA”).
1) Who is responsible for data processing?
The responsible party within the meaning of the PDPA is TERM.IN.TH Co., Ltd, [email protected] (“we”, “us”, or “our”). If you have any questions or if you wish to exercise your rights, please contact us using [email protected]
1) What is Personal Data?
Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address. In contrast, information of a general nature that cannot be used to determine your identity is not Personal Data. This includes, for example, the number of users of a website.
1) What is processing?
"Processing" means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.
1) What are the legal bases of processing?
In accordance with the PDPA, we have to have at least one of the following legal bases to process your Personal Data:
- you have given your consent,
- the data is necessary for the fulfilment of a contract / pre-contractual measures,
- the data is necessary for the fulfilment of a legal obligation, or
- the data is necessary to protect our legitimate interests, provided that your interests are not overridden.
Data we collect automatically
1) Log data
Each time you visit our website, our system automatically records the following data from the visiting device and stores it in a so-called log file: i) Name of the retrieved file, ii) date and time of the visit, iii) amount of data transferred, iv) message about successful retrieval, type of browser and version used, v) IP address (identification of the user's device), vi) Operating system of the visiting device, vii) Internet service provider of the visiting device, viii) website from which you access our website, and ix) which of our website pages you are accessing. The legal basis for processing is our legitimate interest.
1) Cookies
We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies: i) Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and ii) Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyze your behavior on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies).
As set out in the Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of Non-essential Cookies. For further information on the Cookies we use, please refer to our Cookie Policy. The legal basis for processing is our legitimate interest and your consent.
1) Hosting
To provide our website, we use the services of Hostinger International Ltd, who process all data to be processed in connection with the operation of our website on our behalf. The legal basis for the data processing is our legitimate interest in providing our website.
Data we collect directly
1) Contacting us
In addition to your name, e-mail address, IP address or telephone number, if provided, we usually collect the context of your message which may also include certain Personal Data. The Personal Data collected when contacting us is to handle your request and the legal basis is both your consent and contract.
If you contact or connect with us via the social media platforms on which we are present we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a contractual service, if any.
1) Account Registration
If you register on our website, we will request mandatory and, where applicable, non-mandatory data in accordance with our registration form including your username, e-mail address, telephone number. The entry of your data is encrypted so that third parties cannot read your data when it is entered. The basis for this storage is our legitimate interest in communicating with registered users and, in the case of contracts, also the storage of contract data.
Alternatively, you are able to sign up using the convenience log in and sign up from Discord and Line. Using convenience log in and sign up, you will be asked to provide your basic information (i.e., name, email address) linked to your account. If granted, your username and password will be auto generated to fill in the rest of required user data. When registering via convenience functions, you agree to the relevant terms and conditions and consent to certain data from your respective profile of being transferred to us.
1) Order processing
We process your mandatory and, where applicable, non-mandatory data first name, last name, e-mail address, and Verification Data (e.g., proof of identity, proof of address) related to your contract with us data to handle the contractual relationship between you and us. The legal basis for the data processing is our contract and the fulfillment of our legal obligations.
1) Payment Data
The provision of payment details is subject to our payment processors and does currently not take place through our website. For further information, please refer to our payment processors Privacy Policy. The legal basis for the data processing is the fulfilment of our contractual obligations and the fulfilment of our legal obligations.
1) Administration, financial accounting, office organization, contact management
We process data in the context of administrative tasks as well as organization of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.
1) Marketing
We are entitled to contact you for these purposes via the communication channels you have given your consent to. Our direct marketing typically takes the form of e-mail but may also include other less traditional or emerging channels including social media. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will also include a means by which you may unsubscribe or opt out.
Principles of processing Personal Data
1) Storage and Retention
At the time of data collection, for example in the context of a contractual relationship we process and store Personal Data from you. We process and store your Personal Data only to achieve the respective processing purpose or for as long as a legal retention period exists. Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.
1) Security
Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us. We have also implemented numerous security measures (“technical and organizational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website.
Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.
1) Special Category Data
Unless specifically required when using our services and explicit consent is obtained for that service, we do not process special category data.
1) Minors
We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.
1) Automated decision-making
Automated decision-making is the process of making a decision by automated means without any human involvement. Automated decision-making including profiling does not take place.
1) Do Not Sell
We do not sell your Personal Data.
1) Sharing and Disclosure
We will not disclose or otherwise distribute your Personal Data to third parties unless this is i) necessary for the performance of our services and, ii) you have consented to the disclosure, iii) or if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or other legal proceedings; or proceedings at home or abroad or to fulfil our legitimate interests.
1) International Transfer
We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organizational measures to protect the Personal Data we transfer.
Your Rights and Privileges
1) Privacy rights
Under the PDPA, you can exercise the following rights:
- Right to information
- Right to rectification
- Right to object to processing
- Right to deletion
- Right to data portability
- Right of objection
- Right to withdraw consent
- Right to complain to a supervisory authority
- Right not to be subject to a decision based solely on automated processing.
If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.
1) Updating your information
If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.
1) Withdrawing your consent
You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.
1) Access Request
In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.
1) Complaint to a supervisory authority
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in Thailand is: The Personal Data Protection Committee, 120 Moo 3 Chaloem Phrakiat Government Center, Building B, Chaengwattana Road, Laksi, Bangkok, Thailand, Bangkok.
Changes and Questions
We may update this Privacy Policy from time to time. If we make changes to this Privacy Policy or materially change our use of your Personal Data, we will revise this Privacy Policy accordingly and also change the effective date at the end of this section. We encourage you to periodically review this Privacy Policy to be informed of how we use and protect your Personal Data. If you would like to contact us regarding our privacy practices for any reason, please contact us.
Effective Date
Monday, 17 April 2023