Thai Digital Platform Social Enterprise Company Limited (the “Company”) as the owner and the developer of TAGTHAi Platform (“TAGTHAi”) has prepared this Privacy Notice (the “Notice”) in order to elaborate and define how the Company will collect, use, disclose, manage and protect the personal data of you as the TAGTHAi user (the “User”) to the User for information. Once the User register to use the service of TAGTHAi and open the TAGTHAi user account, the Company would deem that the User accept and agreed upon this Notice.

TAGTHAi Functions

For reference, the Company would like to inform the User that TAGTHAi provides 3 main services and functions as follows: (1) Pass and Benefit Function where the Company will provide the virtual cards services that can be used to participate in various types of activities in Thailand (“Pass”), for instance attraction tickets, travel and transportation ticket, product and sale redemption ticket to be used at the partnered restaurants or spas, and other benefits provided in the Pass that the User can enjoy; (2) Travel Function where the User can view the general travel guide information and book the travel and transportation vehicles, including without limitation the reservation of transportation tickets or transportation rental services (such as airplane, railway, boart, car, tour or van); and the reserve of accommodations or other related services (all the reservations made under Travel Function shall collectively be referrd to as the “Travel”); and (3) SOS Function where the support will be provided in case of emergency by contacting and forwarding information to Tourist Police or Police (“SOS”).

Scope of Application of this Notice

This Notice shall only be applicable to the services provided by the Company via TAGTHAi only and shall not be applicable to the platform, website or other services performed by third party service providers even through redirected or linked from or to TAGTHAi, including without limitation (i) the third party service provider involved in the performance of Travel Function where TAGTHAi will link all the content and booking system from the third party service providers to display on the Travel Function yet the booking and payment process will be executed and transacted directly by the third party service provider where the Company does not have any involvement in the personal data processing undertaken by the third party service providers on their system and platform; (ii) the IT service provider who will facilitate the emergency contract call to be executed under the SOS Function on TAGTHAi; (iii) Third-party payment service providers; (iv) the merchants and services provider that will be providing their goods and services under the Pass to the User that the User obtains from TAGTHAi, including without limitation the Company’s partner registered to provide goods and services on Pass Function to the User (the “Merchant”); and/or (v) other third-party service providers that may be engaged in the provision of TAGTHAi's services.

For the avoidance of doubt, the personal data processing undertaken by the third party service provider are out of the Companys’ control; therefore, the Company would recommend that the User should study the privacy notice defined by those third party service providers directly since the Company shall not give any representation or guarantee of the personal data processing undertaken by those third party.

In case any amendment made on this Notice, the Company shall notify the User explicitly on TAGTHAi and the amended Notice shall become effective upon announcement.

Data Sources where the Company may receive the User's Personal Data

The Company may receive the User’s personal data from the following data source: (1) directly from the User that submit those personal data for the registration of the TAGTHAi user account and for the transaction or activity to be executed via their registered TAGTHAi user account; or the personal data that the User may submit to the Company in any other circumstances to enjoy the benefit or transact in any way with the Company; (ii) collected automatically by TAGTHAi system; or collected from the relative data analysis of the User transaction information executed on TAGTHAi; or (iii) indirectly obtained from the third party service providers that the User may coordinate and execute any transaction with for the use of TAGTHAi services, including without limitation the Merchant and the Travel and SOS Function service providers, social media service providers that the User select to link their profile to TAGTHAi user account, where the Company would need to obtain the User’s information from those third party to display on TAGTHAi system for the User’s benefits.

User’s Personal Data being Processed by the Company

During the registration of the TAGTHAi user account and throgh the use of TAGTHAi service, the Company will collect, use and process the User’s personal data through various steps with the details of personal data being collected; the objective for those processing; and the retention period of those personal data defined as follows:

1. Automatic Processing of User’s Personal Data

• Personal Data being processed: Once the User access TAGTHAi, the Company’s system may collect and process the following personal data of the User automatically: User's IP address and/or domain name; information of other pages that link such User to TAGTHAi; the information relating to the browser type and version and OS configuration setting of the User's device; and the bahvavioural data of the User collected on TAGTHAi system.
• Processing Objectives: These automatically collected personal data shall be processed to serve these specific purposes: (1) to improve the performance of TAGTHAi to match the User’s preference and behaviour; (2) to make recommendation or display the most relevant content either for the travel guide information or the relevant Pass that would match the User’s preference and interest; and (3) to manage any associated risks that the Company may have in providing the services to the User.
• Retention Period: The Company would need to retain the defined personal data for the period of time that is necessary for the Company’s technical and business objectives; provided that the Company guarantee not to cause excessive effect on the User’s rights.

2. Personal Data Collected for the User’s Registration

• Personal Data being processed: During the registration process of the user account, the Company will collect, process and use the following personal data of the User: (1) the registration information that the User can select to register the user acocunt by giving full name, email and password for such registration; or select to link TAGTHAi user account with the user account from other social media platform (i.e. facebook, google, apple or wechat accounts); (2) date of birth and nationality information (If the User agrees to provide those information); and (3) after the susccessful registration of the user account, in order to guarantee the best service of TAGTHAi, the Company will assign user ID for each User and such such ID will be used to identify the identity of each User who use any services on TAGTHAi.
• Processing Objectives: The Company would need to process the defined personal data of the User obtained during the user registration for the following objectives: (1) to evaluate the User’s qualification and eligibility to use each function on TAGTHAi; (2) to use as the reference or identifier to combine all the transaction or activities that may be undertaken by the User on TAGTHAi; and (3) to communicate and contact with the relevant User for the purpose of ensuring the services will be provided to the User pursuant to the terms of services defined for all the services of TAGTHAi.
• Retention Period: The Company would need to collect and retain the User’s personal data collected during the user account registration throughout the period of time that the User still have the user account on TAGTHAi.

3. PERSONAL DATA being Processing during the Use of each Function of TAGTHAi

• Personal Data being processed: During the use of each function of TAGTHAi, the Company would need to collect, use, process and analyze the following personal data of the User, divided by each function of TAGTHAi as follows:

For using Pass Function

• Purchase information of additional Pass: In case of the purchase of any Pass in addition to Essential Pass, the Company will collect additional personal data of the User as follows: email address for delivery of the Pass, which may not be the same email address registered during the user account registration; and payment information where the Company will only obtain the payment confirmation from the third party service providers, not the User’s credit card information or bank account;
• Location information that the User can turn on directly from the User’s device and if such device location is turned on, the Company will collect such information;
• Pass Usage Information that the User may obatin under the Pass obtained and the details of the Pass usage that the User may redeem with the relevant Merchant;
• TAGTHAi Service and transaction information that the User have executed via TAGTHAi system, including without limitation, log-in information and services transaction information that will be compiled in the tranasction history of each User;
• Other User’s pesonal data that the User may provide to the Company during the communication and contact or the User may submit or disclose to the Company for the participation in any special event, lucky draw or other promotional activities TAGTHAi and/or the Company may host and User participated in, including without limitation via Play Function on TAGTHAi.

For using Travel Function, the Company will only receive transaction information that the User executed on the third party service platform and not obtain any personal data that the User may provide to those third party service provider;

For using SOS Function, in case of a foreign User, no personal data of the User shall be collected and in case of a Thai User, the Company would collect the following personal data: (1) full name; (2) telephone number; (3) location information; and (4) relevant SOS text solely for the purpose of transmitting all those pesonal data to the police department wihtout collecting or retaining any information on TAGTHAi, except for the transaction history information.

• Processing Objectives: The Company would need to collect, use and process the User’s personal data during the use of TAGTHAi (as defined above) in order to serve the following purposes:
• For the performance of the contractual obligations by the Company to the User as defined and committed under the terms of servicees that the Company set, including without limitation the process for the following purposes: (1) to verify the User’s identity and eligibility to use each function on TAGTHAi; (2) to ensure the User’s right to redeem any privileges under the Pass obtained; (3) to display all the transaction historical information that the User may executed on TAGTHAi for the purpose of reducing the dispute between the User and the Company relating to those transaction; and (4) to verify the User’s identity before the participation in the event that TAGTHAi or the Company may host and the User may be interested in participating in;
• For the Company’s performance of the legal obligations that the Company may have, in particular, the taxation and accounting obligations under the relevant laws and any other legal obligations under other relevant laws that the Company may be obliged to perform;
• For the purpose of protecting the Company’s legitimate interest without causing excessive effect on the User’s rights, in particular for these particular purposes: (1) to protect the Company’s legitimate rights and to prevent the Company’s right in the legal proceedings; (2) to plan the improvement in products and service provided on TAGTHAi to ensure that those products and services would match the interest and needs of each Users, as an individual or generally as the TAGTHAi user; (3) to manage the enterprise risk of the Company and to prevent any fraud in TAGTHAi system; (4) to improve the relationship between the User and the Company through the management and resolution of any dispute arisen by the User and/or the Company; (5) to analyze and define the relevant User segment and profiles for the purpose of Facebook lookalike marketing and/or other marketing methodology to the similar profiled group as the User that is not the direct marketing to the User; (6) to publicize the marketing materials produced by the Company that may include the personal data of the User (including photos and satisfaction feedback) to the general public; and (7) to compile the statistic and de-identified information of the User to make a report of all the usage of TAGTHAi and to use for other purposes that the Company may deem appropriate.
• With the User’s explicit consent, the Company may use the User’s Personal Data for the specific purposes defined under the consent given, in particular for the purpose of marketing and promotion purposes of all the information that the User may be interested in, via in-application notification or other communication channels that the User may register and notify the Company.
• Retention Period: The Company may collect, user and retain all of the User’s personal data for the purposes defined above for the period of times as follows: (1) throughout the period of time that the User still have TAGTHAi user account, or in other words, until the User has notified the Company in writing of the intention to terminate the user account; (2) throughout the period of time specified by the relevant laws that the Company shall be obliged to comply with; (3) 5 (five) years after the termination of each User's user account under such time that the Company may retain such personal data solely for the purpose of protecting the Company’s legitimate interest in any dispute or claim that may arisen during such time; or the purpose of improving the relationships between the Company and the Users; (4) in case of any de-identified information, for any period of time that the Company may consider necessary for their business operation; and (5) for any personal data being processed with the consent given, for any period of time until such consent will be withdrawn.

4. Disclosure of User’s personal data

Generally, the Company will not share or disclose the User’s personal data to any third party, except to these following persons that the Company would need to disclose and share the User’s personal data to due to their direct involvement in the services to be performed by the Company to the User:

• Merchant who has the direct responsibility to provide good or services under Pass to the User and in order to ensure that the User shall be entitled to enjoy the benefit under Pass, the Company would need to disclose the User’s personal data to the relevant Merchant yet the Company commits to limit the data to be provided on the necessary basis solely and will define the clear data processing agreement with the Merchant in writing;
• Third Party Service Provider that may include (1) the third party service provider that the Company may redirect the TAGTHAi service to the platform of those third party service provider for the performance of Pass / Travel or SOS Function on TAGTHAi; (2) other service providers that the Company may engage to assist in the service performance of TAGTHAi, including without limitation the technology and IT service providers and payment service providers; (3) the Company’s external consultant engaged for the business operation of the Company, including auditors and other expertise consultant (i.e. financial, legal consultant). For the disclosure of the User’s personal data to these third party service providers, the Company guarantee to implement the appropriate measures to limit the access of those parties to the need to know basis and assure the entering into the relevant data processing agreement between the Company and those service providers;
• Other business partners from whom the Company may receive various support or cooperation for the delivery of TAGTHAi service to the User and the Company may be contractually obliged to share the TAGTHAi usage statistic data to those business partners; provided for all ot these sharing or disclosure, the Company commits to only share the de-identified information of the User to those business partner;
• Government authority and regulators that the Company may be obliged under the relevant laws, regulations, instructions or government order to disclose the User’s personal data to.
• Any other persons that the Company may obtain the User’s explicit consent to disclose the personal data to those persons.

5. Representation to implement appropriate information security measures

Preventing and securing your personal are the most important priority for the Company. The Company commits to implement all of the necessary information security measures to prevent the unauthorized access, amendment or disclosure of the User’s personal data retained in the Company’s possession and the Company commits to review and revisit the relevant measures on the regular basis in order to ensure the compliance with the relevant laws and regulations and the industrial best practice and standards.

6. Data Subject Rights

The Company respect the User’s statutory rights as the data subject under the relevant laws over the relevant User’s personal data, including in particular the following rights: (1) the right to request for access or copy of their personal data (2) the right to request for data portability; (3) the right to object to any process of their personal data; (4) the right to request for deletion or de-identification of the User’s personal data once there is no further necessity; (5) the right to request for the suspension of the User’s personal data processing; or (6) the right to withdraw consent. In case the User would like to exercise any of these rights; (7) right to revise or rectify the personal data; (8) right to complain, please feel free to contact the Company as the defined contact channel and the Company will consider and get back to the relevant User’s request within properly period under the law.

7. Contact Information of the Company as a Data Controller

The Company welcmes any queries, complaints, comments, or requests relating to this Notice, in particular the request for the exercising of the data subject rights by the User. Please feel free to contact us at: Userservice@tagthai.com