SF Development Company Limited (“Company”, “we”, “us”, or “our”) recognizes the importance of the protection of personal data you have entrusted to us. The Company will manage, protect, and process your personal data in appropriate manner, which information about you shall be collected, used, disclosed, and transferred to overseas, and we will carefully and sensibly use your personal data.
What personal data is?
“Personal Data” means any information relating to a person, which enables the identification of such Person, whether directly or indirectly.
When and what personal data we collect?
We may collect or obtain the following types of information, which may include your Personal Data, directly or indirectly from you or other sources. The specific type of Personal Data collected will depend on the context of your interactions with us, and the services or products you need or want from us.
- Personal details, such as title, full name, gender, age, occupation, qualifications, job title, position, business type, company name, nationality, country of residence, date of birth, marital status, number of family members and children, ages of children, information on government-issued cards (e.g., national identification number, photograph of the national identification, information on the national identification, control number on the reverse side of the national identification (Laser ID), social security number, passport number, tax identification number, driver's license details or similar identifiers), immigration details such as arrival and departure date, signature, voice, voice record, photograph, facial features for recognition, CCTV records, work place, education, insurance details, license plate details, house registration, household income, salary and personal income;
- Contact details, such as postal address, delivery details, billing address, residential address, workplace address, address on the national identification, telephone number, fax number, email address, LINE ID, Facebook account, Facebook ID, Google ID, Twitter ID, and other account from social networking sites, including your contact person detail such as telephone number, contact data on other correspondence (e.g. written communication with you);
- Membership details, such as account details, member card number, reward points, member ID, member type, customer type, member join/registration date and month, membership period, bank account and payment details, service and product applications;
- Financial details, such as debit/credit card or bank information, credit/debit card number, credit card type, issuance/expiration date, cycle cut, account details, bank account details, prompt pay number payment details and records;
- Transaction details, such as details about payment to and from you, payment date and/or time, payment amount, details about refund, refund amount, points, date and location of purchase, purchase/order number, appointment date for service, address/date and time for pick up or delivery, acknowledgement of receipt, recipient email’s signature, warranty details, complaints and claims, booking details, rental details, transaction, transaction history, location, transaction status, past sales transaction, status, transaction status, purchasing behavior, and any other details of products and services you have purchased, including but not limited to any information incurring from using of products;
- Technical details, such as Internet Protocol (IP) address, cookies, media access control (MAC) address, web beacon, log, device ID (such as international mobile equipment identifier (IMEI), electronic serial number (ESN), mobile equipment identifier (MEID) and serial number (SN)), device model and type, formats of software and hardware of the device when it is activated in the system, network, connection details, access details, single sign-on (SSO), login log, access time and location, time spent on the page, login data, GPS, latitude, longitude and time spent on each webpage, login information, applications downloaded on a communication devices, search history, browsing details, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on devices you use to access the platform, including any other technical information arising from the use of our platform and systems;
- Behavior details, such as information about your purchasing behavior and data supplied through the use of our products and services;
- Profile details, such as your username and password, profile details and picture, purchases, PIN, your interests, preferences, feedback and survey responses, satisfaction survey, social media engagement, participation details, loyalty programs, your use of discount codes and promotions, customer order description, customer service, attendance to trade exhibitions and events, trade exhibitions, litigation, testing and trials;
- Usage details, such as information on how you browse or use our websites, platform, application, use of our products and services, follow-shop record, and timestamp of last click and Q&A record;
- Marketing and communication details, such as your preference in receiving marketing from us, our affiliates, subsidiaries, third parties, business partners, and your communication preferences; and/or
- Sensitive data, such as race, religion, political opinions, fingerprints, facial recognition, person identity information (biometrics), face, information from the iris recognition, physical or mental health or condition, genetic data, medical history, disability and criminal records.
We will only collect, use, or disclose sensitive data on the basis of your explicit consent or where permitted by law.
We only collect the information of children, quasi-incompetent persons, and incompetent persons where their parent or guardian has given their consent. We do not knowingly collect information from customers under the age of 20 without their parental consent, or from quasi-incompetent persons and incompetent persons without their legal guardian's consent, when consent is required. In the event we learn that we have unintentionally collected personal information from anyone under the age of 20 without parental consent, or from quasi-incompetent persons and incompetent persons without their legal guardians, we will delete it immediately or process only if we can rely on other legal bases apart from consent.
You may access and use our websites without disclosing your Personal Data, providing of Personal Data is voluntary. However, if you decide not to provide your Personal Data, we may not be able to provide preference products and services to you.
Collecting and processing of Personal Data
We may collect, use and disclose your Personal Data for the marketing and communications purpose, including but not limited to provide privileges and promotions, discounts, special offers, advertisements, notices, news, information and any marketing and communications about the products and services from us and/or our business partners which we cannot rely on other legal bases.
However, we may also rely on other purpose and legal bases for collecting and processing of your Personal Data, including for our initiation or fulfilment of contract, legal obligation, legitimate interest, legitimate interests of third parties, vital interest, for preventing or suppressing a danger to a person’s life, body, or health and/or public interest, or the exercising of official authorities.
Your Personal Data shall be collected, used, disclosed and/or processed according to purposes that the Company may/need to process your Personal Data in any circumstances, and to comply with legal obligations and regulations in a reasonable time and in accordance with the applicable law. The collecting and processing shall include but not limited to following purposes:
- For marketing and communications, to provide privileges, offers, updates, sales, special offers, promotions, advertisements, notices, news, information and any marketing and communications about the products and services, including activities from Megabangna Shopping Centre and our business partners;
- To manage any activities related to customer services, including, to handle customer service-related queries, request, feedback, complains, claims, disputes or indemnity; to provide technical assistance and deal with technical issues; to process and update your information; to facilitate your use of the products and services;
- To maintain and gain relationship with customer and to contact and communicate with you in relation to the products and services you obtain from us;
- To evaluate, proceed, and provide the services, products and/or facilities to you;
- To manage and proceed the services, products and facilities as you requested;
- To identify you and your profile;
- To handle your queries or complains, and to resolve any dispute arise from the communications between you and the Company;
- To provide services or support as you requested;
- To provide information and/or upcoming of product, service, promotions and/or events organize by the Company and third party elected by us, which you may interest from time to time;
- For direct marketing, which can be done via SMS, phone calls, email, FAX, social media and/or any other means if you are a member of the Company’s activities, such as Megabangna Application, Mega Smile Rewards and/or Mega Smile Kids and via other method of consent given by you.
- To facilitate you to participate or earn promotions, special offers, loyalty programs, reward program, sweepstakes, privilege, prize draws, competitions, and other offer/promotions (e.g., sending you reminder emails and transferring your Personal Data to business partners) to participate in activities and seminars, and all services related to advertising. This includes to process and administer your account registration, gift registration, event registration; for processing, collection, addition, exchange, earning, redemption, payment, and transfer of points; to examine your entire user history, both online and offline; to provide and issue gift vouchers, gift cards, and invoices;
- To provide points or reward of activities of the Company;
- To store and maintain the Company’s internal information up to date;
- For internal management of the Company;
- To send greetings on various time;
- To manage and analyse Personal Data, whether in individual or group;
- For registration and authentication, including to verify, prove, affirm, identify, and/or authenticate you or your identity;
- To conduct marketing research and survey, internal marketing analytics, customer data, type and choice of customer analysis, planning and statistic analytics and our products and services trend;
- To disclose your Personal Data to auditor for internal audit and generating financial reports of the Company;
- To use your Personal Data, that we collected from contract or other documents made by and between you and the Company, for obtain legal advice and/or financial advice and/or for legal proceedings;
- To disclose your Personal Data to business partner of the Company to co-develop products and services and/or marketing campaign;
- To perform financial audit performance, risk management and security management;
- To detect, investigate and prevent fraud and, misconduct and illegal actions;
- To comply with contractual obligation of the Company and to exercise the Company’s right under contract or other document with the Company is a party;
- To transfer right, benefit and obligation of the Company according to any contract entered into with the Company;
- To comply with law and relevant regulation, and to disclose for comply with the law, rule, regulation, court order, guideline, circular letter or measure which the Company is subject.
- To exercise rights or protect interest of the Company and you, where it is necessary and lawfully to do so;
- For any other purposes which are reasonably in connection to manage, maintain and run our business effectively, including to gain relationship between you and the Company, in such cases, we will notify you upon we obtain your consent;
- To manage our relationship with you, to contact and communicate with you in relation to the products and services you obtain from us, those within Megabangna’s data ecosystem and business partners; to handle customer service-related queries, request, feedback, complains, claims, disputes or indemnity; to provide technical assistance and deal with technical issues; to process and update your information; to facilitate your use of our products and services;
- With your consent from time to time (where required), to provide personalization experiences, analyse your preferences and habits (Profiling), conduct data analytics to provide you with targeted products and services, anticipate your preference and provide you with personal experience, learn more about you, your services and products you obtained to evaluate your preferences and habits to products and services; to conduct data analytics, data cleansing and data profiling for marketing research, survey, behaviors assessment, statistic and consumption trend classification; to analyse your preferences and habits based on the processing of your Personal Data, for instance by looking at the types of products and services that you receive, how you like to be contacted; to learn more about you; and to improve business operations, as well as to adjust content to meet your satisfaction; to analyse the efficiency of marketing campaign; to identify and resolve products and services problem; to improve existing data quality. For such purposes, we will collect and disclose your Personal Data for your interests and benefits, and for our legitimate interests and business operation of the Company, affiliates, subsidiaries and business partners which shall not overridden by the fundamental rights of the data subject of his or her Personal Data.
- To improve business operations, products, and services, to evaluate, develop, manage, and improve, research and develop the services, products, system, and business operations for you and all of our customers within Megabangna's data ecosystem, including but not limited to our business partners; to identify and resolve issues; to create aggregated and anonymized reports, and measure the performance of our physical products, digital properties, physical measurement of products performance, digital features and marketing campaigns;
We may collect, use, disclose or process your Personal Data apart from the above purposes, howsoever, we will notify you additional purposes and we obtain your consent, unless otherwise authorized by law to process your Personal Data without your consent.
To whom we may disclose or transfer your Personal Data
We may disclose your Personal Data to the third parties, agents, affiliates or related companies for the purposes hereunder or purposes of collecting, using, disclosing and processing of Personal Data we notified you in accordance with law. We may disclose your Personal Data to government authorities where we it is necessary to comply with law, rule, regulation, guideline, order or governance which the Company is subject.
We may disclose or transfer your Personal Data to the following persons:
- data entry service providers;
- infrastructure, internet, infrastructure technical, software and website, and IT service providers;
- research agencies;
- analytics service providers;
- survey agencies; (7) auditors;
- marketing, advertising media, and communications agencies;
- campaign and event organizers;
- outsourced administrative service providers;
- data storage and cloud service providers;
- printing service providers;
- professional advisors, consultants and/or auditors;
- third party providers, such as service providers in management or business operations, for instance, telecommunications, information technology, logistics, shipping, assembly, installation, postal service, or marketing service and marketing campaign;
- public officer or Government authorities, including third party assigned by law;
- business partners, affiliates or related companies, whether located in Thailand or overseas;
- service providers who provide data report services or recruitment services, we may share your Personal Data to our service providers in the course of recruitment process and consider appropriate candidates; and/or other authorities in respect of the recruitment process of the Company;
- social networking site; and
- other person, such as associations, organizations and assignee of rights and/or obligations
In the course of providing such services, the service providers may have access to your Personal Data. However, we will only provide our service providers with the Personal Data that is necessary for them to perform the services, and we ask them not to use your information for any other purposes.
We may disclose or transfer your Personal Data to overseas third parties or service providers, that may have different laws and data protection compliance requirements. We will provide appropriate safeguards to protect your Personal Data, and the receiver shall have adequate data protection standard or otherwise as required by law. We may obtain your consent for the international transfer if required by law.
However, third parties of the Company shall solely use your Persona Data for the purposes of performing of contract entered in to with the Company. As a part of our contract with them, they are required to strictly adhere to applicable laws and policies specified by the Company and to take reasonable measures to ensure that your Personal Data is secure.
Cookies and how they are used
If you visit our websites, we will gather certain information automatically from you by using cookies.
Cookies are small pieces of information or text issued to your computer when you visit a website and are used to store or track information about your use of a website and used in analyzing trends, administering our websites, tracking users’ movements around the websites, or to remember users’ settings. Some cookies are strictly necessary because otherwise the site is unable to function properly. Other Cookies allow us to enhance your browsing experience, tailor content to your preferences, and make your interactions with the site more convenient: they remember your username in a secure way, as well as your language preferences.
Most Internet browsers allow you to control whether or not to accept cookies. If you reject, remove or block Cookies can affect your user experience and without cookies, your ability to use some or all of the features or areas of our websites may be limited.
In addition, some third parties may issue Cookies through our websites to serve ads that are relevant to your interests based on your browsing activities. These third parties may also collect your browser history or other information to determine how you reached our websites and the pages you visit when you leave our websites. Information gathered through these automated means may be associated with the Personal Data you previously submitted on our website.
Your rights as a data subject
The Company recognizes the importance of maintaining the security of your Personal Data. Therefore, the Company establish security measures for your Personal Data appropriately and in accordance with the confidentiality safeguard of Personal Data, to prevent loss, unauthorized or unlawful access, destruction, use, alteration, rectification or disclosure; provided, however, that the Company will ensure that the method of collecting, storage and processing of your Personal Data according to processing principal, including physical safety measures follow the information technology security policies and guidelines of the Company.
Subject to applicable laws and exceptions thereof, you may have the following rights to:
- Access: You may have the right to access or request a copy of the Personal Data we are collecting, using or disclosing about you. For your own privacy and security, we may require you to prove your identity before providing the requested information to you.
- Rectification: You may have the right to have incomplete, inaccurate, misleading, or not up-to-date Personal Data that we collect, use or disclose about you rectified.
- Data Portability: You may have the right to obtain Personal Data we hold about you, in a structured, electronic format, and to send or transfer such data to another data controller, where this is (a) Personal Data which you have provided to us, and (b) if we are collecting, using or disclosing such data on the basis of your consent or to perform a contract with you.
- Objection: You may have the right to object to certain collection, use or disclosure of your Personal Data such as objecting to direct marketing.
- Restriction: You may have the right to restrict the use of your Personal Data in certain circumstances.
- Withdraw Consent: For the purposes you have consented to our collecting, using or disclosing of your Personal Data, you have the right to withdraw your consent at any time.
- Deletion: You may have the right to request us to delete, destroy or de-identity your Personal Data that we collect, use or disclose, except we are not obligated to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise, or defend legal claims.
- Lodge a complaint: You may have the right to lodge a complaint to the competent authority where you believe our collection, use or disclosure of your Personal Data is unlawful or noncompliant with applicable data protection law.
You may exercise the rights relating to your Personal Data under our possession by contact us or email us at firstname.lastname@example.org.
You acknowledge that the Company assumes that all Personal Data submitted to us is complete and accurate. The Company shall not be responsible in case of use of incorrect or inaccurate Personal Data acquired from you and/or you rectify your Personal Data which makes the information you provide to the Company is not up to date.