LEGAL

The Creators HQ Co., Ltd.‍

The Creators HQ Co., Ltd. recognizes the importance and strictly adheres to the rights and privacy of your personal data as a data subject. When we use your personal data in conducting our business and providing services to you, your personal data will be protected in accordance with the Personal Data Protection Act B.E. 2562 (2019).As your data controller, we have a strict duty to inform you of the privacy policy for personal data subjects, which explains the collection, use, or disclosure of your personal data and your rights as a data subject. We also confirm that we have strictly complied with this law to protect your personal data.

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Personal data is divided into two categories:

Personal Data (General)
It refers to personal data of a living person that can identify that person, directly or indirectly, such as name, surname, address, email address, and citizen identification number.

Sensitive Personal Data
It refers to personal data that requires special protection and needs extra caution in its collection, use, or disclosure. Examples include personal data concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, sexual behavior, criminal records, health data, disability, trade union information, genetic data, and biometric data.

01 Definition of Personal Data
Personal data is divided into two categories:

02 Personal Data We Collect From You
We collect your data when:

You visit our website.
You provide information to us via our website or application.
You provide information to us through inquiries made via our online or conventional channels.

We collect your personal data only as necessary to provide services to you, to allow you to inquire for information, and to conduct business in a way that you would reasonably expect us to use your personal data for that purpose.

We may collect, use, or disclose various types of your personal data, which can be grouped as follows:

Communication Data

Used to store data such as email, conversation records, and communication data.

Contact Data

Used to store data such as name-surname, address, email, telephone number, projects you are interested in, parts of the announcement for purchasing tickets, the reasons for your purchase provided to us.

Technical Data

Used to store data such as the computer's IP Address, browser type, time zone setting, location, operating system, platform, and technology of the device used to access the website.

Usage Data

Used to store data such as the most frequent pages/actions you visit or perform on the platform, website pages you view, the amount of time you spend viewing pages, products or information you search for on the platform, time and date of website access, data entered into website forms.

Contract – related Data

Used to store data such as citizen identification number, address, credit card number, date of birth, gender.

03 Sources of Personal Data
We obtain personal data directly from you through the following channels:

You register by creating an account via the website or application.
You contact us to request information about the residential project you are interested in.
You make an appointment to visit the residential project.
You provide us with information when you visit the residential project.
You participate in our promotional activities through electronic channels, Social Networks, or conventional channels.

Your personal data that we receive from a third party (Third Party) who collects, uses, or discloses personal data based on our instructions or on our behalf. Your personal data will not be used beyond the purposes we have specified or instructed, and we have stipulated that the third party must maintain the confidentiality and protect your personal data according to the standards of Thailand's Personal Data Protection law.

We may collect, use, or disclose various types of your personal data, which can be grouped as follows:Personal data obtained from cookies when you visit our website. This data enables us to provide a better, faster, safer, and more personalized service when you use the service and/or access the platform.

04 Purposes of Collecting, Using, and Disclosing Personal Data
We obtain personal data directly from you through the following channels:We use your personal data within the scope of data protection laws and collect only the data necessary for such operations. We will only store data related to the provision of services between you and us that is necessary:

For our Legitimate Interests or the legitimate interests of a third party, or your legitimate interests, provided that your fundamental rights in your personal data are not overridden.
To perform a contract to which you are a party, or to take steps at your request before entering into a contract.
For us to comply with the law, or to prevent or suppress danger to a person's life, body, or health.

We have summarized the use of your personal data in providing services to you, along with an explanation of the Lawful Basis of Processing that we use to process your personal data in each activity, as shown in the table below:

Purpose

Data Type

Lawful Basis of Processing

1) To provide services related to projects you are interested in.

- Contact Data
- Communication Data

1) To perform a contract to provide services.
2) For our legitimate interests in providing information about projects you are interested in.

2) To build and maintain good customer relations (Customer Relations) through marketing activities and sales promotion.

- Contact Data
- Communication Data

1) To perform a contract.
2) For our legitimate interests in carrying out marketing activities and sales promotion, following up on customer satisfaction and collecting feedback to improve our services.

3) To track financial activities, develop our business, and solve potential problems in service usage efficiently.

- Contact Data
- Transaction Data

For our legitimate interests in auditing and tracking financial activities and using data to develop our services for better efficiency.

4) To analyze and develop our website and platform to meet customer needs and improve service quality.

- Transaction Data
- Usage Data

For our legitimate interests in developing our website, knowing customer trends, service usage patterns, and improving the design of our website and applications to better meet customer needs.

5) For contracts related to buying and selling goods.

- Contact Data
- Data related to the contract

To perform a contract.

6) To give and receive consent for financial transactions.

- Contact Data

To perform a contract related to financial transactions.

7) To send direct marketing regarding residential or other projects you are interested in (only with your explicit consent).

- Contact Data

We rely on consent for sending direct marketing information about residential or other projects you are interested in.

8) To manage and transmit your personal data to subsidiaries, joint ventures, joint capital ventures, or companies in the same group, such as Company A, Company B, and Company C, which are companies in our group, for the purpose of staff management and data transmission for projects and as part of our structure to provide personnel management and data transmission services through the Smart World Application and other related services for residents and homeowners.

- Contact Data- Communication Data

To perform a contract to provide personnel management and data transmission services to subsidiaries, joint ventures, joint capital ventures, or companies in the same group, such as Company A, Company B, and Company C, which are companies in our group, for the purpose of staff management and data transmission for projects and as part of our structure to provide personnel management and data transmission services through the Smart World Application and other related services for residents and homeowners.

We may rely on more than one Lawful Basis of Processing when processing your personal data, depending on the purpose of each of our activities that use your personal data.

05 Disclosure or Sharing of Personal Data
1. We may disclose or share your personal data with the following third parties:

Affiliated companies
Online advertising platforms
Marketing companies or consultants
Regulatory authorities, such as the Office of the Personal Data Protection Commission
Business or professional advisors

We require the aforementioned third parties with whom we disclose or share your personal data to maintain confidentiality and protect your personal data according to the standards set by Thailand's Personal Data Protection law, and to use your personal data only for the purposes we have specified or instructed them to carry out. The third party will not be able to use your personal data beyond these specified purposes

2. Upon request, we may disclose your personal data to relevant authorities to comply with the law, such as to prevent threats to life or body, for the purposes of law enforcement, prosecution, exercising legal rights, and fraud prevention

06 Retention and Period for Retaining Personal Data
We store your personal data in our information systems and provide standard security measures to ensure the safety of our information systems and the use of your personal data, with the following measures:

Restricting access to personal data which may be accessed by employees, agents, partners, or third parties. Access to personal data by third parties is only allowed as specified or instructed, and these third parties must have a duty to maintain confidentiality and protect personal data.
Implementing technological methods to prevent unauthorized access to computer systems.
Managing the destruction of your personal data for safety when such data is no longer necessary for legal and business purposes.
Having procedures to deal with personal data breaches or suspected breaches, and must notify the Office of the Personal Data Protection Commission of the breach according to the conditions stipulated by law.

Period for Retaining Personal Data
We retain your personal data for the period necessary to carry out the purposes of our service provision, and in accordance with the period specified by accounting standards, legal standards, and other relevant regulations.In determining the data retention period, we will consider the volume, nature of use, purpose of service provision, sensitivity of the personal data, the potential risks arising from unauthorized use of personal data, and the period specified by relevant laws.Personal data obtained from Cookies during your visit to our website will be retained for no more than 13 months or as specified by relevant laws.

07 Rights of the Data Subject
As a data subject, you have the right to proceed within the scope permitted by law, as follows:

You have the Right to withdraw Consent in the processing of your personal data that you have given consent to us, throughout the period your personal data is with us.
You have the Right of Access to your personal data and can request us to make a copy of such personal data for you, including requesting us to disclose the acquisition of personal data that you did not give consent to us.
You have the right to request us to correct your personal data or supplement incomplete data (Right to Rectification).
You have the Right to Erasure (request us to delete your data) for certain reasons.
You have the right to request us to suspend the use of your personal data for certain reasons (Right to Restriction of Processing).
You have the Right to Data Portability (request to transfer personal data you provided to us to another data controller or to yourself) for certain reasons.
You have the Right to Object to the processing of your data for certain reasons.
You can contact the DPO/Company staff to submit a request to exercise the above rights.

08 Marketing Activities and Sales Promotion
We may carry out marketing and sales promotion activities, or have third parties we have stipulated or instructed to do so, in the following cases:

In the case where we use your personal data for Direct Marketing to you, we will only proceed if you have given us explicit consent, and we have informed you of the purpose of using your data for that direct marketing. You can revoke your consent for direct marketing at any time through our data opt-out system.
In the case of participating in the company's sales promotion activities, such as gaming activities or activities on various Social Network channels to publicize our products and services to the public, we will not process your data for Direct Marketing, unless you explicitly consent to allow us to use personal data for direct marketing. We will inform you of the purpose of using your data for direct marketing, and you can revoke your consent for direct marketing at any time through our data opt-out system.

09 Cookies Policy
The Creators HQ Co., Ltd. respects the right to privacy of visitors or users of the website and may use cookies or other similar technologies on our website or application to help you gain a better experience from using the services and enable us to further develop the quality of our services to better meet your needs. Your information will be properly protected.

The Creators HQ Co., Ltd. hereby announces this Cookies Policy ("Cookies Policy") for this website.

Cookies are small data files that are downloaded and stored on your device when you visit a website. Cookies are then sent back to the original website each time you visit that website, or sent to other websites that recognize that cookie. Cookies are useful in helping the website remember your device and provide services that are more suitable for you.We use Cookies to store information about your website visits to help us provide better, faster, safer, and more personalized services when you use our website. We use Cookies in the following cases:

Strictly Necessary Cookies: This type of cookie is essential for the website to function, including cookies that enable you to securely access information and use our website.
Functional Cookies: We use this type of cookie to help remember your device or browser so that we can create content more quickly to suit your personal interests, and to make the services and platform more convenient and beneficial to you.
Targeting Cookies: We use this type of cookie to remember your settings when accessing web pages, the web pages you have visited, and the links you have followed, in order to collect information about how you access and behave while visiting the website, and to improve the website, as well as any content that appears on the page, to better match your interests. We also test the effectiveness of our advertisements and present the advertisements most appropriate to you as necessary. Furthermore, we may share this information with third parties for the aforementioned purposes.
Statistic Cookies: We use Analytics Cookies provided by Google, which are intended to store insights about your usage patterns on our website. This information includes the web pages you visit, the links you click, and the duration you spend on each page. We use this data to analyze user usage patterns and ensure the website functions correctly.

By using our website, you acknowledge that we will use various types of cookies for the purposes specified above, and we may collect, use, or disclose your personal data, which is considered a part of such cookies, for the purposes specified in our Privacy Policy.

If our website links to third-party websites, please note that those parties may have their own cookies policies. We recommend that you study the Cookies Policy of those parties before using those websites.

Website visitors or users can use the web browser's cookie control tools to change cookie settings. For more information on how to adjust settings, please visit the Cookie Settings webpage.

Most browsers are set to accept cookies by default. However, you can delete or refuse the use of cookies in the settings page of the browser you are using. Your changes may affect the usage or display format of the website. You can check the setting methods for each browser below:

Google Chrome
Safari
Microsoft Edge
Firefox
Internet Explorer

However, The Creators HQ Co., Ltd. would like to inform you that disabling some cookies may affect the functionality of this website and may result in certain functions or operations of the website becoming unavailable.

10 Privacy Policy of Other Websites
This Privacy Policy applies only to our services and the use of our website. If you click a link to another website (even if it is through a channel on our website), you must study and comply with the privacy policy appearing on those websites separately from ours.

11 Changes to the Personal Data Protection Policy
We regularly review the effectiveness of the Privacy Policy. In the event of any changes to the Privacy Policy, such changes will be announced or published on our website or other platforms.

12 Contact Channel
If you wish to contact us to exercise your rights as a personal data subject, or if you have any questions, including any complaints (further), you can contact us through the following channel:‍

The Creators HQ Co., Ltd.Contact Address:
65/218 Chamnan Phenjati Business Center Building, 26th Floor, Rama 9 Road, Huai Khwang Subdistrict, Huai Khwang District, Bangkok 10310
Telephone: 02-246-2195
E-mail: dpo@thecreatorshq.com

LEGAL

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