Asian Identity

1. Introduction

This Privacy Policy describes how we collect, use, disclose, share, store, and transfer (collectively, “process”) information about you when you use Services or products (collectively, “Services”) or our Website (“Websites”). We act as a Data Controller for any information collected through Services.

1.1 Who are we?
We are Asian Identity Co., Ltd., a corporation having its registered office at M Thai tower 5Fl., Unit 2A, All season place, 87 Wireless Rd., Phathumwan, Bangkok 10330.

1.2. What is Personal Data?
In this Policy, “Personal Data” means information relating to a natural person, which is identified or identifiable, whether directly or indirectly, but excluding information of deceased natural persons. Please note that at all times we will adhere to the applicable statutory definition in determining what information is and is not Personal Data for the purposes of this Privacy Policy.

1.3. Scope of this Privacy Policy
This Privacy Policy applies to information, including Personal Data, which we collect in relation to your use of Services or Websites only. Regarding any information which you provide to or is collected by any third party other than us, please refer to the privacy policy separately established by such third party.

1.4. Changes to this Privacy Policy
We will amend this Privacy Policy from time to time. We will notify you of the amendment of this Privacy Policy through Services, or other measures determined by us if we make any substantive or material amendments. Any amendment will become effective upon our posting of the amended privacy policy on Services.

2. What information do we collect about you?

We collect the following information about you:

1) Information which you choose to provide to us through Services

• Profile Information: such as name, mailing address, phone number, email address, affiliation, identification information (such as ID number, driver’s license number), date of birth, gender, and photo
• Payment Information: such as credit card information, banking information, or information relating to other kinds of payment measure
• Information of Communication with us: such as information about the communications between you and us including your inquiry, compliments, and other contact to us

2) Information collected as you visit Websites
Usage Information: such as access dates and times, pages viewed, type of browser. In some cases, we collect this information through cookies, tags, and similar technologies that create and maintain unique identifiers using Google Analytics.

• How Google uses data when you use Websites
  https://www.google.com/policies/privacy/partners/
• Google Analytics Opt-out Browser Add-on
  https://tools.google.com/dlpage/gaoptout?hl=en
• For Google Analytics Advertising Features, please refer to the following link.
  https://support.google.com/analytics/answer/2700409?hl=en&topic=2611283

• Device Information: such as information about the devices you use to access Services, including the hardware models, device IP address, operating systems and versions, preferred languages, unique device identifiers
• Information of Communication with us: such as information about the communications between you and us including your inquiry, compliments, and other contact to us

3) Sensitive Personal Information
You may choose to provide us through Services or Websites with your information of a sensitive nature such as racial, ethnic origin, political opinions, cult, religious or philosophical beliefs, sexual behavior, criminal records, health data, disability, trade union information, genetic data, biometric data, or any other information of a sensitive nature. We do not collect and use the information without explicit consent from you, except where permitted by applicable laws.

3. Why do we process your Personal Data?

3.1. We process your Personal Data for the following purposes, to the extent applicable.

• To provide Services
  We process your Personal Data for providing you with Services. For example, we collect your name, email address, and other information to make customer registration for Services. If you use a chargeable service, we collect and use your payment information, such as banking account, credit card information, to charge you fees and other payment relating to Services.
• To provide personalized services
  We process your Personal Data for providing you with personalized services. For example, we provide recommendations or personalized contents of Services based on your activity on Services.
• To develop new products or services
  We process your Personal Data for developing new products or services. For example, we collect and utilize information of how you use Services, inquiry from you, or questionnaire results for developing new products or services.
• To measure and analyze performance
  We process your Personal Data for analyzing and measuring how Services are used. For example, we measure and analyze your visits to and activity on Websites for optimizing them using Google Analytics.
• To communicate with you
  We process your Personal Data to communicate with you. For example, we respond to inquiries from you or may send you a notification about Services by using contact information provided by you such as email address. In addition, if you contact us, we will keep a record of your request in order to help solve any issues you might be facing.
• To protect us, our customers, and the public
  We may process your Personal Data to protect us, you or other customers, or the public interest. For example, we use your identification information for detecting and preventing fraud, abuse, or security risks. We may also use your Personal Data to investigate or address claims or disputes relating to Services.
• Other Purposes
  We may process User Information for the purposes prescribed in 5. below.

3.2. If you do not provide us with your Personal Data which is necessary for complying with laws or performing the contract between you and us or entering into such contract (e.g., the information required to be entered by you on the application screen for a transaction through Services), your application for use of Services may not be accepted, or you may not be allowed to use part of Services.

4. Disclosure, Share, or Transfer of Personal Data

4.1. We may share your Personal Data with the following categories of recipients:

• Affiliate Companies
• third-party service providers performing functions or services on our behalf, such as customer support, technical support, or customer management
• third-party IT service providers, such as provider of data storage service or business communication platform service

4.2. Except for the recipients prescribed above, we will not disclose your Personal Data to any third party without your prior consent, except where we collected your Personal Data based on any of the legal basis prescribed in 5. below.

4.3. We transfer your Personal Data to any of Affiliate Companies, third-party service providers or third-party IT service providers outside of Thailand. When we transfer it to such entities outside of Thailand, we ensure that appropriate safeguards and protections are taken in place pursuant to applicable laws. However, please acknowledge that some countries that we transfer your Personal Data might not have appropriate safeguards and protections under the applicable laws of Thailand.

5. The legal basis on which we process Personal Data

We process your Personal Data based on a different legal basis depending on the nature of Personal Data and the type of processing involved. We rely on the following legal bases (single or multiple) other than or in addition to your consent, insofar as it applies.

• Performance of a Contract / Entry into a Contract
  Some of Personal Data is processed on the basis that it is necessary for the performance of our agreement with you or for taking steps at your request prior to entering such an agreement. For example, we need to request you to provide your email address, login name, login passwords to create your account for using Services in order to perform our obligation under service agreement with you.
• Legitimate Interests
  A second ground relied upon by us is that it is necessary for the purposes of legitimate interests pursued by us or a third party. These legitimate interests include the operation of Services and our business, maintenance and improvement of Services, pursuit of the safety of Services, such as fraud detection and prevention, charging the payment regarding the chargeable services, providing ads of Services or products or ads of third-party’s services or products. We only rely on such a ground where such interests are not overridden by your interests or fundamental rights and freedoms.
• Research or Statistics / Preparation of Historical Documents or Archives for Public Interest
  A third ground relied upon by us is that it is necessary for research or statistics, or preparation of historical documents or archives for the public interest. For example, we may create statistics relating to the business area to which Services belong for the purpose of our own or third-party’s marketing. We only rely on such a ground where the suitable measures to safeguard your rights and freedoms are taken in place and in accordance with applicable law.
• Compliance with a Law
  A fourth ground relied upon by us is that it is necessary for compliance with a legal obligation. For example, we are required to retain records for fixed periods of time in order to comply with applicable laws.
• Prevention of a Danger / Performance of a Task for Public Interest
  In some rare cases, there may be necessity to prevent or suppress a danger to your or other persons’ life, body, or health, or we may need to perform a task for the public interest.

6. What do we do to keep your Personal Data secure?

We seek to take reasonable security measures to protect your Personal Data against loss, misuse, alteration, and divulgation. Such reasonable security measures include use of adequate security software, restricted access, and assigning a person in charge of managing Personal Data.

However, please note that although we take appropriate steps to protect your Personal Data, no website, product, device, online application or transmission of information, computer system or wireless connection is completely secure and therefore we cannot guarantee the security of your Personal Data.

7. How long do we store your Personal Data?

We retain your Personal Data until it is no longer necessary to fulfill the purposes of processing your Personal Data, or until you request us to erase or destroy your Personal Data. We may be required to retain certain information in order to comply with the laws to which we are subject.

Specific retention periods are determined based on the following considerations: purposes of processing, the nature of Personal Data, and the necessity of retaining Personal Data for legal or business reasons. For example, if you are a customer of Services, we will normally erase your Personal Data within [36] months from the last date on which you use Services; however, we may be necessary to retain the whole of part of your Personal Data for the purpose of establishment, compliance, or exercise of legal claims, defense of legal claims, or the purpose of compliance with the law.

8. What are your rights regarding your Personal Data?

Regarding your Personal Data which we collect and store, you have the rights to:

• request access to and obtain a copy of your Personal Data
• receive your Personal Data or request us to send or transfer your Personal Data to other Data Controllers by the automatic means
• object to the collection, use, or disclosure of your Personal Data
• request to erase, destroy, or anonymize your Personal Data
• request to restrict the use of your Personal Data
• request correction or update of your Personal Data
• withdraw the consent which you have given to us, except where there is a restriction by law or the contract which gives benefits to you (provided, your withdrawal of consent will not affect the lawfulness of procession made prior to such withdrawal)
• complain to the expert committee with respect to our processing of your Personal Data. If you are not satisfied with how we process your Personal Data, you may contact us through the Contact Details below.

9. Contact Details

If you have any questions regarding this Policy, please contact us here; or you may also contact us through the contacts set out below.

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