Similar Company Limited (“Company”), a distributor of Eminent products and after-sales services, has paid attention to your privacy, including personal information and personal information security measures. You can be confident that for the duration of your use of the service or doing business with the Company, it will supervise the collection, use, and disclosure of information relating to your personal information in order to be accurate to its purposes and laws. Therefore, the Company has established this Privacy Notice (“Notice”) to inform and explain to you the Company’s practices in relation to personal information and the reasons for the collection, use, and disclosure of your personal information, as well as the protection and duration of the collection of personal information and your rights as a personal information owner in accordance with the Personal Information Protection Act, B.E. 2562 (2019), applicable laws and rules (“Personal Data Protection Act”).
- To whom does this policy apply?
This policy applsonal information:
Types of Personal Data Owners Covered under this Policy
– The Company’s common customers (“Common Customers”) include individuals taking actions as follows:
- The persons who buy and sell Eminent products and/or uses the Company’s services.
- The persons who register the products and/or Eminent product warranty.
- The persons contacting person for after-sales service with the Company.
- The persons who contact for enquiries to the Company.
- The persons who participate in activities and/or promotional campaigns of the Company, etc.
No matter what the above person is acting through the Company’s website, application, agent or any other channels, including the person who ever established a relationship with the Company for such purposes, etc.
– Natural persons associated with the juristic person (“Juristic Persons”), such as personnel, authorized persons, key contact persons, shareholders, representatives, corporate representatives, corporate customers, service providers, suppliers, and business partners.
– Natural persons who are involved in the Company’s transactions or with whom the Company has any direct or indirect relationship, whether or not the Company has directly or indirectly acquired the personal information of such persons through any means (“General Public”), such as the following:
- Persons with whom the Company can be contacted.
- Employees, staff, officers and related persons.
- Person who receives products and /or services that the Company has delivered.
- Respondents who respond questionnaires and/or surveys to improve the Company’s business.
- Any other persons to whom the Company may receive information as a result of the transactions of customers, natural persons, and legal entities.
- Persons who visit the Company’s websites, applications and/or official accounts on social media.
- Persons who make contacts and enquiries, access to services, purchase Eminent products and/or participate in the Company’s activities through its agents or contractors, etc.
- Consultants, external auditors, speakers, etc.
- Sources of Personal Information
The Company may receive your personal information from various service channels of the Company as follows:
2.1 The Company receives personal information from you directly.
The Company will collect your personal information from the registration process for Eminent products or after-sales service, including:
- Procedures for buying–selling or implementing to buy the products and/or services, registering product warranty, contacting subscription to use the services according to service contracts with the Company, searching for information to participate in activities with the Company through the Company’s website, application, agent, official account on social media, or any other means of the Company.
- Completion of a questionnaire, feedback, service comment, or interaction by email, telephone, the Company’s official account on social media or other communication channels between the Company and you on a voluntary basis.
- Use of cookies and/or similar technologies through the Company’s website, application and official account on social media.
- Application for rights under the Personal Data Protection Law with the Company.
2.2 The Company receives your personal information from a third party.
- The Company may obtain your personal information from third parties who have the right to disclose your personal information lawfully, including companies in the Eminent group, partners, or the Company’s contractor companies, Eminent product dealers and/or service agents on behalf of the Company according to each type of service, namely a dealer, service center for repair service appointed as dealer (Authorized Service Dealer), authorized spare part dealer, contractor of repair and maintenance services for Eminent products, and/or subcontractors under various types of service contracts to be able to proceed with the purchase and sale of Eminent products and/or provide services to you on behalf of the Company. They will receive information via an application used within the organization, e-mail, telephone notification, LINE account, or documents. The disclosing parties have the right to provide personal data lawfully or to obtain information from the various service procedures carried out by the order and/or on behalf of the Company.
- Personal Information Collected, Used, and/or Disclosed by the Company
Personal information refers to information that directly or indirectly makes it possible to identify you but does not include deceased and juristic person information.
3.1 Your Personal Information as Common Customer, Juristic Person Personnel, or General Public
The Company collects various types of personal information. The collection, use, and disclosure of information varies depending on the products and/or services you use and/or your interaction with the Company. To provide you with information about all personal information we have currently collected (subject to change in the future), we group them by data type as follows:
| Type of Information | Example of Personal Information |
|---|---|
| Information for identification and documents confirming the identity from the government | – Title, first name, middle name, last name – Gender, date of birth, age – Information on important government documents, such as copies of citizen ID card/passport, driver’s license, professional license, house registration, birth certificate, change of name certificate, or any other documents that are used to identify and verify the identity in the same way. – Signature |
| Contact Information | – Contact address, current address, address according to important documents – Telephone number – Email address – Name, reference number or account for electronic communications or social media (for example, LINE ID, Account Facebook). |
| Financial Information and Work Information | – Income data, sources of income and expenditure, accounting entries or other proof of income – Taxpayer identification number and personal tax payment information – Occupation, position, job description, type of business – Information on a copy of the operating document or company certificate, such as a company certificate, shareholder list, power of attorney, commercial registration, commercial registration certificate, or VAT registration certificate (Por Por. 20) – Payment method information, payment details, payment confirmation. – Bank account number and bank account details. – Information for considering the limit for entering into a business agreement, collateral information, and documents of collateral ownership. – Other information for applying for or making a business contract, such as dealer ID, reference numbers, documents. |
| Information for Subscription and Use of Products and/or Services | – Details about the products and/or services you use, such as the type/model of products, the numbers, locations where the products are installed within your house. – Product reference number/documents – History of notifications for repairs or use of services – Location information for receiving the service. – Login information, usage activity, for example, search/browsing history. – Contact information for receiving the service. |
| Technical data, Equipment, or Tools | – Cookies ID, Cache File and/or technology of the same nature. – Application usage information. – IP Address – Device ID – Coordinate information. – Version and type of devices, network, connecting data. – Access data, including Log. – Other technical information from the use on the various platforms and operating systems. |
| Other Information | – Feedback and comments on the services. – Recordings of communications or participation in activities between you and the Company, including recordings of audio, motion pictures, chatbots, CCTV camera, information on documents necessary for the Company to establish or exercise legal claims or to comply with applicable laws and/or court orders of the Company. |
3.2 Personal Data of minors, incompetent persons, quasi-incompetent persons
Since the nature of Eminent products and/or the Company’s services does not aim or wish to transact with minor, quasi-incapable, or incompetent persons, unless the Company has obtained the consent of their parents or curators (as the case may be) to process personal data as required by the Personal Data Protection Laws.
3.3 Personal Data of Third Parties
In case you are a provider of personal information of a third party to the Company, which is a person of the legal entity and/or related to you, such as an acting authorized person, a family member, contact person and/or any other person according to documents for the application or use of the products and/or services of the Company, you must inform them about the details of this policy and ask for their consent if necessary, or comply with other legal bases before providing personal information of the third party to the Company.
- Purposes for Collection, Use, Disclosure of Personal Information
The Company collects, uses, and discloses your personal information only to the extent necessary for lawful purposes for the following purposes:
-Compliance with the contract as you are a party with the Company
- Pre-contractual actions or purchase and sale of Eminent products and/or services with the Company, such as correspondence, delivery of documents or parcels, consultation, advice and/or any other information related to products and/or services, qualification checks, verification of the status of the legal entity customers, verification of the accuracy of data or documents, verification and authentication, customer risk rankings, partners, registration to use products and services and/or to participate in the Company’s activities, and identification of personal data/contact information of customers for facilitating the Company’s next request for services (pre-fill).
- Any action for the purpose of enabling you to use Eminent products and/or services related to the Company, such as contracting the purchase and sale of products and spare parts of products, dealer application, product registration, product warranty application, service contract application, registration to use after-sales service, facilitating and providing after-sales service, processing your request, tracking compliance with the terms of use of Eminent products and/or services, termination of the service, payment, impacting the amount, actions on your interests, complaint management, problem-solving, customer relationships management, and/or management for your complimentary goods.
-Compliance with the law and/or the order of the legal authority
The Company is obliged to comply with the applicable laws and the orders of the relevant legal authorities, therefore, it is necessary to collect, use, and disclose your personal data for various purposes, including but not limited to the following purposes:
- To comply with the Personal Data Protection Laws and other applicable laws.
- To comply with other laws (such as computer offences law, electronic transactions law, consumer protection law, tax and accounting law, and other laws with which the Company is obliged to comply).
- To comply with regulations and/or orders of the competent authority (for example, court orders, orders of public authorities, or competent officials).
-Other actions of the Company under the necessity for the legitimate interest of the Company
The Company will consider collecting, using, and disclosing your personal information as necessary for the legitimate interests of the Company or third parties, with regard to our interests or those of other persons or legal entities and the fundamental rights of your personal information, including but not limited to the following purposes:
- Management, risk management and assessment, corruption, internal audit supervision of the Company
- Establishment of a database of customers, dealers, partners, or recordings of the data in the database.
- Review of the ability of dealers or partners to conduct business.
- Notification of liquidation or renewal of products and/or services, debt follow-up and collection.
- Surveys and satisfaction assessments after using products and/or services.
- Litigation or related legal proceedings.
- Cooperation, coordination, and/or delegation of tasks for others to act on behalf of the Company.
- Security for entering into the Company’s area, such as the use of CCTV, documentary evidence checks, and/or devices to monitor communicable diseases (in the absence of collection of your sensitive data).
- Management of complaints, suspicious incidents, or incidents that pose a risk of harm, including your request for permission to enter the area to handle or resolve such incidents.
- Implementation of information technology, communication system management, and prevention and reduction of information technology risks and cyber threats.
- Preservation of legitimate interests and related litigation or legal proceedings.
- Consideration of customer segments for appropriate promotion.
- Sending you news, product and/or service details, privileges of the Company’s activities or training you have attended, as well as facilitating your participation in the Company’s events, or presenting products, services and/or privileges you have requested.
- Presentation on product details, such as spare parts, parts, equipment and/or services related to the product you are using to maintain its performance in accordance with Eminent service standards, for example, repair-cleaning services for air conditioners.
- Contacts for facilitating you in case you have not successfully subscribed to a product and/or service.
- Analysis, research, preparation of statistical data, and/or preparation of reports for internal use of the Company.
- Contacts, video recordings, audio recordings of meetings, training, recreation, or booth events.
-Other actions of the Company under other legal bases (as the case may be)
- Prevention or suppression of harm to a person’s life, body, or health.
- Making historical or notarial material for the public interest or in connection with research studies or statistics.
- Implementation by a mission for the public interest of the Bank or to perform duties in the exercise of public authority conferred on the Company.
In this regard, for considering the legal bases for processing personal data for the purposes specified above, the Company will consider the nature and purpose according to the relationship between you and the Company on a case-by-case basis.
The Company is required to collect personal information in accordance with the law or to enter into a contract with you. If you choose not to provide this personal information to the Company as required, or choose to cancel your user account from the application and/or to limit your contact with the Company’s official account on social media, the Company may not be able to provide parts or all of the services to you, as well as it may affect the performance of the Company’s compliance with legal duties or the legal and/or contractual relationship between you and the Company.
In some cases, the Company may request useful personal information to enable you to make better use of our products and/or services. We will provide you with clear details when we need to request that personal information. You have the right to opt out of providing these additional details to the Company. Your decision will not affect the Eminent products you have used and/or your use of the Company’s services related to such products.
4.2 The Company collects, uses, and discloses personal information that requires your consent for the following purposes:
- The collection, use, and/or disclosure of sensitive data that the Company cannot rely on other legal bases other than to request ro4 explicit consent to process. The Company will consider seeking your explicit consent directly through its channels and/or its agents from time to time as necessary to process your sensitive data, including:
- Religious and racial information (such information is obtained by keeping a copy of the citizen ID card or passport of a specific country that the Company is required to use the documents only to prove and verify the identity of the individual. The Company does not intend to process such personal information in the form of sensitive data).
- Health history information, such as results of communicable disease examination in the form of documents, evidence, photos, and/or equipment. The Company may collect your sensitive personal data only if it is necessary for the purpose of entering the operational building or service area of the Company in accordance with the in-house risk management process for the safety of services to customers.
The Company may also consider seeking your explicit consent to collect your sensitive data for identity verification, security, or as evidence of your participation in some activities of the Company on a case-by-case basis.
- Analysis, research for developing and improving product quality and/or providing services to be more effective and meet your needs that require your consent in accordance with the law.
- Marketing operation to receive information, communications, benefits, and interesting activities of interest or special offers selected for you that require your consent in accordance with the law;
In this regard, the Company will consider requesting your direct consent through the channels and/or of its agents or contractors of the Company with whom you have legal relations and/or interactions to use its services as appropriate.
- Disclosure of Personal Information to Third Parties
The Company may disclose your personal information to others for the purposes described in this Policy with your consent and/or the rules under law permitting disclosure.
Since the Company provides services through third parties, partners, contractors, and/or dealers of the Company, which are varied according to the specialization in business, for example, distributors of Eminent products and/or agents for various services and repairs, to facilitate the provision of services or to help support the use of Eminent products and/or services of the Company, to the extent that each building and/or area in which you live, the Company may disclose your personal information to persons or entities according to the relationships and services you request. When the Company discloses your personal information to provide the services you request, you may also be subject to the personal data protection policy of the recipients of your personal information.
The Company has a list of third parties that may be recipients of your personal information according to each area in which you may purchase Eminent products and/or use its services, types of services requested, and the relationship and transactions between you and the Company. Therefore, the Company identifies as a type of organization and/or person receiving your personal information in this policy for the clarity and easy understanding, including but not limited to the types of recipients of personal information listed in the table below (in case you wish to know the list of third parties to whom the Company discloses your personal information, you can contact the Company according to the channels specified by the Company).
| Types of Recipients of Personal Data | Details |
|---|---|
| Providers of services related to the Company’s core products and/or services | • Dealer • Service centers for repair service appointed as dealers (Authorized Service Dealer) • Authorized Spare Part Dealers • Customer service agents • Eminent product repair and maintenance contractors • Contractors and/or subcontractors under the service contracts |
| Service providers supporting the Company’s services | • Technological system providers, such as Cloud Computing/Data Platform. • Marketing service providers • Service providers for goods inventory • Freight carriers, consignment of documents and parcels • Call Center service providers • Banks or service providers for payment channels, bill placement, or other financial transactions. |
| Government Agencies | In some cases, the Company is required to disclose your personal information to comply with the order of a person with authority or having legal rights and/or comply with the law. The recipients of your personal information include government agencies, law enforcement agencies, associations, agencies, or any other persons as necessary to comply with the Company’s statutory obligations, which may include any legal proceedings related to the Company. |
| Consultants/Experts | For the purpose of managing the Company’s risks and business, the Company may disclose your personal information to the following recipients of personal information: auditors, external auditors, legal counsel, tax advisors, consultants or other experts, as the case may be. |
| Any other third party to whom the Company may disclose personal information, as the case may be. | • Partners, interested persons, transferee of rights in case of merger of the Company and possession and transfer of products and/or services. • Companies in the Similar Group • Persons with whom you have a contract or a joint transaction relationship |
In this regard, the Company’s business operations mainly disclose your personal data to the recipients of personal data in Thailand. If the Company needs to send or transfer your personal data to other countries, it will comply with the applicable laws, including the duties related to the processing of your personal data with appropriate security measures and adequate personal data protection standards. However, the Company may consider implementing the Binding Corporate Rules that have been reviewed and approved by the relevant legal authority (if any) and will allow the transmission or transfer of personal information to other companies abroad under the Personal Data Protection Policy.
- Protection, Retention, and Duration of Collection of Personal Data
The Company will keep your personal data according to the technical safeguards, administrative safeguards, and physical safeguards to maintain the confidentiality, accuracy, completeness, and availability of personal data. It is as required by the Personal Data Law.
In addition, the Company has determined a retention period for your personal information following the Company’s policies, regulations, or rules for the personal information protection, which are as follows:
- Determination of the form of storage: The data is stored in the form of a book (hard copy) and an electronic system (soft copy) with effective personal information security measures to prevent the loss, access, use, alteration, alteration, or disclosure of personal information without authority.
- Incident management: The Company has procedures to deal with suspected privacy violations for complaints about violations of customer privacy and personal information.
- Storage period: The Company will store your personal data within the period necessary for the purpose of collecting that personal information, or within the period of contract or legal relationship between you and the Company, or within the period of exercising the legal claims of the parties by the prescription or the period required by law or permitted by law. The period specified by the Company is the standard period that the personal data owner may expect, or the Company has taken actions as necessary to allow the personal data owner to expect the said period.
- At the end of the storage period: At the end of the retention period of the personal data as stipulated and/or the Company does not have the right or cannot claim the basis for the processing of your personal data, the Company will delete or destroy the personal data or make it non-personally identifiable within a reasonable period or according to the practices prescribed by relevant laws.
If the Company employs others to act as processors of personal data, the Company will prepare an agreement to control and protect the personal data appropriately and under the Personal Data Protection Law.
Furthermore, the executives, officers, employees, and personal data processors of the Company are obliged to maintain the confidentiality of personal data in accordance with the confidentiality measures established by the Company.
- Rights of the Personal Data Owner
You may exercise your rights regarding your personal data under the enforcement of the Personal Data Protection Laws according to the rules and conditions set out. If you are not yet 20 years old or are restricted in your ability to take a legal action under the law, you may request the exercise of your rights by having the competent authority acting on your behalf under the law to inform the purpose as detailed below.
- Right to withdraw consent
In case you give your consent to us for any particular purpose, you may withdraw your consent at any time, except in the case of a limitation of your legal rights or the existence of a contract benefiting you. The withdrawal of your consent will not affect the collection, use, and/or disclosure of your personal data made before the withdrawal of consent.
However, withdrawing your consent in the part related and necessary for obtaining the services may affect the receipt of information about the products and/or services that may be related to the products you have used. For example, you will not receive offers of products and/or services, benefits, promotions or new offers that are in line with or meet your needs, or you will not receive useful information, advice, etc.
- Right to request access and obtain a copy of personal data
You have the right to request access to your personal information under the Company’s responsibility, including requesting the Company to make a copy of such personal information to you or requesting the Company to disclose the acquisition of your personal information.
- Right to request data portability of personal data
You have the right to obtain your personal information under the Company’s responsibility in a form that can be read or used by automated tools or devices and can be used or disclosed by automated means, or to request the Company to send or transfer it to other organizations and companies when it can be done by automated means. You also have the right to request to receive the personal information that the Company sends or transfers in such form directly to the controller of personal information. Unless it is not possible to do so due to technical reasons. The above action shall be taken to the extent required by the Personal Data Protection Law.
- Right to object to the personal data processing
You have the right to object to the processing of your personal data for certain reasons at any time, to the extent required by the Personal Data Protection Law, for example, in the case of processing your personal data for the purposes related to direct marketing.
- Right to request the erasure or destruction of personal data
You have the right to request the deletion or destruction of your personal data or to make your personal data non-personally identifiable to the extent required by the privacy protection laws, for example, if your personal data has been unlawfully processed by the Company or if the Company no longer has the legal authority to process that personal data.
- Right to request the suspension of the use of personal data
You have the right to request a temporary suspension of the use of personal data if the company is in the process of reviewing the request to exercise your right to modify your personal information or to object or any other cases that the Company considers it is unnecessary and is obligatory to delete or destroy your personal data following applicable laws. However, you need to ask the Company to keep your personal data to the extent required by personal data protection laws.
- Right to request rectification of personal data
You have the right to inform us that your personal data is inaccurate, not current, or incomplete and request to amend and improve the said personal data. The Company will investigate and amend it to be accurate, current, and complete and not cause any misunderstanding.
The Company reserves the right to exercise your rights as mentioned above, which may be limited under personal data protection laws, or the relevant laws, including some cases where there is a necessity that the Company may refuse or be unable to act upon your request to exercise any of the above rights, such as being required to comply with law or a court order. The exercise of right may have an effect that may damage the rights and freedoms of other people, or in the case of an extravagant or unreasonable request, etc.
In this regard, if the Company rejects the above request, the Company will inform you of the reason for the rejection. You can complain to the Office of Personal Data Protection and/or other competent authorities regarding personal data according to the channels announced.
- Use of Cookies and/or Similar Technologies
The Company may collect, use, and disclose cookies and similar technologies when you use its products and/or services, including accessing its website, application, and official accounts on social media for the following purposes:
- Process the website, application, or official account of the Company on social media.
- Protect users from online threats and continue to improve the security of the channel.
- Survey comments from visitors to the Company’s website, application, or official account on social media to improve its services through such channels.
- Consider customer segments for appropriate promotion.
- Improve the visibility of the Company’s media on the social media you use.
- You can opt out of the data collection via cookies through your cookie and/or browser settings. Such settings may reduce the maximum effectiveness of your use of the website, application, or interaction and the use of the Company’s official accounts on social media.
- Collection and Use of Personal Data for its Original Purpose
The Company will process personal data in accordance with the laws currently in force. The Company has the right to collect and use personal data that the Company collects before the effective date of the personal data protection law in relation to the collection, use, and disclosure of personal data with the same purposes. If you do not wish the Company to collect and use such personal data further after the personal data protection law applies, you can notify the cancellation of consent according to the channels that the Company will publicize later.
- Amendments and Changes to the Policy
The Company will review this policy as appropriate to comply with guidelines, applicable laws, and regulations. If this policy is amended, improved, or changed, the Company will make an announcement of the current policy to you through the Company’s website or any other means of communication with the Company relating to your use of the products and/or services.
- Contacting the Company
If you wish to inquire about the details of the processing of your personal data and exercise your rights under this policy, you may contact the the Company’s Privacy Protection Officer
via email: dpo@eminent.co.th
Contact Location: Similar Company Limited (Headquarters)
235 Lasalle Road, Bangna Tai Subdistrict, Bangna, Bangkok 10260
