Privacy Policy

A. Introduction

This is the Privacy Policy (“Privacy Policy”) of CompAsia Co., Ltd. (including its affiliates, brands, related companies and/or all related affiliates/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 describe our practices regarding the collection, use, disclosure, and transfer of your personal information.

1. This privacy policy is part of the terms of use of CompAsia. Your use of the platform and/or services is subject to these terms of use and this privacy policy, unless specifically stated otherwise in this privacy policy. The terms defined shall have the same meaning as defined in the terms of use.
2. In order to process, manage, and/or handle 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 (members/users of CompAsia, CompAsia partners, business/marketing partners, agents, vendors, distributors, suppliers, contractors, service providers, etc.) and/or individuals you provide to us that we hold or that we receive about you, whether currently or in the future. We will process your personal data in accordance with applicable data protection and privacy laws in the countries where we operate and this privacy policy only.
3. If you are a company, legal entity, or organization, references to the terms "you" and "your" will include your employees, agents, and representatives as well.
4. Accessing, browsing, downloading, and/or using our platform and/or services or contacting us means that you acknowledge that you have read and understood this privacy policy and agree to our processing of your personal data in the manner described in this privacy policy, which may be amended from time to time.
5. We may modify or update this privacy policy at any time by posting the revised/updated version on the platform. Unless otherwise specified, any modifications or updates will take effect immediately. Your continued access to and/or use of our platform and/or services, or your interaction with us after the modifications or updates to this privacy policy, constitutes your acceptance of the revised 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 any amendments to this privacy policy, we may not be able to provide you with all services, and you may need to terminate any agreements related to us and/or stop accessing or using the platform and/or services.

C. Collection of Personal Data

1. The term "personal data" refers to any information that we possess or control, which relates to an individual directly or indirectly to the extent that the individual can be identified, or can be identified from such information, such as name, address, phone number, passport/ID number, date of birth, email address, gender, ethnicity, bank details, credit/debit card details, etc. The type of personal data collected depends on the purpose of collection. We may "process" your personal data by collecting, recording, storing, using, disclosing, and/or deleting such information.
2. Your personal information may be collected from you when you interact with us in any way, 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 available 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 if you send a request, file a complaint, or contact our support team.
3. In addition, we may receive, store, and process your personal data that is provided or made available by third parties you authorize, reference/reporting agencies, regulatory and law enforcement agencies for various reasons such as delivering our services, complying with the terms of the agreement, and/or to fulfill our legal and regulatory obligations.

1. The purpose of collecting and processing your personal data

The personal information you provide or collect from you or from other sources necessary to achieve the objectives while searching for or collecting that information may be processed for the following purposes (collectively referred to as "Purposes"):

 In the case that you are a member/user of CompAsia:

1. To register a user account with us

• To process, manage, or verify your identity
• to provide, maintain, and improve the platform and/or services for you
• To complete your purchase/reservation/book and verify accuracy
• To process payments from you, including authorizing and processing online banking, 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 your user experience with the platform and/or services
• To provide support and manage requests and complaints for you
• To facilitate participation and management of any of our activities, including competitions, promotions, campaigns, polls, or surveys.
• To conduct research or market surveys, internal market analysis, customer profiling activities, analysis of customer patterns and preferences, analysis of usage and trends related to our platform and/or services, and demographic data of our users (anonymously) to protect and/or enforce our legal rights and interests, including the protection of any claims.
• To comply with our legal obligations and regulations under applicable laws, regulations, or court orders.
• To comply with or as required by the request or order of any law enforcement/government agency, or to respond to a request for information from public agencies, ministries, legal entities, or similar agencies.
• To detect, investigate, and prevent fraudulent, prohibited, or illegal activities or the misuse of the platform and/or services.
• to transfer or assign our rights, benefits, and obligations under any agreements made with us
• For management and internal update purposes such as auditing, data analysis, data storage, contact lists, risk management, security, etc. and/or
• For 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 to us using and processing your personal data for the purposes outlined in this privacy policy.

In the case that you are a CompAsia group partner, 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
• To process any payments related to your commercial transactions with us
• to communicate with you and maintain and improve relationships with customers
• To support you and manage requests and complaints
• To verify your credit reference information and determine your creditworthiness.
• To carry out verification or monitoring activities or other screenings (including background checks) in accordance with legal obligations or regulations or risk management procedures that may be stipulated by law or that we have established.
• To send seasonal greeting messages, gifts, occasional newsletters
• To protect and/or enforce our legal rights and interests, including the protection of any claims.
• To comply with our legal obligations and regulations under applicable laws, regulations, or court orders.
• To comply with or respond to requests or orders from any government agency/law enforcement or in response to information requests from public agencies, ministries, legal entities, or similar agencies.
• To detect, investigate, and prevent fraudulent, prohibited, or illegal activities, or omissions or misconduct.
• To transfer or assign our rights, benefits, and obligations under any agreements made with us.
• For management and internal update purposes such as auditing, data analysis, record keeping, contact management, risk management, security, etc. and/or
• For storage, hosting backup data (whether for disaster recovery or otherwise) of your personal information, whether inside or outside your country.

1. Marketing and Promotion Objectives

We may use and process your personal data for the following marketing and promotional purposes (“Marketing and Promotional Purposes”):

• To send information, notifications, newsletters, updates, promotional documents, announcements of product-related privileges, services, upcoming competitions, events, activities, promotions, campaigns, polls or surveys proposed/organized by us and/or third parties we select (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 third parties we select (business/marketing partners, sponsors, advertisers) that may be of interest to you.
• To process your registration to participate in or join 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 with selected third parties (business/marketing partners, sponsors, advertisers) who may communicate with you to market their products, services, events, or promotions from time to time using SMS, phone, email, fax, mail, social media, and/or other appropriate communication channels, you have the right to request that we stop sending marketing and promotional materials or contacting you for marketing and promotional purposes at any time. Additionally, you can click the "Unsubscribe" link embedded in the relevant marketing and promotional emails to avoid receiving future marketing and promotional emails. If you unsubscribe, we may still send you non-marketing and promotional information, such as your account information, platform and/or services, or our ongoing business relationships.
• If you are a CompAsia member, your user profile information, such as your username, will be used to identify you when you use the platform and/or services. Your username may be visible 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, process, and share non-identifiable information. The collected data is statistical and/or non-identifiable with third parties to analyze data and to analyze and develop our marketing strategies and to improve and develop the platform and/or services further. You agree and consent to our use and processing of your personal data for the purposes stated in this privacy policy.
• We will seek separate consent from you for any purposes not listed in the categories mentioned above.

The consequences of not consenting to this privacy policy / not providing your personal information

The collection of your personal information may be mandatory or voluntary, depending on the purpose of collecting your personal information. In the event that you are required to provide your personal information to us, and you do not or choose not to provide such information to us, or do not consent to the above or this privacy policy, we will not be able to provide you with the platform and/or services (if you are a member of CompAsia) or engage you to supply products and/or services to us or on our behalf, or make payments to you for the products and/or services provided (if you are a partner of CompAsia, a business/marketing partner, agent, vendor, distributor, supplier, contractor, or service provider).

Your personal information disclosure

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 purposes mentioned above:

• Affiliated companies, related companies and/or our subsidiaries, close family members and/or emergency contacts as may be notified to us from time to time.
• Third-party successors selected by us (business/marketing partners, sponsors, advertisers) who offer promotions or organize competitions, events, or campaigns.
• Any person who is responsible for maintaining confidentiality and has promised to keep your personal information confidential, which we have hired to fulfill our obligations to you.
• Any party involved in legal proceedings or potential legal processes

Auditors, consultants, lawyers, accountants, or other financial advisors or professionals appointed to be involved with our business under strict confidentiality, who have been appointed by us to provide services to us.

• Any party that we nominate or appoint solely by ourselves or in conjunction with other service providers, which provides services or processes data on our behalf, or for the purpose of data centralization and/or logistics management.
• Data centers and/or servers located in or outside your country for the purpose of data storage
• Providers of storage and record management facilities, government agencies, law enforcement agencies, courts, lower courts, regulatory/professional agencies, industry regulatory agencies, ministries, and/or legal entities or organizations, offices, or municipalities in any country, if necessary or permitted to do so, to comply with applicable laws, regulations, orders, or enforceable court judgments or inquiries from relevant agencies.
• Reference agency/credit report for the purpose of checking your credit
• Our business/marketing partners, third-party product and/or service providers, suppliers, vendors, distributors, contractors, or agents, adhere to the principle of "need to know," which provide related products and/or services associated with our business on our behalf or to assist us in providing platforms and/or services to you.
• Insurance company for the purpose of applying and receiving insurance policies if necessary
• Financial institutions for the purpose of applying for and receiving loans 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 events or activities, submit your scores and/or reviews or other features of the platform and/or services that the general public can view without compensation for advertising and public relations purposes.
• Any third party (and advisors/agents) involved in restructuring, mergers, sales, consolidations, acquisitions, joint ventures, assignments, transfers, capital utilization, or the sale of proposed or actual assets/shares related to all or part of our business, or in the unlikely event of bankruptcy, insolvency, or being placed under guardianship, and/or
• Any other person who reasonably claims that we can operate and maintain our business or carry out activities specified in the objectives or as instructed/authorized by you.

Your personal data accuracy

We consider all personal information you provide to be accurate and complete, and there is no part that is misleading or outdated. We will update you immediately if your personal information changes. Please note that if you do not keep your personal information accurate, complete, and up to date (including having incorrect or expired payment methods), it may result in your inability to access and use the platform and/or services.

Your Rights

1. In accordance with the personal data protection and privacy laws applicable in the countries where we operate, you have the right to request access, request a copy, request updates or corrections to your personal data that we hold. We may charge a small fee (an amount permitted under applicable law) to cover the administrative costs associated with processing your request for access to your personal data. Notwithstanding the above provisions, we reserve the right to rely on legal exemptions and/or any exceptions in the collection, use, and disclosure of your personal data.
2. In addition, you have the right to notify us in writing of the withdrawal of consent (in whole or in part) that you have previously given to us, subject to applicable legal restrictions, contractual terms, and a reasonable period for the withdrawal of consent. However, your withdrawal of consent may have certain legal consequences arising from such withdrawal. In this regard, it depends on the extent of your withdrawal of consent for the processing of your personal data, which may mean that we will not be able to continue the existing relationship with us or that the contract you have with us will need to be terminated.
3. You can edit, update, or delete your personal information at any time by modifying your profile on the "Account Settings" page on the platform. However, please note that your personal information may be retained in our backup system for a period of time. Additionally, you cannot delete information related to past transactions as we keep records of these.

C. The storage of your personal data

Any personal information you provide to us will be retained as long as the purpose for collecting that personal information remains valid. After that, your personal information will be destroyed or made unidentifiable from our records and backup systems in accordance with our data retention policy in case your personal information is no longer needed for such purposes, unless it needs to be retained further to meet longer data retention periods for our operational, legal, regulatory, tax, or accounting requirements.

Your personal data security

1. We are committed to ensuring that your personal information is kept secure to prevent unauthorized access, disclosure, or other similar risks. We strive to use appropriate technical, physical, electronic security measures, and procedures in accordance with applicable laws and regulations and industry standards to prevent and protect your personal data from unauthorized or unlawful processing, as well as accidental destruction, loss, damage, alteration, disclosure, or unauthorized access to your personal information.
2. We will periodically update our security measures reasonably and ensure that authorized third parties will use your personal information only for the purposes specified in this privacy policy.
3. The internet is not a secure medium. However, we will take various appropriate safety measures regarding your platform and electronic communications with us. All our employees and data processors who are authorized to access and are involved in processing your personal data are obligated to respect the confidentiality of your personal information.
4. Unfortunately, we cannot guarantee that data transmission over the internet or any wireless network will be 100% secure. Although we use commercially reasonable measures to protect your personal information, we cannot and do not accept responsibility for unauthorized access, illegal interception, or loss of personal data sent to or from CompAsia Co., Ltd., and we will not be liable for any actions of third parties that may receive such personal information.

Personal information from children and other individuals

1. To the extent that you have provided (or will provide) personal information about family members, spouses, other dependents (if you are an individual), directors, shareholders, employees, agents, representatives (if you are a legal entity, agency, or organization), 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 information in accordance with this privacy policy.
2. In the case of children (that is, individuals under the age of 18 or below the legal age in your country) or individuals who do not have the legal capacity to give consent, you confirm that you are the parent or legal guardian or a person responsible for their self-governance or a person appointed by the court to manage their affairs or that they have appointed you to act on their behalf to consent on their behalf to the processing (including disclosure and transfer) of their personal data in accordance with this privacy policy.

Your personal data may be transferred outside of your country.

Our data storage and information technology servers may be located in countries other than your own, which may include but are 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 entities located outside your country. Please note that these foreign entities may be located in countries that may not have a level of data protection equivalent to that offered in your country under the laws applicable in your country. You explicitly consent to us transferring your personal data outside your country for such purposes.

Reg. Internet and mobile application usage

1. You acknowledge that providing your personal information to us over the internet is at your own risk.

2. 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.

 3. If any part of the platform links you to another website, those websites do not operate under this privacy policy, and we will not be responsible for any issues arising from those websites. We recommend that you read and understand the privacy policies of those websites before you provide your personal information to them.

4. We use cookies (a string of letters and numbers that we transfer to the hard drive of your computer or mobile device so that we can recognize your web browser or mobile device, track your visits to our platform, or remember your username and/or password each time you log in) to track your usage of our platform. All demographic information collected through cookies is not personal data, and we may use this information in aggregate, statistical, and/or non-identifiable forms. You can disable cookies by changing the settings in your web browser or mobile device. However, this may mean that some features on the platform will not function properly if you set your web browser or mobile device not to accept cookies.

5. In addition to using cookies and related technologies as described above, we may also allow certain third-party companies to help us customize advertisements that we believe may be of interest to users and use other information about user activities on our platform and/or services (for example, allowing them to customize ads in third-party services). These companies may display ads that may place cookies and track user behavior in other ways.

6. Please note that when you first install our mobile application on a mobile device, 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 each time you activate our mobile application on that mobile device. This usage includes linking your personal information to your account. Most mobile platforms (iOS, Android, etc.) have different permission systems to request your consent. The iOS platform will notify you the first time our mobile application requires permission to access certain types of data and will allow you to consent (or not consent) to such requests. Android devices will inform you of the permissions that our mobile application requires before you use the mobile application for the first time, and your usage will be considered your consent.

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

8. We may automatically collect and store location service data from your computer or mobile device when you interact with us. You consent to our use of anonymized location service data collected from you. In cases where location service data can be identified, we will provide you with options to manage this disclosure, depending on the functionality available on your computer or mobile device. You may benefit from advanced options to manage location service data. Your computer or mobile device may report GPS location at the time you interact with us. If location service settings are enabled, such data will not be identified as personal information, except where we are required to do otherwise by applicable law.

The collection of your computer or mobile device location data is solely at your discretion. You can enable or disable location services at any time when using the platform through your computer or mobile device settings. If you use the platform with location services enabled, you consent to our collection and publication of your computer or mobile device location data through the platform as outlined in this privacy policy. We will not be liable for any claims or damages arising from your decision to allow other users to view your computer or mobile device location data as specified in this privacy policy.

Contact Details

If you have any questions regarding this privacy policy, or have further inquiries, or wish to make a complaint, or request access to or correction of your personal information, you can contact us at support-th@compasia.com or write to CompAsia Co., Ltd., 184/181 Forum Building, 28th Floor, Ratchadaphisek Road, Huai Khwang Subdistrict, Huai Khwang District, Bangkok 10310, Thailand.

The English version will take precedence.

 In the event of any conflict or discrepancy between the English version and other translated versions of this privacy policy, the English version shall prevail.