Privacy Policy
Harborland
Company Limited (“Company”) is company that operates an
indoor playground business conducts and compliance with applicable legal
framework. The Company is aware of your trust in the Company products /
services and recognizes your need for security in transaction and the handling
of your personal data.
For prioritizing your privacy and safeguarding your personal
data, the Company, therefore, has set out policies, regulations and rules for
the Company's business providing strict measures in protecting your personal
data so that you can be assured that your personal data entrusted to Company
will be processed to meet your needs and in accordance with the laws.
1.
What is the purpose of this Policy?
This Policy is to inform you, as a data subject and a user of
the products and/or services to be aware of the purposes and details of the collection,
usage and/or disclosure of your personal data as well as your legal rights in
connection with personal data.
2.
Which personal data that the Company collects,
uses, and/or discloses?
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2.1 Personal Data That You Gave Us:
Personal data that you gave us directly,
or through the use of our products and/or services, or through the use of other
organizations' products and/or services that in turn use our products and/or
services, that can directly or indirectly identify you, such as:
§
Name
§
Telephone number
§
Email address
§
ID of Facebook, Google, Line,
Instagram etc.
§
Address
§
Birthdate
§
Gender
§
Still images, animations, audio data
§
Payment information, e.g., parts of credit
card credentials, citizen/tax identification number
§
Subscription information to merchants in
the platform
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2.2 Indirect Personal Data:
the data related to you that you did not
directly give us but we can collect from your usage of our products and/or
services, such as:
§
Device information
, e.g., IP address,
MAC address, Cookie ID, UUID, hardware model. The Company might associate these information to your account.
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2.3 Usage Data:
the usage and transaction data that
is collected automatically through your usage of our products and/or services,
such as:
§
Log information: The log data is
automatically collected by the system via Company's and/or 3rd parties tools, e.g., Google Analytics, Facebook, when
you uses our products and/or services. The Company might send cookies or other
tools that aid this collection. Log information is, for example:
§
Log in and log out events
§
Search queries
§
Input data
§
Command actions
§
IP address
§
Errors, warnings
§
Logged in devices, software version, software
installation details
§
Viewing news and promotions,
collecting/using points, collecting/using coupons,
purchasing goods, chatting, and doing other activities with the merchants
you subscribed to
§
Location Information:
When you use a location-enabled service
and have given the permission to collect the location information, we may
collect, store, process information out of that data and use, redistribute the
data and information in non-personally identifiable forms.
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2.4 Sensitive Data
is personal data that is specially
categorized by law. The Company's products and/or services, in general,
will not collect any sensitive data. If any products and/or services of the
Company are collecting such data, it will be stated clearly in their additional
privacy policies for your consideration.
3.
What are the Company's purposes of collecting,
using and/or disclosing your Personal data?
The Company will collect your Personal Data for your benefits in
using products and/or services; for performing legal obligations required by
any law applicable to Company or you; and for any purposes provided in this Policy,
as follows;
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3.1 For your benefits in using the
Company's products and/or services that meet your own purposes
, such as:
§
(1) To log in as a registered user
§
(2) To receive notifications and other
information during the use of the products and/or services
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3.2 To comply with relevant or applicable
law (Legal Obligation)
, for instance,
§
(1) to comply with an order from a competent
authority
§
(2) to comply with
applicable laws, including Computer Law, and other laws to which the
Company is subject both in Thailand and in other countries including
regulations and rules issued pursuant to such laws.
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3.3 For improving, developing of the Company's
Products and/or Services
The Company may use your personal
data in improving and developing of its products and/or services in order to
serve you better.
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3.4 For better services for you from the
Company
The
Company may use your personal
data for you to receive products and/or services that are better and
suitable for your need.
4.
To whom may the Company disclose your Personal
Data?
The Company may disclose your Personal Data to other persons to
the extent permissible under your consent or law. The persons or entities
receiving such data will collect, use, and/or disclose the Personal Data to the
extent permissible under your consent or related to this Policy
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4.1 Personal Data That You Gave Us:
The Company will strictly use the Personal Data That You Gave Us
only within the Company or its subsidiaries. The Company will not disclose it
in other purposes unless it is clearly stated and you have given an explicit
consent or the Company is obligated by law to do so.
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4.2 Indirect Personal Data:
The Company may use the Indirect Personal
Data within the Company or its subsidiaries. The Company may also disclose
to other parties it in non-personally identifiable forms. The
Company will not disclose it in other purposes unless it is clearly stated
and you have given an explicit consent or the Company is obligated by law
to do so.
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4.3 Usage Data:
The Company may use the Usage Data within
the Company or its subsidiaries. The Company may also disclose to other parties
it in non-personally identifiable forms. The Company will not
disclose it in other purposes unless it is clearly stated and
you have given an explicit consent or the Company is obligated by law to
do so.
5.
Will the Company send or transfer your Personal
Data to other countries?
When it is necessary, the Company may send or transfer your
Personal Data to receivers in ordinary course of the Company's business,
e.g. sending or transferring the Personal Data to be stored on server/cloud
services in other countries. The Company will try its best to choose such
services that are of good standard and have privacy protections mechanisms that
are in consistent with privacy measures in this policy.
6.
How long does the Company retain your Personal
Data?
The Company will retain your Personal Data for as long as necessary during the period you are a customer or under relationship with the Company, or for as long as necessary in connection with the purposes set out in this Policy, unless law requires or permits longer retention period. For example, retention pursuant to Cyber Crime Act and Anti-money Laundering Law, retention for proving and examining in the event of dispute within legal prescription period of not over 5 years from the date of the last time you used the Products and/or Services of the Company.
The Company may erase destroy, or anonymize the Personal Data
when it is no longer necessary or when the period lapses.
7.
How does the Company protect your Personal
Data?
For retention of your Personal Data, the Company implements
technical measures and organizational measures to ensure appropriate security
in the Personal Data processing and preventing Personal Data breach. The
Company has set out policies, rules and regulations on Personal Data
protection, e.g. security standards of information technology and measures to
prevent data receivers from using or disclosing the data outside the purposes
or without authorization or unlawfully. The Company will amend the policy,
rule and regulation as frequently as necessary and appropriate.
Moreover, the Company's executives, staffs, employees,
contractors, agents, advisers and data receivers are obligated to keep the
Personal Data in confidence pursuant to confidentiality measure provided by the
Company.
8.
What are your rights related to Personal Data?
Your rights described here are legal rights that you should be
informed. You may exercise any of these rights within legal requirements and
policies at the present or as amended in the future as well as regulation set
out by the Company. In case you are under 20 years old or your
legal contractual capacity is restricted, your father and mother, guardian or
representative may request to exercise the rights on your behalf.
The exercise of rights above may be restricted under relevant
laws and it may be necessary for the Company to deny or not be able to carry
out your requests, e.g. to comply with laws or court orders, public tasks, your
request in breach of rights or freedom of other persons, etc. If the Company
denies the request, the Company will inform you of the reason.
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8.1 Withdrawal of consent
: If you have given consent to the Company to
collect, use and/or disclose your Personal Data (whether before or after the
effective date of the Personal Data Protection law), you have the right to
withdraw such consent at any time throughout the period your Personal Data
available to Company, unless it is restricted by laws or you are still under
beneficial contract.
Withdrawal of your consent may affect your use of products and/or
services. For example, you may not be able to use the services as a
registered user, you may not receive privileges, promotions or new
offers, products and/or services that are enhanced and consistent with your
needs, or not receive beneficial information, etc. For your benefits, you are
advised to learn and ask for consequences before withdrawing your consent.
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8.2 Data Access
: You have the right to access your Personal
Data that is under the Company's responsibility; to request the Company to make
a copy of such data for you.
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8.3 Data Portability
: You have the right to obtain your Personal
Data if the Company organizes such Personal Data in automatic machine-readable
or usable format and can be processed or disclosed by automatic means; to
request the Company to send or transfer the Personal Data in such format
directly to other data controllers if doable by automatic means; and to request
to obtain the Personal Data in such format sent or transferred by the Company
directly to other data controllers unless not technically feasible
Your Personal Data above must be under your consent given to the
Company to collect, use, and/or disclose; or those the Company deems necessary
to collect, use and/or disclose to allow you to use products and/or services
that meet your need under your contract with the Company; or to take steps at
your requests before using products and/or services; or as legally required by
competent authority.
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8.4 Objection
: You have the right to object to collection,
use and/or disclosure of your Personal Data at any time if such doing is
conducted for legitimate interests of the Company, corporation or individual
which is within your reasonable expectation; or for carrying out public tasks.
If you request to object, the Company will continue collecting, using and/or
disclosing your Personal Data only when the Company can establish a legal basis
that doing so is more important than your fundamental rights; or to affirm
legal rights; to comply with laws; or to defend a legal proceedings, depending
on a case by case basis.
In addition, you have the right to object to collection, use
and/or disclosure of your Personal Data carried out for purposes related to
marketing, scientific, historical or statistical research.
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8.5 Data Erasure or Destruction
: You have the right to request the Company to
erase, destroy or anonymize your Personal Data if you believe that the
collection, use and/or disclosure of your Personal Data is against relevant
laws; or retention of the data by the Company is no longer necessary in
connection with related purposes under this Policy; or when you request to
withdraw your consent or to object to the processing as earlier described.
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8.6 Processing Suspension
: You have the right to request the Company to
suspend processing your Personal Data during the period where the Company
examines your rectification or objection request; or when it is no longer
necessary and the Company must erase or destroy your Personal Data pursuant to
relevant laws but you instead request the Company to suspend the processing.
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8.7 Data Rectification: You have
the right to rectify your Personal Data to be updated, complete and not
misleading.
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8.8 Complaint Lodging
: You have right to complain to competent
authorities pursuant to relevant laws if you believe that the collection, use
and/or disclosure of your Personal Data is violating or not in compliance with
relevant laws.
9.
Changes
Our Privacy Policy may change from time to time. We will not
reduce your rights under this Privacy Policy without your explicit consent. We
will post any privacy policy changes on this page and, if the changes are
significant, we will provide a more prominent notice (including, for certain
services, email notification of privacy policy changes). We will also keep
prior versions of this Privacy Policy in an archive for your review.
10.
How can you contact the Company and the Data
Protection Officer?
If you have any suggestions or inquiries regarding collection,
usage and/or disclosure of your Personal Data as well as a request to exercise
your rights under this Policy, you may contact the Company and/or the Data
Protection Officer via the following channel:
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Email: harborlandgroup@gmail.com
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Company address: Harbor Office (15th fl.)
4/222 Moo. 10 Thung Sukha, Sriracha, Chonburi 20230
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Telephone : (+66)65-848-1000, (+66)65-848-2000