1. Our Commitment to Privacy
Our primary purpose to collect Personal Data is to create and maintain the relationship with you as our customers, prospects, or candidates. The confidentiality of your Personal Data is top priority for us.
2. What Personal Data we collect and how we collect your Personal Data
We may collect your information which may include your Personal Data directly or indirectly from you or other sources which depends on your interactions with us.
Our Website is not intended for minors below the age of 10, and we do not knowingly collect personal data relating to a minor.
(a) Information we collect about you
When you visit our Website, we will record each of your visit and will automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, geo-location, time zone setting, browser plug-in types and versions, device types, operating system, time and date of consent and platform;
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed, searched for, filtered or purchased/redeemed, the hyperlinks you have clicked, the websites you visited before arriving at our Website, page viewed, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse the Website.
This information is stored exclusively by us to administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and for the control of illegal acts. We reserve the right to check these log files and data retroactively if there is reasonable suspicion of an illegal act due to concrete indications. As far as Personal Data is processed, we do so solely to protect our legitimate interest to control illegal acts particularly in connection with our Website.
(b) Information you provide to us
This is information about you that you provide to us by placing an order with us at our store(s) and/or through our Website, signing up to our newsletters or promotional materials, registration for marketing and promotional activities or membership offered by us or any TTI Group Entity (as defined below), registering for product warranty, registering as a registered user of our Website, redemption of souvenirs, registering for servicing of your products, corresponding with us by e-mail, telephone, social media or other communication means, creating an account with us, submitting your resume through our job recruitment section or otherwise. It includes information you provide when you enter a competition, promotion or survey, search for a product, report a problem with our Website or tools via customer service or other social media functions on our Website or other communication means. The information you give us may include but is not limited to your name, your trade, your employer/company information, job title, telephone number, fax number, address, email address, personal description, photographs, age group, gender, date of birth, financial and credit card information, social media accounts information, the products you owned and their serial number, purchase history and payment receipt, service booking details, comments on products you provided, shopping preferences, interest and hobbies or personal information as set out in your resume. We will only request information, which is required for the specific purpose. Please note that it is mandatory for you to provide Personal Data marked with asterisks. Refusal to provide such Personal Data may render us unable to handle any application or request you are making or may otherwise defeat the objectives of your visit.
“TTI Group Entity” means the Company or any other person or entity directly, or indirectly through one or more intermediaries, controlling, controlled by, or under common control of the Company, in Thailand or abroad.
By using our Website and providing Personal Data to us, you give your consent that we collect and process the Personal Data to provide you with the information, products and services that you requested from us. You have the right to withdraw this consent at any time. We may also use this Personal Data to carry out our obligations arising from any contracts entered between you and us. We store your personal data only as long as we need it to provide the information, services or offers you requested or to carry out our obligations arising from any contracts.
(c) Information we receive from other sources
This is information we receive about you if you use any of the other websites we and/or our affiliate(s) operate and/or the other services we and/or our affiliate(s) provide. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies), and you may be directed to our Website through those third parties. We may therefore collect information about you, or you may provide information to us. Regarding our collection of your information, please refer to Section 2(a) “Information we collect about you”; regarding your provision of information to us, please refer to Section 2(b) “Information you provide to us”.
Most of the cookies we use are so-called “session cookies”. Other cookies remain on your device until you delete them. These cookies allow us to recognize your browser at the next visit.
As far as Personal Data is processed in this regard, we carry out such processing on basis of our legitimate interest to improve our Website for users. We only process pseudonymised data in this regard upon your visit of our Website. You can delete cookies on your device at any time and once they are deleted, we cannot process any information contained in a cookie.
You can further adjust your browser so that you are informed about the setting of cookies and only allow cookies on an individual basis, exclude accepting cookies for specific cases or in general, and activate the automatic deletion of cookies when you close your browser. The functionality of this Website may be restricted when cookies are deactivated.
(a) Google Analytics
As far as Personal Data is processed in this regard, we carry out such processing as part of our legitimate interest for own marketing purposes. We safeguard your interests by anonymizing your IP address upon collection so that you are not identifiable.
(b) Meta Pixel
We use the Meta Pixel from Meta Platforms, Inc. (hereinafter referred to as “Meta”) on this Website.
You can object to the collection of your data by Meta Pixel, or to the use of your data for the purpose of displaying Facebook advertisements by contacting Meta.
Meta is certified under the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
(c) Google Tag Manager
With Google Tag Manager, website tags can be administered via an interface. Google Tag Manager solely implements tags. It does not place any cookies and no Personal Data is collected. Google Tag Manager triggers other tags that potentially collect data, but Google Tag Manager does not access this data. If certain websites are deactivated at domain or browser level, all tracking tags remain in place to the extent that they are implemented by Google Tag Manager.
(d) Google Ads
Google Ads inserts a cookie or a pixel on your computer or on your mobile device if you are directed to our Website via Google advertisement. These cookies will no longer be applicable after 30 days, and are not intended for personal identification. If you visit certain pages of our Website and the cookie is still active, both we and Google will be able to see that you clicked on the advertisement and were forwarded to our Website. We, as well as all other clients of Google Ads, receive different cookies. The cookies affected by our Google advertisements can therefore not be followed beyond our Internet service.
The information obtained from the conversion tracking serves to compile statistics on the conversion for us. We learn about the total number of users who clicked on an advertisement and were forwarded to a site provided with a conversion tracking tag. However, we do not receive any information that would allow your potential identification.
(e) Crazy Egg
All Personal Data you provide to us is secured on our Website or stored on our secure servers with restricted access by authorized personnel only. We utilize encryption/security software for data transmission so as to protect your data via encrypting it in a secure format to ensure its privacy and security from unauthorized access or disclosure, accidental loss, alteration or destruction.
In addition, we will adopt contractual or other means to prevent any Personal Data transferred to our data processor (i) from being kept longer than is necessary for processing of the data; and (ii) from unauthorized or accidental access, processing, erasure, loss or use, if we are to engage any data processor.
However, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website; any transmission is at your own risk. Once we have received your Personal Data, we will use strict procedures and security features to try to prevent unauthorised access.
6. Purpose of Collection and Use of Personal Data Collected
By using our Website and/or providing Personal Data to us, you agree that your Personal Data collected may be used and retained by us (in electronic form and/or hard copy form or in any appropriate manner) for the following purposes and for other purposes as shall be agreed between you and us or required by law from time to time in connection with our relationship with you, type of information and purpose of collection:
– providing information about the Company and our products and/or services to you;
– processing your order for purchase, including verifying your payment details or status;
– processing your registration for any newsletters, marketing and promotional activities or membership;
– processing your registration for product warranty;
– processing your registration as a registered user of our Website;
– processing your redemption of souvenirs;
– processing your registration for servicing of your products;
– providing you with our products and/or services;
– providing you with regular communications from us with details of our products, services and relevant benefits;
– carrying out promotional campaign which you have entered;
– carrying out data sorting and analysis to enable us to better understand your preference and buying behavior and to provide products and services better tailored to your needs, and to assist us in selecting products and services that are likely to be of interest to you;
– processing any enquiries arising out of or in connection with the Company, products and/or services;
– investigation of complaints and suspicious transactions;
– prevention or detection of crimes;
– disclosure as required by law;
– processing your job application;
– other related purposes for which you have otherwise made it available to us;
– if you have provided your consent for the use of your Personal Data for marketing purposes, we will contact you by electronic means (e-mail, SMS, other media whether now known or available in the future), phone call and/or by direct mail with information about goods and services like those which were the subject of such consent; and
– if you have provided your consent, to permit selected third parties to use your Personal Data, to contact you by electronic means, phone call and/or by direct mail.
We will not use your Personal Data to provide marketing materials to you unless we have your prior consent.
The Company may not so collect, process, retain or in any manner use your Personal Data unless we have received your consent to the above intended use. If you no longer wish us to use your Personal Data for the above intended purposes, you may at any time inform us by contacting our Data Protection Officer using the contact information set forth in Section 11 below.
7. Direct Marketing
If you have provided your consent for the use of your Personal Data for direct marketing purposes, we may from time to time use your Personal Data in order to send you marketing materials about, including without limitation, our products, services, campaigns, events, promotions and loyalty programme updates, by electronic means (email, SMS and/or other media whether now known or available in the future), phone call, and/or by direct mail. The dispatch of such direct marketing communications may be undertaken by third-party service providers.
In addition, subject to your consent, we may transfer your Personal Data to other TTI Group Entities such that they can share with you their marketing materials by electronic means (email, SMS and/or other media whether now known or available in the future), phone call, and/or by direct mail. In any case, we will not share your Personal Data with third parties for gain.
You may opt out of receiving direct marketing communications at any time by contacting our Data Protection Officer using the contact information set forth in Section 11 below. We will then stop, and request other TTI Group Entities to stop, sending any further marketing materials to you. Please note that you may continue to receive direct marketing communications for a short period after changing your preferences while we and/or other TTI Group Entities are updating our systems.
8. Retention/Accuracy of the Personal Data
We retain records of your dealings with us for the purposes set forth in Section 6 above. Our general policy is to retain your Personal Data no longer than is necessary for the fulfillment of the purposes mentioned above and to comply with our obligations under rules, regulations and laws unless a longer retention period is permitted by applicable law.
We will take reasonable steps to ensure the accuracy of your personal data Personal Data held by us. If we note that the Personal Data is inaccurate, we will not use such Personal Data and will notify any third party to which your Personal Data has been transferred regarding the same.
9. Disclosure and Transfer of Personal Data
By using our Website and/or providing Personal Data to us, you agree that we may disclose or transfer (whether in Thailand or abroad) to third parties if legally required or if we instruct third parties to process your Personal Data under our authority, but this will be done strictly in accordance with the applicable laws and regulations. These third parties may include, if applicable, (a) any agent, contractor or other third party service provider who provides data processing, telecommunications, collection, credit reference, security, credit, banking, financial, or other professional services, to us; (b) any TTI Group Entity; (c) any of our actual or proposed assignees or transferees of our rights (whether in Thailand or abroad); and/or (d) any person or entity to whom we are under an obligation to make disclosure under the requirements of any laws, rules, regulations, codes of practice or guidelines issued by any regulatory or other authorities, for any or all of the purposes mentioned above.
The data protection laws of the jurisdictions where the third parties receiving your Personal Data are situated may not be substantially similar to those of Thailand. This means your Personal Data may not be protected to the same or similar level in Thailand.
The Company may not so transfer your Personal Data unless we have received your consent to the above intended transfer.
10. Third-Party Websites
Our Website may, from time to time, contain links to and from the websites of our partners, advertisers and affiliates. We do not assume any responsibility or liability for any of those websites. If you follow a link to any of those websites, please note that those websites may have their own privacy policies, and that we do not accept any responsibility or liability for those policies. We recommend you carefully reading those policies before you submit any Personal Data on those websites.
11. Access to and Correction of Personal Data
As a data subject, you have the right to assert the rights of the data subject at any time. In particular, subject to applicable law, you have the right to:
- obtain information about whether or not and, if applicable, to which extent we process Personal Data concerning you;
- access information, in particular, the following information: stored Personal Data concerning you, purpose(s) of the processing, categories of Personal Data, recipients to whom we disclose Personal Data or duration of the storage in the case of processing of Personal Data concerning you ;
- require us to correct any Personal Data without undue delay which is inaccurate or incomplete;
- ascertain our policies and practices (from time to time) in relation to Personal Data and the types of Personal Data held by us;
- require us to delete or cease the collection, processing, using or disclosing of your Personal Data without undue delay;
- withdraw your consent given to us concerning the processing of your Personal Data at any time;
- let the processing of your Personal Data be restricted;
- receive the Personal Data concerning you which you had provided to us in a structured, standard and machine-readable format, and to transmit these Personal Data to another controller
If permitted by law, we may charge a reasonable fee for the processing of any Personal Data access request. If you would like to exercise the above right, please contact our Data Protection Officer using the following contact information:
Data Protection Officer
Toll-free Phone Number : 1-800-012-243
E-mail address : [email protected]
Address: 65/116-117, 14th Floor, Chamnan Phenjati Building, Rama 9 Road, Huaykwang, Bangkok 10310, Thailand
You have the right to file a complaint with competent officials in the event that we or a data processor, including our or their employees or service providers, violate or do not comply with the Personal Data Protection Act B.E. 2562, including notifications issued thereunder.
Effective date: 2023-02-01