Similar Co., Ltd. (“Company”) operates in the business of selling Eminent products and providing after-sales services. The Company prioritizes your privacy, including personal data protection and security measures, ensuring that throughout your use of services or business dealings with the Company, your personal data will be collected, used, and disclosed in compliance with applicable purposes and laws. Therefore, the Company has established this Privacy Policy (“Policy”) to inform and explain its practices regarding personal data collection, use, and disclosure, as well as protection measures, retention period, and your rights as a data subject under the Personal Data Protection Act B.E. 2562 (2019) and other applicable data protection laws (“Data Protection Laws”).

1. Who This Policy Applies To

This policy applies to your personal data collected, used, and disclosed by the Company when you are classified as one or more of the following data subjects:

Types of data subjects covered under this policy:

– Individual customers of the Company (“Individual Customers”), including those who:

• Purchase or sell Eminent products and/or use the Company’s services
• Register products and/or Eminent product warranties
• Request after-sales services from the Company
• Contact the Company for inquiries
• Participate in various events and/or promotional campaigns of the Company

This applies regardless of whether these activities occur through the Company’s website, applications, representatives, or other channels, including individuals who have had prior relationships with the Company for such purposes.

– Individuals associated with a legal entity (“Corporate Personnel”), including employees, designated contacts, shareholders, representatives, or authorized persons of corporate customers, service providers, suppliers, and business partners.

– Individuals involved in transactions with the Company or who have any relationship with the Company, whether the personal data was obtained directly or indirectly through any channel (“General Individuals”), including:

• Persons the Company may contact
• Employees, staff, and related personnel
• Recipients of products and/or services delivered by the Company
• Individuals responding to surveys or questionnaires for the Company’s business development
• Other individuals whose data the Company may receive due to transactions with individual customers and corporate personnel
• Visitors to the Company’s website, applications, and/or official social media accounts
• Individuals who contact, inquire, use services, purchase Eminent products, and/or participate in the Company’s activities through representatives or contractors
• Consultants, external auditors, lecturers, etc.

2. Sources of Personal Data

The Company may receive your personal data from various service channels as follows:

2.1 When the Company receives your personal data directly from you

The Company will collect your personal data from the process of registering for Eminent products or after-sales services, including:

• The buying-selling process or actions to purchase products and/or services, registering for product warranties, contacting, subscribing to service agreements with the Company, searching for information, and participating in activities with the Company through the website, application, agents, official social media accounts, or other channels of the Company.
• Surveys, feedback, service reviews, or communications via email, phone, the Company’s official social media accounts, or other communication channels with the Company, based on your voluntary consent.
• The use of cookies and/or similar technologies through the website, application, and the Company’s official social media accounts.
• Submitting a request to exercise rights under personal data protection laws with the Company.

2.2 When the Company receives your personal data from third parties

• The Company may receive your personal data from third parties who have the legal right to disclose your data, including companies within the Eminent group, business partners, individuals or companies acting on behalf of the Company, authorized distributors, and/or service providers representing the Company for specific services. This data may be received through internal organizational applications, emails, phone notifications, Line accounts, documents authorized for disclosure, or service processes carried out under the Company’s orders and/or on its behalf.

3. Personal Data Collected, Used, and/or Disclosed by the Company

Personal data refers to information that allows the identification of your person, either directly or indirectly, but excluding information of deceased individuals and data of legal entities.

3.1 Personal Data of Individual Customers, Corporate Personnel, or General Public

The Company collects various types of personal data. The collection, use, and disclosure may vary depending on the products and/or services you use and/or have interacted with the Company. To keep you informed of all the personal data we currently collect (which may change in the future), we categorize the data as follows:

3.2 Personal Data of Minors, Incompetent Persons, and Persons Similar to Incompetent Persons

Due to the nature of Eminent’s products and/or services, the company does not intend or wish to conduct transactions with minors, incompetent persons, or persons similar to incompetent persons unless the company has obtained consent from the legal guardian, custodian, or protector (as the case may be) to process the personal data as required by the Personal Data Protection Law.

3.3 Personal Data of Third Parties

In the event that you provide the personal data of third parties to the company, such as employees of a legal entity and/or those associated with you, such as an authorized representative, family members, contact persons, and/or others as part of the registration or use of the company’s products and/or services, please notify those individuals about the details of this policy and seek their consent if necessary, or comply with other legal bases before providing third-party personal data to the company.

4. Purpose of Collecting, Using, and Disclosing Personal Data

4.1 The company collects, uses, and discloses your personal data as necessary within the legal purposes for the following purposes:

– To fulfill the contract in which you are a party with the company

• To perform actions before entering into a contract or buying/selling Eminent products and/or services with the company, such as communication, sending documents or parcels, providing consultation, advice, and/or other information related to products and/or services, checking qualifications, verifying customer status, verifying the accuracy of data or documents, verifying and confirming the identity of individuals, evaluating partner risk levels, registering to use products or services, and/or participating in company activities, identifying personal/contact information to facilitate service requests in the future (pre-fill), etc.
• To perform any action to enable you to use Eminent products and/or related services, such as executing a product purchase contract, including product spare parts, registering as an agent, registering the product, registering product warranty, signing service contracts, registering for after-sales service, facilitating and providing after-sales service, fulfilling your requests, monitoring the compliance with product terms, providing services, service cancellations, payments, settlements, ensuring benefits, managing complaints, resolving issues, managing customer relationships, and/or managing rewards for you, etc.

– To comply with the law and/or orders from legal authorities

The company has an obligation to comply with applicable laws and orders from legal authorities. Therefore, the company is required to collect, use, and disclose your personal data for various purposes, which include, but are not limited to, the following:

• To comply with the Personal Data Protection Law and other relevant laws
• To comply with other laws (e.g., the Computer Crime Act, Electronic Transactions Act, Consumer Protection Act, Taxation and Accounting Laws, and other laws the company is obligated to comply with)
• To comply with regulations and/or orders from legal authorities (e.g., court orders, government agency orders, or orders from authorized officers)

– Other actions of the company based on legitimate legal interests

The company will consider collecting, using, and disclosing your personal data as necessary based on legitimate legal interests of the company or external parties, taking into account our interests or the interests of other individuals or legal entities, while considering your fundamental rights regarding personal data. These purposes include, but are not limited to, the following:

• Risk management, fraud detection, internal company audits
• Creating customer, agent, or partner databases or recording data into systems or databases
• Reviewing the business capabilities of agents or partners
• Sending reminders for debt payments or product/service renewals, or debt collection
• Conducting satisfaction surveys after using products and/or services
• Engaging in legal proceedings or relevant legal processes
• Collaborating, coordinating, and/or delegating tasks to third parties on behalf of the company
• Ensuring security in company premises, such as using CCTV, inspecting documents, evidence, and/or health inspection devices (in case no sensitive data is collected)
• Managing complaints, suspicious incidents, or events posing risks or potential harm, including requesting permission to access your premises to manage or resolve such incidents
• Managing IT systems, communication systems, and mitigating cyber threats and technology-related risks
• Protecting legal interests and engaging in legal proceedings or relevant legal processes
• Assessing customer groups for targeted promotions
• Sending news, product details, and/or service benefits of company activities or training events that you have attended, as well as facilitating participation in such activities or offering products, services, and/or benefits requested by you
• Offering product-related details, such as spare parts, components, equipment, and/or services related to products you use, to maintain product performance according to company service standards (e.g., air conditioner repair and cleaning services)
• Contacting you if you have not successfully registered for products and/or services, to facilitate your process
• Conducting statistical analysis, research, and/or creating internal reports for company use
• Recording meetings, training, leisure activities, or booth events

– Other actions of the company based on other legal bases (as the case may be)

• Protecting or preventing harm to life, body, or health
• Creating historical documents or archives for public benefit or research/statistical purposes
• Engaging in public benefit missions or exercising state powers delegated to the company

In this regard, when considering the legal basis for processing personal data for the purposes outlined above, the company will consider the nature of the purpose based on the relationship between you and the company on a case-by-case basis.

The company is required to collect personal data under the law or for contracts you have with the company. If you choose not to provide this personal data to the company as specified, or choose to cancel your user account from the application and/or limit the communication with the company’s official account on social media, the company may not be able to provide some or all of its services to you, and it may also affect the company’s legal obligations or the relationship, legal actions, and/or contracts between you and the company.

In some cases, the company may request personal data that is useful to enable you to use our products and/or services more effectively. We will specify clear details when we need to request such personal data. You have the right to choose not to provide this additional information to the company, and your decision will not affect your use of Eminent products and/or services related to such products.

4.2 The company collects, uses, and discloses personal data that requires your consent for the following purposes:

• The collection, use, and/or disclosure of sensitive personal data (Sensitive Data) that the company cannot rely on other legal bases besides obtaining explicit consent for processing. The company will consider directly requesting your explicit consent through various channels of the company and/or the company’s agents as needed to process your sensitive personal data, which includes:

1. Religious and ethnic data (This information is obtained from the collection of copies of ID cards or passports from certain countries, which the company needs as documentation to verify and confirm identity only. The company does not intend to process such data as sensitive personal data.)
2. Health history data, such as the results of communicable disease tests in the form of documents, evidence, photos, and/or equipment. The company may collect your sensitive personal data only when necessary for entering company buildings or service areas, as part of internal risk management procedures to ensure safety when providing services to customers.

The company may consider requesting your explicit consent to collect your sensitive personal data for the purpose of identity verification, security measures, or as evidence for participation in certain company activities on a case-by-case basis.

• Analysis and research for product development and improving service quality to meet your needs more effectively, which requires your consent under the law.
• Marketing activities to receive information, communication, benefits, and interesting activities or special offers tailored for you, which requires your consent under the law.

In this regard, the company will consider directly requesting your consent through various company channels and/or agents or contractors of the company with whom you have a legal relationship and/or interaction to use the company’s services, as appropriate.

5. Disclosure of Personal Data to Third Parties

The company may disclose your personal data to others for purposes as outlined in this policy, based on your consent and/or as permitted by law.

Since the company provides services through external parties, partners, contractors, and/or agents with expertise in various business areas, such as authorized distributors of Eminent products and/or service and repair agents, etc., to facilitate the provision of services or to assist in the use of Eminent products and/or services within your residence or area, the company may disclose your personal data to individuals or organizations depending on the relationship and services requested. When the company discloses your personal data to provide services as requested, you may be subject to the personal data protection policies of the recipients of your personal data.

The company has a list of external parties that may receive your personal data, depending on the area where you purchase Eminent products and/or use the company’s services, the type of service requested, and the relationship and transactions between you and the company. Therefore, the company outlines the types of organizations and/or individuals who may receive your personal data in this policy for clarity and ease of understanding, which includes, but is not limited to, the types of recipients listed in the table below. (If you wish to know the list of external parties to whom the company discloses your personal data, you can contact the company through the channels specified by the company.)

In this regard, the company’s business operations mostly involve disclosing your personal information to recipients in Thailand. However, if the company needs to send or transfer your personal data to other countries, the company will comply with applicable laws, including obligations related to the processing of your personal data, with appropriate security measures and sufficient data protection standards. However, the company may consider using the Binding Corporate Rules policy, which has been verified and certified by the relevant legal authorities (if any), and may transfer your personal data to other companies within the group located abroad in accordance with such data protection policies.

6. Protection, Retention, and Duration of Personal Data Collection

The company will retain your personal data in accordance with technical safeguards, administrative safeguards, and physical safeguards to maintain the confidentiality, accuracy, and availability of personal data, in compliance with personal data protection laws.

Additionally, the company has set retention periods for your personal data as per the company’s policies, regulations, or data protection guidelines, as follows:

• Storage Characteristics: Personal data is stored in hard copy (paper) and electronically (soft copy), with effective security measures to prevent the loss, unauthorized access, use, alteration, or disclosure of personal data.
• Incident Management: The company has procedures in place to handle suspected personal data breaches in the event of complaints related to privacy violations and personal data breaches.
• Retention Period: The company will collect your personal data for as long as necessary for the purpose for which the data was collected, or within the time period specified in a contract or legal relationship between you and the company, or within the period for exercising legal claims as defined by the law. The retention period is also in line with legal retention requirements. The company establishes a retention period that individuals can reasonably expect, or which is necessary for the purpose.
• Post-Retention: After the defined retention period, and/or when the company no longer has the right or cannot justify the processing of your personal data, the company will delete or destroy your personal data or anonymize it within a reasonable time, or in accordance with applicable laws.

In the event the company hires others to process your personal data, the company will ensure that appropriate agreements are in place to protect personal data in compliance with applicable personal data protection laws.

Furthermore, the company’s executives, employees, agents, and data processors have a duty to maintain the confidentiality of personal data in accordance with the confidentiality measures established by the company.

7. Rights of Personal Data Subjects

You can exercise various rights related to your personal data under the applicable personal data protection laws, in accordance with the specified criteria and conditions. If you are under the age of 20 or have limited legal capacity, a legal representative may act on your behalf as detailed below.

• Right to Withdraw Consent

If you have given consent to us for a specific purpose, you may withdraw that consent at any time, unless restricted by law or a contract that benefits you. Withdrawing consent will not affect the collection, use, and/or disclosure of your personal data that was done before the withdrawal.

However, withdrawing consent in connection with services may affect your ability to receive information related to products and/or services, offers, benefits, promotions, or new offers tailored to your needs, or news and recommendations that would benefit you.

• Right to Access and Request Copies of Personal Data

You have the right to access your personal data under the company’s responsibility, including requesting copies of the data or requesting the company to disclose how the personal data was obtained.

• Right to Data Portability

You have the right to request your personal data in a format that is readable or usable by automated tools or devices, and to transfer or disclose it to other organizations or companies in an automated manner, provided that it is technically feasible. The company may transfer or disclose your personal data to other personal data controllers directly unless technical limitations prevent it. This action must be in accordance with the scope defined by personal data protection laws.

• Right to Object to Processing of Personal Data

You have the right to object to the processing of your personal data for certain reasons at any time, as defined by the applicable personal data protection laws, such as for direct marketing purposes.

• Right to Deletion or Destruction of Personal Data

You have the right to request the deletion or destruction of your personal data, or to anonymize it in a way that no longer identifies you, in cases where the data has been processed unlawfully or where the company no longer has the legal authority to process your personal data.

• Right to Suspend Processing of Personal Data

You have the right to request the temporary suspension of processing your personal data while the company investigates your requests for data correction or objection. This is applicable in cases where the company no longer requires the data and needs to delete or destroy it, but you have a legitimate need to request its retention under personal data protection laws.

• Right to Correct Personal Data

You have the right to inform us if your personal information is incorrect, outdated, or incomplete, and request to have your personal data corrected or updated. The company will review and make the necessary corrections to ensure the information is accurate, current, and complete, and does not cause any misunderstanding.

The company reserves the right to limit your rights mentioned above, which may be restricted under the personal data protection laws or related regulations. In some cases, there may be necessary reasons that the company may refuse or be unable to process your request for the above rights, such as complying with laws or court orders, the exercise of rights may negatively affect the rights and freedoms of others, or the request is excessive or unreasonable, etc.

If the company denies the request above, the company will notify you of the reason for the denial. You can file a complaint with the Personal Data Protection Office and/or other authorities responsible for personal data supervision through the specified channels.

8. Use of Cookies and/or Similar Technologies

The company may collect, use, and disclose cookies and similar technologies when you use the company’s products and/or services, including when you access the website, applications, or official accounts on social media platforms, for the following purposes:

• Processing of the website, application, or official accounts on social media
• Protecting users from online threats and improving security of those platforms
• Studying how visitors interact with the website, application, or official accounts on social media to develop and improve services offered through these platforms
• Consideration of customer segments for appropriate promotions
• Improving the visibility of the company’s content on social media platforms you use
• You can refuse to collect information through cookies by adjusting cookie settings and/or your browser settings. However, such settings may reduce the maximum efficiency of using the website, application, or interaction through the company’s official accounts on social media.

9. Collection and Use of Personal Data for Original Purposes

The company will process personal data according to the applicable laws currently in force. The company has the right to continue collecting and using personal data collected before the enforcement of the Personal Data Protection Act for its original purposes. If you do not wish to allow the company to continue collecting and using such personal data after the Personal Data Protection Act becomes effective, you may cancel your consent through the channels the company will announce.

10. Policy Amendment

The company will review this policy as appropriate to align with practices, laws, and regulations. In the event of any changes, amendments, or updates to this policy, the company will announce the current policy on the company’s website or through other relevant channels concerning the use of your products and/or services.

11. Contacting the Company

If you have any questions regarding the details of how your personal data is processed or wish to exercise your rights under this policy, you can contact the company’s Personal Data Protection Officer via email at dpo@eminent.co.th

Contact address: Similar Company Limited (Head Office)

235 Lasalle Road, Bangna Tai Sub-district, Bangna District, Bangkok 10260