This Statement may be subject to updates. Any material future changes or additions to the processing of personal information as described in this Statement affecting you will be communicated to you through an appropriate channel. For example, we may place a prominent notice on a product site or email you to let you know of an updated Statement.
1. THE INFORMATION WE COLLECT AND HOW WE COLLECT IT
In providing our services, we collect, store and use the following Information relating to you:
“Information” is Personal Information and Non-Personal Information;
“Personal Information” is any information or combination of information that relates to you, and can be used to identify you. Personal Information may include the following:
information you make available to us when you open an account or use our services, such as your name, telephone number, email address and credit card details;
information which you make available to our services as you use them, including Shared Information you make available to others through our services and information you store using our services;
shared Information that others using our services make available about you, such as information contained in posts they make and communications they make to you or others using our services;
online identifier which may be collected with unique identifiers tied to the browser, application, or device you are using. This helps us do things like maintain your language preferences across browsing session; and
Information we collect as you use our services, such as certain Location Data, Log Data and public information.
the IP address of the device or internet service you use to access our services,
other information made available by you or others that gives an indication as to where you are or have been located, such as account information that indicates where you are located and Shared Information you or others post indicating your location, such as any geotag information that is embedded in any photos you make available to us; and
if you have provided us with your location data previously and would like us to delete such existing location data, you may be able to do so via our services.
information about communications you have made using our services, such as the people you’ve communicated with and the time, data and duration of your communications; and
metadata, which means information related to items you have made available through our services, such as the date, time or location that a shared photograph or video was taken or posted.
“Non-Personal Information” is any information that relates to you but from which it is not practicable to directly or indirectly identify you, including Personal Information in aggregated, anonymized or pseudonymized form.
“Shared Information” is information about you or relating to you that is voluntarily shared on our services, including postings that you make on our services (including your public profile, the lists you create), any postings from others that you re-post and including Location Data and Log Data associated with these postings. Shared Information also includes information about you (including Location Data and Log Data) that others who are using our services share about you.
2. HOW WE USE YOUR INFORMATION
We may use your Information for any of the following purposes:
to provide our services to you;
for customer service, security, fraud-detection, archival and backup purposes in connection with the provision of our services;
to provide you with advertising;
to better understand how you access and use our services, for the purposes of trying to improve our services and to respond to customer desires and preferences, including language and location customization, personalized help and instructions, or other responses to your and other customers’ usage of our services;
to help us develop our new services and improve our existing services;
to assess the effectiveness of and improve advertising and other marketing and promotional activities on or in connection with our services;
for the purposes of software verification or administering software upgrades; and
to allow you to participate in surveys and other activities about our products and services.
Please note that for the purposes of seeking to provide our users with a better experience, to improve our services or otherwise where you have consented, Personal Information collected through one of our services may, subject to user privacy controls (where available), be used by our other services (including in an aggregated or individualized manner).
For example, Personal Information collected during your use of one of our services may be used to suggest particular content that can be made available to you on another service or be used to try to present more relevant advertising to you in another service. You may also from time to time ask us to migrate or export your Personal Information contained in one of our services to another of our services, where such migration option is available.
3. YOUR RIGHTS
You may have rights under Thai and other laws to have access to your personal information and to ask us to rectify, erase and restrict use of, your personal information. You may also have rights to object to your personal information being used, to ask for the transfer of personal information you have made available to us and to withdraw consent to the use of your personal information. Further information on how to exercise your rights is set out below.
We will honor your rights under applicable data protection laws. You have the following rights under Thai laws, and may have similar rights under the laws of other countries.
Right of subject access: The right to make a written request for details of your personal information and a copy of that personal information
Right to rectification: The right to have inaccurate information about you corrected or removed
Right to erasure (‘right to be forgotten’): The right to have certain personal information about you erased
Right to restriction of processing: The right to request that your personal information is only used for restricted purposes
Right to opt out of marketing: You can manage your marketing preferences by unsubscribe links found in the communications you received from us or by visiting the preference setting
Right to object: The right to object to processing of your personal information in cases where our processing is based on the performance of a task carried out in the public interest or we have let you know the processing is necessary for our or a third party’s legitimate interests. In these circumstances the right to object is not absolute.
Right to data portability: The right to ask for the personal information you have made available to us to be transferred to you or a third party in machine-readable format
Right to withdraw consent: The right to withdraw any consent you have previously given us to handle your personal information. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information prior to the withdrawal of your consent
These rights are not absolute and they do not always apply in all cases. In response to a request, we will ask you to verify your identity if we need to, and to provide information that helps us to understand your request better. If we do not comply with your request, whether in whole or in part, we will explain why.
In order to exercise your rights please contact us via contact information as mentioned above.
5. SHARING OF YOUR PERSONAL INFORMATION
A WORD ABOUT SHARED INFORMATION
A number of our services enable Shared Information to be shared publicly with all users of that service and not just your contacts. Our social media services in particular are primarily designed to help you share Shared Information with the world, so Shared Information can be broadly and instantly transmitted and will remain public for as long as you do not delete it (and even after you delete Shared Information, it may still be separately cached, copied, or stored by, or remain public through, other users or third parties who are not affiliated with and not controlled by us).
Please consider carefully what you post and communicate through our services.
6. COMMUNICATIONS FROM US
Newsletters and other types of communications
When you use our services, we may use your Information to send you emails, newsletters or push notifications to your device. If you no longer wish to receive these communications, you can do so by following the unsubscribe instructions in the emails we send to you, opting out of notifications at the device level (if available) or contacting our Privacy Officer.
We may from time to time send you service-related announcements when we consider it necessary to do so (such as when we temporarily suspend one of our services for maintenance). You may not opt-out of these service-related announcements, which are not promotional in nature.
7. A WORD ABOUT SENSITIVE PERSONAL INFORMATION
In some jurisdictions, certain Personal Information, such as information about your race or ethnic origin, religious or philosophical views or personal health, is characterized as “sensitive” and is subject to stricter regulation than other personal information. Please note that content and information that you input to our services, such as photographs or information about your school or social activities, may reveal your sensitive Personal Information to others.
Please note that we do not use your sensitive Personal Information for the purpose of serving advertising to you.
We urge you to consider whether it is appropriate to communicate sensitive Personal within our services.
8. THIRD PARTY SERVICES ON OUR SERVICES
Our services may include, or they may link you to, social media or other services (including websites) provided by a third party. For example:
you may be able to share content on our services using services provided by third parties. The third parties who provide such services may be able to collect your Information and Personal Information (including your Log Data), and may set cookies on your computer to enable such third party services to function properly; and
We may (whether in advertisements or otherwise within our services) provide you with links that allow you to access third party services or websites.
9. INTERNATIONAL TRANSFER
10. HOW WE SECURE PERSONAL INFORMATION
We have put in place physical, electronic, and managerial procedures designed to help prevent unauthorized access, to maintain data security, and to use correctly the Information we collect online. These safeguards vary based on the sensitivity of the Information that we collect and store.
In some cases, we will use encryption technology (such as SSL) to protect certain sensitive Information provided by you to us. Please be aware that despite our efforts, no data security measures can guarantee 100% security at all times. Our systems and the communications networks through which you access our services may be subject to security breaches and failures which are due to circumstances beyond our reasonable control.
11. RETENTION PERIOD OF PERSONAL INFORMATION
Subject to applicable laws and regulations (including as set out under the “Sharing of your Personal Information” section above), we will only retain your Personal Information for so long as is necessary to fulfill the purposes as set out under the “How We Use Your Information” section above.
We retain your information in accordance with our enterprise records retention schedule. You can find more information on the criteria used to calculate the retention periods set out below.
Loxley Evolution Technology has a Records and Information Governance team that works in conjunction with our Privacy Team to implement policies and rules relating to the retention of personal information. We have an enterprise records retention schedule that is based upon a classification scheme consisting of business functions, record classes, and record types.
We calculate retention periods for your personal information in accordance with the following criteria:
the length of time necessary to fulfill the purposes we collected it for
when you or your employer (or other subscriber providing for your access to our Services) cease to use our Services
the length of time it is reasonable to keep records to demonstrate that we have fulfilled our duties and obligations
any limitation periods within which claims might be made
any retention periods prescribed by law or recommended by regulators, professional bodies or associations
the existence of any relevant proceedings