Privacy Policy

Introduction

This is the Privacy Policy ("Privacy Policy") of CompAsia Co., Ltd. (including affiliated companies, brands, related companies and/or all affiliated/related brands) These entities are collectively referred to as "CompAsia," "CompAsia th," "we," "us," or "our." CompAsia is committed to respecting and protecting your online privacy. This Privacy Policy will explain our practices regarding the collection, use, disclosure, and transfer of your personal data.

1. This privacy policy is part of CompAsia's terms of use. Your use of the platform and/or services is subject to the terms of use and this privacy policy, unless specifically provided otherwise in this privacy policy. The terms defined shall have the same meaning as defined in the terms of use.
2. For processing, managing, and/or handling your relationship with us, we need to collect, use, disclose, and/or transfer your personal data. This privacy policy applies to personal data about you (CompAsia members/users, CompAsia business partners, business/marketing partners, agents, sellers, distributors, suppliers, contractors, service providers, etc.) and/or individuals you provide to us, that we possess or have obtained about you, whether currently or in the future. We will process your personal data in accordance with data protection laws and privacy regulations applicable in the countries where we operate, and this privacy policy only.
3. If you are a company, corporation, or organization, references to "you" and "your" shall include employees, representatives, and agents of yours.
4. By accessing, viewing, downloading, and/or using our platform and/or services, or contacting us, you acknowledge that you have read and understood this privacy policy and agree to us processing your personal data as described in this privacy policy, which may be updated periodically.
5. We may amend or update this privacy policy at any time by posting the amended/updated version on the platform unless otherwise specified. Any amendments or updates shall be effective immediately upon you accessing and/or using our platform and/or services continuously, or contacting us after such amendments or updates to this privacy policy shall constitute acceptance of the amended or updated privacy policy.
6. We need to collect and process your personal data. If you do not provide us with your personal data, or do not consent to this privacy policy, or make any changes to this privacy policy, we may not be able to provide all services to you, and you may have to cancel agreements related to us, and/or stop accessing or using the platform and/or services.

Collecting personal data

1. Personal data
2. Your personal information may be collected from you while you are contacting us, regardless of the method, including transactions and/or communications made with us. Additionally, we may collect your personal information from various sources, including but not limited to meetings, events, competitions, customer satisfaction surveys organized and/or supported by us, as well as from publicly disclosed sources such as directories and CompAsia's social media pages. If you follow, like, or are a fan of such pages. Furthermore, we may collect additional information when we exchange communications with you, such as when you submit requests, file complaints, or contact our support team.
3. In addition, we may receive, store, and process your personal data provided or made available by third parties authorized by you, reference agencies/credit reports, regulatory authorities, and law enforcement agencies for various reasons such as delivering our services, complying with the terms of agreements, and/or to comply with our legal obligations and regulations.

Purpose of obtaining and processing your personal data

Personal information that you provide or collect from you or from other sources that are necessary to achieve the objectives while searching or collecting that information may be processed for the following purposes ("Objectives"):

If you are a member/user of CompAsia:

1. To register an account with us

• For processing, managing, or verifying your identity
• To provide maintenance, care, and improvement of the platform and/or services for you
• To complete your purchase/booking/reservation and verify its accuracy.
• To proceed with payment from you, including authorization and processing of online banking transactions, credit/debit card transactions, and sending receipts to you.
• To communicate with you and to maintain and improve relationships with customers
• To customize and enhance the user experience of your platform and/or service
• To support and manage requests and complaints for you
• For the convenience of participating and managing any of our activities, including competitions, promotions, campaigns, surveys, or questionnaires.
• To conduct research or market surveys, analyze internal marketing activities, customer profiling activities, analyze customer patterns and options, analyze platform-related activities and trends, and user demographic data (non-identifiable) to protect and enforce our legal rights and benefits, including protecting any claims.
• To comply with our legal obligations under laws, regulations, or court orders that are enforceable
• To comply with or as required by any request or order from any law enforcement agency/government or respond to requests for information from public agencies, ministries, legal entities, or similar organizations.
• To detect, investigate, and prevent fraudulent, prohibited, or illegal activities or the misuse of the platform and/or services.
• To transfer or assign benefits, rights, and obligations under any agreement made with us
• For the purpose of managing and updating internally, such as checking, analyzing data, storing data, contact lists, risk management, security, etc.
• For the storage, hosting backup data (whether for disaster recovery or otherwise) of your personal data, whether inside or outside your country, and you agree and consent for us to use and process your personal data for the purposes as specified in this privacy policy.

In case you are a partner of CompAsia group, business/marketing partner, agent, seller, distributor, supplier, contractor, or service provider:

• To hire you to source products and/or services for us/on our behalf
• For processing any payment related to your commercial transactions with us.
• To communicate with you, maintain, and improve relationships with customers
• To support you and manage requests and complaints
• To verify credit references and establish your creditworthiness
• To conduct verification of accuracy or tracking activities or other screening (including background checks) in accordance with legal obligations or regulations or risk management procedures that may be prescribed by law or as we have specified.
• To send seasonal greetings, gifts, newsletters occasionally
• To protect and/or enforce our legal rights and benefits, including any claims protection.
• To comply with our legal obligations under laws, regulations, or court orders that are enforceable
• To comply with or respond to requests or orders from any government agency/law enforcement agency or to respond to requests for information from public agencies, ministries, legal entities, or similar organizations.
• To detect, investigate, and prevent fraudulent, prohibited, or illegal activities or misconduct.
• To transfer or assign our rights, benefits, and obligations under any agreement made with us.
• For the purpose of managing and updating internally, such as checking, analyzing data, keeping records, contact lists, risk management, security, etc. and/or
• For the storage, hosting backup (whether for disaster recovery or other purposes) of your personal data, whether inside or outside your country.

The objectives of marketing and sales promotion

We may use and process your personal data for the following marketing and sales promotion purposes:

• For sending data, notifications, newsletters, updates, sales promotion materials, special product/service offers, upcoming competitions, events, activities, promotions, campaigns, polls, or surveys offered/organized by us and/or selected third parties (business/marketing partners, sponsors, advertisers) that may be of interest to you.
• To send greetings or messages about festivals/celebrations to you
• To notify and invite you to participate in events or activities organized by us and/or selected third parties (business partners/marketing sponsors/advertisers) that may be of interest to you.
• To register for your participation in or attendance at an event or activity and to communicate with you regarding your participation in that event or activity and/or
• To share your personal information within our organization and selected third parties (business partners/marketers, sponsors, advertisers) who may communicate with you for marketing their products, services, events, or promotions occasionally using SMS, phone, email, fax, mail, social media, and/or other appropriate communication channels. You have the right to request us to stop sending marketing materials and sales promotions or contacting you for marketing and sales promotion purposes at any time. Additionally, you can click on the "Unsubscribe" link embedded in marketing and sales promotion emails to opt out of receiving marketing and sales promotion emails in the future. If you unsubscribe, we may still send non-marketing and sales promotion information such as your account information, platform and/or services, or ongoing business relationships.
• If you are a member of CompAsia, your user profile information such as username will be used to identify you when you use the platform and/or services. Your username may be displayed to other users when you submit ratings and/or reviews. We will not disclose or share your email address and other information directly without your consent.
• In addition, we may use processing and sharing of non-identifiable data. The collected data is aggregated statistics and/or non-identifiable with third parties for data analysis, to analyze and develop our marketing strategies, and to improve and develop our platform and/or services in the future. You agree and consent to us using and processing your personal data for the purposes stated in this privacy policy.
• We will request your separate consent for any other purposes not covered above.

The consequences of not consenting to this privacy policy/do not provide your personal information.

The collection of your personal data may be mandatory or voluntary, depending on the purpose of collecting your personal data. In cases where you are required to provide your personal data to us and you choose not to provide such data to us or do not consent to the above privacy policy or this version, we may not be able to provide platform and/or services to you (if you are a member of CompAsia) or engage you to source products and/or services for us or on our behalf, or make payments to you for products and/or services sourced (if you are a partner of CompAsia, business/marketing partner, agent, seller, distributor, supplier, contractor, or service provider of ours).

Disclosure of Your Personal Information

We will not sell, rent, transfer, or disclose your personal information to third parties without your consent. However, we may disclose some of your personal information to the following third parties for one or more of the above purposes:

• Affiliated companies, related companies and/or subsidiaries of ours, close family members and/or emergency contacts of yours as may be notified to us from time to time.
• The person who inherits rights from us, the third party we select (business partners/marketing supporters/advertisers) who offer promotions or organize competitions, events, or campaigns.
• Any individual who is responsible for maintaining confidentiality, which includes the obligation to protect your personal information as confidential, is hired to comply with our obligations to you.
• Any department involved in legal processes or legal processes that may occur

Accountants, consultants, lawyers, accountants, financial advisors, or other professionals appointed to be involved in our business must strictly adhere to confidentiality principles. They are appointed by us to provide services to us.

• Any department that we propose a name or appoint solely by us or jointly with other service providers who provide services or process data on our behalf, or for the purpose of data center consolidation and/or logistics management.
• Data center and/or server located inside or outside your country for the purpose of data storage
• Service providers for convenient storage and management of records, government agencies, law enforcement agencies, courts, administrative agencies, industrial regulatory agencies, ministries, and/or organizations, offices, or municipalities in any country, if necessary or authorized to do so, to comply with laws, regulations, orders, or judgments enforced by courts or administrative agencies, or inquiries from relevant agencies.
• Reference agency/credit report for the purpose of verifying your credit.
• Our business/marketing partners are product and/or service providers to third parties, suppliers, sellers, distributors, contractors, or agents, based on the principle of "need to know", who source products and/or related services related to our business on our behalf or to assist us in preparing platforms and/or services for you.
• Insurance companies for the purpose of applying for and receiving insurance policies if necessary.
• Financial institution for the purpose of applying and receiving credit if necessary
• Banks and financial institutions, merchants, and credit/debit card companies related to your commercial transactions with us. The general public when you become a winner in a competition, participate in our activities or events, submit your scores and/or reviews or other features of the platform and/or services that the general public can view without charge for advertising and publicity purposes.
• Any third party (and consultants/representatives) involved in restructuring, business consolidation, sales, mergers, acquisitions, joint ventures, assignments, transfers, capital utilization, or sale of assets/shares proposed or actually related to all or part of our business, or in the event of insolvency, bankruptcy, or asset foreclosure, and/or
• Any other individuals who make a legitimate request for us to carry out and maintain our business or to perform activities as specified in the objectives or as instructed/authorized by you.

Accuracy of your personal data

We believe that all the personal data you provide is accurate and complete, and there is no part that is misleading or outdated. We will inform you immediately if there are any changes to your personal data. Please note that if you do not maintain your personal data accurately, completely, and up-to-date (including having incorrect or expired payment methods), it may result in you not being able to access and use the platform and/or services.

Your rights

1. Within the scope of data protection and privacy laws applicable in the country where we operate, you have the right to request access, request a copy, request an update, or request the correction of your personal data that we hold. We may charge a small fee (where permitted by law) to cover the cost of managing and processing your request to access your personal data, without prejudice to the above terms. We reserve the right to rely on exceptions as permitted by law and/or any exceptions in collecting, using, and disclosing your personal data.
2. In addition, you have the right to notify us in writing of your withdrawal of consent (in whole or in part) previously given to us, subject to legal restrictions, contractual terms, and reasonable withdrawal periods. However, your withdrawal of consent may have legal consequences arising from such withdrawal. In this regard, the scope of your consent withdrawal for the processing of your personal data may mean that we may not be able to continue our existing relationship with you, or the agreement you have with us may need to be terminated.
3. You can edit, update, or delete your personal information at any time by editing your profile on the "Account Settings" page on the platform. However, please note that your personal information may be stored in our backup system for a period of time. Additionally, you cannot delete data related to past transactions as we track these records.

Privacy Policy

Any personal information you provide to us will be kept only for as long as the purpose of collecting that personal information remains in effect. Your personal information will then be destroyed or anonymized from our records and backup systems in accordance with our data retention policy in cases where your personal information is no longer needed for the aforementioned purposes, unless it needs to be retained further to comply with longer data retention periods to meet legal, regulatory, tax, or accounting requirements.

Security of your personal data

1. We are committed to ensuring that your personal data is securely stored to prevent unauthorized access, disclosure, or other similar risks. We strive to use technical, physical, electronic, and appropriate legal and regulatory measures and industry standards to prevent and protect against unauthorized or unlawful processing, destruction, accidental loss, alteration, disclosure, or access to your personal data without authorization.
2. We will update our security measures periodically and ensure that authorized third parties will only use your personal information for the purposes specified in this privacy policy.
3. The internet is not a secure medium. However, we will use appropriate security measures related to your platform and electronic communication with us. All of our employees and data processors who have access to and are involved in processing your personal data have a duty to respect the confidentiality of your personal data.
4. It is regrettable that we cannot guarantee that transmitting data over the internet or any wireless network will be 100% secure. Even though we implement commercially reasonable measures to protect your personal information, we cannot and do not guarantee unauthorized access, illegal interception, or loss of personal data transmitted to or from CompAsia Co., Ltd. We are not responsible for the actions of any third party that may receive such personal information.

Personal information from children and other individuals

1. Within the scope that you have provided (or will provide) personal information about family members, spouses, dependents (if you are an individual), directors, shareholders, employees, agents, representatives (if you are a legal entity, organization, or corporation), and/or other individuals, you confirm that you have explained (or will explain) to them that their personal information will be sent to and processed by us, and you represent and warrant that you have obtained their consent for the processing (including disclosure and transfer) of their personal data in accordance with this privacy policy.
2. In the case of children (meaning individuals under 18 years of age or below the legal age of majority in your country) or individuals without legal authority to consent, you confirm that you are a parent or legal guardian or a person responsible for self-care or a person appointed by the court to manage their affairs or they have appointed you to act on their behalf to consent to the processing (including disclosure and transfer) of their personal data in accordance with this privacy policy.

Your personal data transfer outside your country

Our information technology storage and server may be located in a country other than yours, which may include but not limited to cases where your personal data may be stored on servers located outside your country. Additionally, your personal data may be disclosed or transferred to agencies located outside your country. Please note that these foreign agencies may be located in countries that may not have data protection standards equivalent to those offered in your country under the laws applicable in your country. You expressly consent to us transferring your personal data outside your country for the aforementioned purposes.

The use of internet and mobile applications

You acknowledge that providing your personal information to us online is at your own risk.

You acknowledge that if you post your ratings and/or reviews on the platform, your ratings and/or reviews will become public information and we will retain them even if your account is canceled. Your email address and phone number will not be visible to others through the ratings and/or reviews you post.

If any part of the platform links you to other websites, those websites do not operate under this privacy policy, and we are not responsible for any issues that may arise from those websites. We recommend that you read and understand the privacy policy of those websites before providing your personal information to them.

We use cookies (alphanumeric identifiers that we transfer to your computer's hard drive or mobile device to enable us to remember your web browser or mobile device, track visits to your platform, or remember your username and/or password each time you log in) to track the usage of your platform. All population data collected through cookies is not personal data, and we may use this data in aggregate, statistical, and/or non-identifiable formats. You can disable cookies by changing settings in your web browser or mobile device, although this may mean that some features on the platform may not work correctly if you set your web browser or mobile device not to accept cookies.

Apart from using cookies and related technologies as explained above, we may also allow certain external companies to help us customize ads that we think may be of interest to users and use other data related to user activities on our platform and/or services (e.g. allowing them to customize ads in a third party's service). These companies may display ads that may place cookies and track user behavior in other ways.

When you install our mobile application on a mobile device for the first time, we will set up an account linked to that mobile device ("Account"). We will collect and use your personal information in accordance with this privacy policy every time you use our mobile application on that mobile device. This includes linking your personal information to your account. Most mobile platforms (iOs, android, etc.) have different permission systems for requesting your consent. The iOs platform will notify you the first time our mobile application requires permission to access certain types of data and will ask for your consent (or denial) to such requests. Android devices will inform you of the permissions our mobile application requires before you use the mobile application for the first time, and your use will be considered as your consent.

The platform may integrate with social sharing features and other related tools that allow you to share information with friends or the public, depending on the settings you have set with the social sharing network. The use of your personal data provided by CompAsia through the social sharing network is subject to the privacy policy control of that social sharing network, not this privacy policy. By connecting your social sharing network account through the platform, you agree that we may collect your personal data from your social sharing network account according to the privacy settings you have set under your social sharing network account, and for the purposes specified in this privacy policy.

We may receive, record, and store location service data from your computer or mobile device automatically when you interact with us. You consent to us using non-personally identifiable location service data collected from you. In cases where location service data can identify individuals, we will provide options for managing the disclosure of this data to you, depending on the functionalities available on your computer or mobile device. You may benefit from advanced options for managing location service data. Computers or mobile devices may report GPS location when you interact with us. If you enable location service settings, such data will not be identified as personal information unless required otherwise by relevant laws.

The collection of computer or portable device location data is at your discretion. You can enable or disable location services at any time when using the platform through the settings of your computer or portable device. By using the platform with location services enabled, you consent to us collecting and sharing your computer or portable device location data through the platform as specified in this privacy policy. We are not liable for any claims or damages arising from your decision to allow other users to view your computer or portable device location data as specified in this privacy policy.

Contact details

If you have any questions regarding this privacy policy, or have any further inquiries, complaints, or requests to access or amend data related to your personal information, you can contact us at support-th@compasia.com or write a letter to CompAsia Co., Ltd., 184/181 Forum Tower, 28th Floor, Ratchadaphisek Road, Huai Khwang Sub-district, Huai Khwang District, Bangkok 10310, Thailand.

The English language version will prevail.

In case of any conflicts or discrepancies between the English version and other translated versions of this privacy policy, the English version shall prevail.

Last updated on May 19, 2020