Privacy Policy

Privacy Policy

1. Scope and Purpose of the Privacy Policy

This document is the Privacy Policy for users of our platform. We act as a data controller under the Personal Data Protection Act. This Privacy Policy explains how we collect and use your personal data according to our scope and purposes.

Data Controller Contact Details

Playtorium Solutions Public Company Limited
1025 Yakult Building, 15th Floor, Phahonyothin Road, Phayathai Sub-district, Phayathai District, Bangkok 10400
Phone: +66(0)61-714-4549
Email: contact@playtorium.co.th

Data Protection Officer Contact Details

Phone: +66(0)61-714-4549
Email: dpo@playtorium.co.th

Under this Privacy Policy, the following terms shall have the meanings specified below:

  • “Processing” means any operation performed on your personal data, including collection, use, storage, disclosure, and deletion of personal data
  • “Legal Basis for Processing” means the legal necessity for processing personal data under Sections 24 and 26 of the Personal Data Protection Act

This Privacy Policy may be reviewed and updated at any time, and we will notify you through appropriate communication channels.

2. What Personal Data Do We Collect?

We collect the following personal data from you:

  • Identity data such as name-surname, taxpayer identification number, and signature
  • Address or contact information such as phone number, email, address, and Line ID
  • Employment information such as company/legal entity name and position
  • Transaction data such as date and time

3. How Do We Collect Personal Data?

Generally, we collect personal data directly from you through various processes or channels such as phone, email, or social media such as Line or Facebook.

However, we may collect additional information from external agencies, including:

  • Government agencies such as the Department of Business Development
  • Commercial banks such as Kasikorn Bank Public Company Limited
  • Accounting service providers such as P U U N Intelligent Company Limited

4. How Do We Use Personal Data?

We use your personal data to carry out all operations according to our purposes, which can be divided into the following activity groups:

Contract-Related Operations [ROP ID: AC01]

  • Identity data
  • Address or contact information
  • Employment information
  • Contractual basis

Accounting Operations [ROP ID: AC02, AC03, AC07]

  • Identity data
  • Address or contact information
  • Employment information
  • Legal obligation basis
  • Contractual basis

Marketing and Customer Relationship Management [ROP ID: MK03, MK07]

  • Identity data
  • Address or contact information
  • Employment information
  • Legitimate interest basis
  • Consent basis

Coordination [ROP ID: MK06]

  • Identity data
  • Address or contact information
  • Employment information
  • Contractual basis

Customer Data Storage [ROP ID: SA01]

  • Identity data
  • Address or contact information
  • Employment information
  • Transaction data
  • Contractual basis

We will process your personal data only for the purposes stated. However, if we need to process your data for other purposes unrelated to the original purpose and such processing cannot rely on other legal bases, we will request new consent to use your data for that new purpose.

If you are unable to provide personal data that is necessary for us to provide products or services to you or to comply with laws or contracts, this may result in us being unable to provide such products or services to you and may affect compliance with any laws that we or you are obligated to follow.

5. Sharing Personal Data with External Parties

We may need to send and/or disclose your personal data to the following external parties to enable them to process data according to their contractual responsibilities with us and/or legal obligations:

  • Government agencies such as the Revenue Department
  • Accounting service providers such as accounting firms

However, when disclosing and/or sending personal data to external parties, we will act only as necessary, disclosing and/or sending minimal data, and may consider using anonymization and pseudonymization methods for greater data security. Additionally, external parties that process personal data for us must have appropriate personal data protection policies, and we will not allow such external parties to use your data for purposes other than those we have specified.

6. Transfer of Data to Foreign Countries

Under the scope and purposes of processing according to this Privacy Policy, we currently have no need to send or transfer your personal data to data recipients located in foreign countries.

Nevertheless, in the event that your personal data is sent or transferred to a foreign country, we will send or transfer your personal data to a foreign country only when one of the following conditions is met:

  • The destination country receiving the data has been determined by the Personal Data Protection Committee to have adequate personal data protection
  • The foreign agency receiving the data is under a personal data protection policy that has been reviewed and certified by the Office of the Personal Data Protection Committee
  • The foreign agency has provided appropriate personal data protection measures that can enforce the rights of data subjects, including effective legal remedies according to the rules and procedures announced by the Personal Data Protection Committee, such as standard contracts and codes of conduct
  • It is necessary for the exercise of legal rights
  • You have given consent after being informed of the inadequate personal data protection standards of the destination country or international organization receiving the personal data
  • It is necessary for the performance of a contract to which you are a party or for taking steps at your request prior to entering into the contract
  • It is an action under a contract between us and another person or legal entity for your benefit
  • To prevent or suppress danger to a person's life, body, or health when such person cannot give consent at that time
  • It is necessary for carrying out tasks for important public interests

7. Security of Personal Data

We have implemented security measures for your personal data. Additionally, external parties that process personal data for us must follow our security measures and must agree to maintain the security of your personal data.

8. Personal Data Retention Period

We will retain your personal data for as long as necessary to carry out our purposes, including various necessary tasks such as legal operations, accounting, and various auditing activities.

9. Rights of Data Subjects

You have the following rights regarding personal data:

Right to Revoke Consent

In cases where we request your consent to process your personal data

Right of Access

You can request a copy of your data and verify whether we have processed your data in accordance with the law

Right to Data Portability

In cases where we have provided a platform that allows you to access personal data through automated means

  • You can request to send or transfer your personal data to other agencies through automated means
  • You can receive personal data that we send or transfer to other agencies directly, unless technically not feasible

Right to Object

You can object in cases where we process your data based on the following legal bases and/or purposes:

  • Based on legitimate interest
  • For direct marketing purposes

Right to Erasure

You can request deletion, destruction, or anonymization of personal data in the following cases:

  • When there is no longer a need to process personal data
  • When you withdraw consent to process personal data and we have no legal grounds to continue processing such personal data
  • When you have objected to the processing of your personal data
  • When personal data has been processed unlawfully

Right to Restrict Processing

You can request to restrict the use of your personal data in the following cases:

  • During verification when you request correction of personal data
  • When personal data should be deleted or destroyed, but you request restriction of use instead
  • When personal data is no longer necessary to retain for the stated purpose, but you need to retain it for establishing legal claims, compliance with or exercising legal claims, or defending against legal claims
  • During verification or examination following your request to exercise the right to object

Right to Rectification

You can request correction of your data to be accurate, complete, and up-to-date if you find that your data is inaccurate, incomplete, and not up-to-date, and we cannot verify and correct such data ourselves

In some cases, due to operational conditions, we may not be able to comply with your request, such as during legal proceedings. However, if you have given consent for processing personal data, you can withdraw that consent at any time by contacting the relevant department. We will cease processing such data as soon as possible. The withdrawal of consent will apply to future processing but will not cancel or revoke personal data processing that has already been carried out.

Please be aware that we will record various actions taken regarding your requests for use in resolving any issues that arise. If you have questions about the practical details of personal data protection operations and your rights, you may study the Personal Data Protection Guidelines (TDPG3.0 Extension) at https://www.law.chula.ac.th/wp-content/uploads/2021/04/TDPG3.0-Extension-20210413-1.pdf

If you wish to exercise the above rights or have complaints about personal data processing, please contact our Data Protection Officer at the details provided above. We will promptly process your request in accordance with legal requirements. However, you have the right to file a complaint about non-compliance with personal data protection laws with the Office of the Personal Data Protection Committee via email at saraban@pdpc.or.th using the complaint form prescribed by the Personal Data Protection Committee.

10. Review and Update of This Policy

This document is the Privacy Policy for users of our platform, last updated on July 31, 2024. We reserve the right to review and update this policy as deemed appropriate and will notify you of any changes to this Privacy Policy.