“Personal Information” shall mean any information about an individual who can be identified from that information either directly or indirectly, including without limitation, information such as name, address, telephone number, e-mail address, and any other personal information. For the avoidance of doubt, Personal Information shall not include job title, workplace, business address or any other information excluded from the definition of Personal Information under Thai law. When using our website or application, you accept, consent and agree to the terms and conditions of this Policy.
1. Information Collection
Personal information which identifies you, either directly or indirectly, as an individual that may be collected by the Company may include:
• If you create an account on platform operated by the Company - your username, password, email, birthday, gender, mobile phone number, and address
• If you use our services at our restaurants, through call center, online delivery or purchase any products or use services through our platforms or otherwise – what you spend, how much you spend, where you spend, when you spend, how frequently you spend, financial account information, such as credit card number and other payment information.
• If you register member with us – accumulating order amounts, point collection, member tier, membership duration, interesting in any products and marketing activities.
• If you take a survey or interact with us in various other ways - demographics information, your comments, feedback, questions or suggestions, and information about subjects that may interest you.
The Company may also collect aggregated data or anonymized data that does not directly identify you. We may combine information we collect about you with information we receive from third parties. In some instances, we may combine other information with Personal Information. If other information is combined with Personal Information or if other information is used to identify an individual, such information will be treated by us as Personal Information.
2. Use of Personal Information
• Process and manage your purchase and use of the Company’s products and Services, including your accounts and program participation, your use of the Sites.
• Respond to your customer service inquiries, post your comments or statements on any blog or other online forum maintained on our Sites, or take other actions in response to your inquiries or other Site activities.
• Create personalized promotions by combining your Personal Information with non-personal information about you, such as the amounts and types of purchases you make or any benefits you receive through our programs.
• Communicate with you by post, telephone, email and SMS about your orders or purchases, your services, accounts and program participation, a contest or sweepstakes you have entered, and your requests for information.
• Communicate with you by post, telephone, email and SMS about our brands, products, events or other promotional purposes, including co-branded offers and Group of Companies and partner offers.
• Request feedback or participation in surveys, conduct market research and/or analysis for statistical, profiling or other purposes for us to review, develop and improve the quality of our Services, and test and improve our systems, and prevent the misuse or improper use of our Services.
3. Sharing Information
We may share your Personal Information as follows:
• We may share your Personal Information to third party service providers who provide data processing services to us, or who otherwise process Personal Information for purposes such as credit card and payment processing, business analytics, customer service, marketing, or distribution of surveys, to facilitate the delivery of online services and advertising tailored to your interests, and/or fraud prevention. Our third-party service providers will only process Personal Information as needed to perform their functions. They are not permitted to share or use the Personal Information for any other purpose.
• We may share your Personal Information to business partners with whom we may jointly offer products or services, or whose products or services may be offered on our Sites. You can tell when a third-party business partner is involved in a product or service you have requested because their name will appear, either alone or with ours. If you choose to access these optional services, we will on occasion share your Personal Information with those partners. An example of a business partner would be a third-party loyalty program that you will earn points for, through Services.
• We may share your Personal Information to our Group of Companies - our Group of Companies' employees who have access to this Personal Information with our permission and who need to know or have access to this Personal Information to perform the service requested by you (including customer services) and internal (audit/compliance) investigations.
• We may share your Personal Information where required or permitted by Law– upon lawful request, in response to legal process, and when required to comply with laws, and to protect ourselves against liability or legitimate interests or to share your Personal Information to the purchasers in connection with any sale, assignment, or other transfer of all or a part of our business or company, to enforce or apply the terms and conditions applicable to our services or to protect the rights, property, or safety of the Company, our users, or others. We may also share your Personal Information where required or permitted by Law.
• Business Reorganization– we may share your Personal Information in case of any sale, assignment or other transfer of our business, or transition of service to another provider. We will ask for your consent if required by applicable law.
We provide appropriate protections for such sharing of Personal Information as required by applicable law to prohibit third parties from using your Personal Information for their own purposes, and to address the security and confidentiality of your Personal Information. Except as specified above, we will not disclose your Personal Information to third parties without your consent.
Transferring Information We may transfer your Personal Information to the countries outside of Thailand to our Group of Companies and our third party service providers as part of our normal business operations to perform our Services (i.e., our IT service provider), that from the standpoint of the data protection supervisory authority in Thailand, may not have an "adequate standard of personal data protection" as specified by the data protection supervisory authority in Thailand if and when the applicable Thai data protection law enters into force.
6. Personal Data Retention Your Personal Information collected, used, or disclosed for the purposes hereunder will be stored only to the extent necessary during the term of your participation in the Services with us, or for the period necessary to fulfil the purposes outlined in this, including during a transition period (e.g. for the compliance of our obligations regarding data retention as established in applicable laws), if any. In principle we will retain your Personal Information as long as required or permitted by applicable law. Afterwards, we will remove your Personal Information from our systems and records and/or take steps to properly anonymize it so that you can no longer be identified from it.
7. Personal Data Protection We maintain reasonable physical, electronic, and organizational security measures to protect your Personal Information against accidental or unlawful destruction or accidental loss, alteration, or unauthorized disclosure or access. We use Secure Socket Layer technology to encrypt credit card information during transit. Through your personal account, you also have the ability to save credit card details for faster future bookings and payments. Your card details are encrypted, and you can always log in to your personal account to delete, edit, or add certain credit card details. For security reasons, the number cannot be edited (but the card details can be deleted). When viewing card details, only the last 4 digits of the number will be visible. Please note that we will store the last 4 digits of your credit card securely upon any payment made (this is required to manage any refund requests for that booking).
8. Personal Data Subject Rights You have the following rights under the conditions set out under applicable law
• Access: You are entitled at any time to obtain your Personal Information that we store, in accordance with applicable law and without any fee. However, in exceptional cases we ask you to pay reasonable fees before we provide the information if permitted by applicable law.
• Rectification: You may request that we rectify any of your Personal Information that is incomplete or incorrect.
• Deletion: You may request that we delete your account and your Personal Information.
• Restrictions of Processing: You may ask us to cease processing of your personal information for example if you have objected to the processing and the existence of legitimate grounds is still under consideration.
• Objection: You have the right to object to collection, use or disclosure of Personal Information, which is carried out to protect our legitimate interests or for performance of tasks in the public interest, at any time, in accordance with the statutory provisions. If you file an objection, we will continue to collect, use or disclose your Personal Information only if we can document mandatory and legitimate reasons that outweigh your interests, rights and freedoms, or if collection, use or disclosure is for the assertion, exercise or defense of legal claims, as may be applicable.
• Right to Revoke Consent: You have the right to withdraw your consent at any time, without affecting the lawfulness of our processing based on such consent before it was withdrawn.
• Data Portability: If applicable, you may request us to send you your Personal Information which we store, in a commonly used and machine-readable format which shall be decided at our sole discretion.
To protect your privacy and security, we will verify your identity before responding to such request, and your request will be answered within a reasonable timeframe. We may not be able to allow you to access certain Personal Information in some cases e.g. if your Personal Information is connected with personal information of other persons, or for legal reasons. In such cases, we will provide you with an explanation why you cannot obtain this information. We may also deny your request for deletion or rectification of your Personal Information due to statutory provisions, especially those affecting our accounting processes, processing of claims, for fraud detection or prevention purposes, and mandatory data retention, which may prohibit deletion or anonymization.