Privacy Policy

Last Updated: March 18, 2024

1. Introduction

Horopass ("the Company" or "we") places a high priority on the privacy of our customers. This Privacy Policy has been established to inform you ("you") about our policies regarding your personal data, how we collect, use, and disclose your personal data, the types of personal data and purposes for processing, the disclosure of your personal data to third parties, as well as details on how we protect your personal data, the retention period of your personal data, and your rights under the Personal Data Protection Act B.E. 2562 and related laws and regulations ("Personal Data Protection Laws").

2. For What Purposes Do We Collect, Use, and Disclose Your Personal Data?

We will collect, use, and disclose (collectively referred to as "process") your personal data only to the extent that it is necessary and lawful. We will process your personal data only when there is a legal basis that allows us to do so, including processing personal data to fulfill our contract with you, to comply with our legal obligations, for our legitimate interests, to prevent or mitigate harm to the life, body, or health of you or others, to carry out a public task in the interest of the company, to exercise state authority, based on your consent, and/or under other legal grounds as stipulated by the Personal Data Protection Laws.

Additionally, the law prohibits us from collecting sensitive personal data, which includes but is not limited to information about race, ethnicity, political opinions, religious or philosophical beliefs, sexual behavior, criminal records, health information, disability, union membership, genetic data, biometric data, or any other information that similarly affects you. Unless we have received your explicit consent, we will not collect or use such data unless permitted by the Personal Data Protection Laws.

We store your personal data to process it for the following purposes:

2.1 To Fulfill Our Contract with You

We will process your personal data to provide the services that you have subscribed to, requested, and/or to fulfill any agreement or contract that you have made with us. This includes but is not limited to the following purposes:

To register and log in to your account
To verify your registration, confirm and authenticate your identity, and verify contact methods
To provide the services you subscribed to, tailored to your preferences and interests, deliver the services you requested, and/or fulfill the contract made with us
To communicate relevant products and services, including sending service fee notifications, product and service orders, payment reminders, and receipts
To process payments for services and fees related to our services
To distribute compensation, rewards, and other benefits
To address inquiries, provide user support, offer information, handle complaints, and resolve issues and obstacles
To conduct business operations such as analysis, surveys, performance measurement, service improvement, and maintenance to ensure normal service delivery
To compensate you for any damages
To inform you of changes to services and terms of service

2.2 To Fulfill Our Legal Obligations

As we are legally obligated to comply with laws and orders from legal authorities, it is necessary for us to collect, use, and disclose your personal data for various purposes, including but 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, the Electronic Transactions Act, the Consumer Protection Act, and other applicable laws)
To comply with regulations and/or orders from legal authorities (e.g., court orders, orders from government agencies, or authorized officials)

2.3 For Our Legitimate Interests and Those of Third Parties

We will process your personal data for our legitimate interests, taking into account our benefits or those of other individuals or legal entities alongside your fundamental personal data rights. This includes but is not limited to the following purposes:

To prevent fraud and corruption, as well as to enforce our terms, conditions, and policies, and/or to exercise legal claims as permitted by applicable laws
To ensure the security of our data and service networks, and to notify you of any suspicious activities, such as unusual login attempts to your account
To analyze how our customers use our products and services to improve service standards, plan and track marketing campaigns, analyze and enhance the services you use for greater efficiency and responsiveness to your needs
To develop new products that meet customer needs and to define customer segments for new products or services
To offer our products, services, and benefits to you based on your information and preferences. If you do not wish to receive product, service, and benefit offerings from us, you can adjust your settings in the application you are using, or in the case of emails, you can opt out by clicking the "Unsubscribe" button included in the email
To record images and audio related to meetings, training sessions, recreational activities, or exhibitions
To anonymize personal data so that it cannot be used to identify individuals

2.4 Processing Based on Your Consent

In certain cases, we must obtain your consent before processing your personal data. This includes but is not limited to the following purposes:

When it is necessary to collect sensitive personal data
To send updates, deals, and promotions from our business partners, and to advertise content based on your information and interests
To disclose your personal data to Horopass for analyzing your usage behavior of our products and services and building a customer database to research, develop, and improve products, and to plan marketing strategies that optimize product and service development to meet your needs, as well as to contact you with personalized offers, services, and benefits from the company
We may collect, use, and disclose beneficial personal data to enhance your experience with our products or services. We will clearly specify the details of the consent request, such as using other service providers’ login credentials, etc.
If you are a minor, an incapacitated person, or a quasi-incapacitated person, consent must be obtained from your parents, guardians, caretakers, or legal representatives, as applicable (unless the Personal Data Protection Laws allow processing without consent).

3. Personal Data We Collect

We collect various types of personal data. The collection, use, and disclosure of personal data vary depending on the products and/or services you use or have used. To give you an overview of the data we collect, we have categorized the data types as follows:

Types of Personal Data

Personal Information

First name, last name
Gender
Age
Date of birth

Contact Information

Current address
Email address
Phone number

Government-issued Identification

National ID number
Passport number
Copies or photos of your ID card, passport

Account Information

Account name
Account number
Account password

Financial Information

Payment and payment confirmation details

Service Usage Information

Products and services you have subscribed to and used
Duration and dates of your logins and service usage
IP Address
Cookie data
Usage activity information

Customer Preferences

Content you prefer

Market Research and Marketing Information

Customer surveys

Device Information, Application and Browser Information

Device identification number or other unique identifiers
Device type
Model and brand
Application and browser details, operating system, and platform

Voice Communication Data Between You and Our Customer Service

Recorded voice data

Location Information

GPS data
Information about nearby objects (e.g., Wi-Fi access points and Bluetooth activations)

Social Media Information

Social media accounts
Your profile information
Your usage and interactions with our social media platforms

Other Information

Any information you provide to us through any channel

4. Sources of Personal Data We Collect

In general, we collect personal data directly from you and automatically when you use our services or interact with us. Additionally, we may collect personal data from our business partners and other sources, adhering to and following the legal processes as mandated by law, and only in cases where the law permits us to do so. The details are as follows:

4.1 Personal Data You Create and Provide to Us

This data includes information you provide to us, as well as information provided by individuals related to you or your business, including those authorized by you or acting on your behalf. This includes:

When you register for our services and access our services
When you communicate with us at our office, or through our website, applications, email, social media, and telephone
When you participate in our surveys or promotional activities
When you agree to receive news updates and progress information, including benefits
When you engage in activities on our services, such as posting comments, uploading content, images, or videos to our services, updating your profile, and setting up your account preferences
If you wish to verify and authenticate your identity with us, we will request that you provide government-issued identification documents and other additional documents
When you make payments for our services, we will collect payment-related information

4.2 Personal Data We Collect Automatically

When you access our services and products through our website and/or applications, we collect the following data:

Your service usage data, your communications with us, application and browser data, as well as information related to the electronic devices you use to access our services or communicate with us.
When you use our services that require device location identification, we collect your device’s location data to enable us to provide various features, such as offering services, discounts, and benefits for nearby stores or restaurants. (You can control the collection of this data through your device settings, which may vary depending on the operating system.)
Additionally, we use cookies and other technologies to collect information while you use our website or mobile app. (You can read more about this in Section 9, "Cookies and Cookie Usage," of this notice.) You can refuse the collection of data via cookies through your browser settings, though this may reduce the optimal performance of our website and application.

4.3 Personal Data from Other Sources

Companies that refer you to us
Internet service providers and telecommunications providers
Social media providers and other technology providers (For example, when you use your credentials from those providers to access our services, we will collect information about your profile. You can control the collection of this data through the options provided in your user account settings by those providers.)

5. Sharing and Disclosure of Personal Data

We may share your personal data with external individuals or organizations for various purposes as outlined in this Privacy Notice. The types of organizations with which we may share your personal data are as follows:

Government Authorities: As required by law
Service Providers Related to Our Products or Services: Companies with whom we may need to share your personal data in relation to our products or services, and/or your use of our services, and/or to fulfill the contracts we have with you, and/or as you request
Service Providers Supporting Our Business Operations: Companies we use to assist in operating, improving, and developing our business. These service providers may need access to your personal data and other information, but we do not permit them to use or disclose your personal data for any other purpose except as related to the services we have contracted them for. These may include:
- Companies that refer you to us
- Customer management service providers
- Banks and payment and transaction service providers
- Business consultants, including legal and information technology consultants
- Information technology service providers
- Advertising, marketing, and social media service providers
- Litigation and debt collection consultants, including legal consulting firms
- Mergers, acquisitions, and transfers of products or services
Sharing and Disclosure of Aggregated or Anonymized Data: We may share data that cannot be used to identify you publicly and/or with our affiliates, partners, and other companies we have relationships with. For example, we may share data to show trends related to our services generally, helping us understand market demand trends.
Sharing Data with Other Parties with Your Consent: We may share personal data or other information as you have consented, such as linking your account to external platforms.

6. Data Security and Retention Periods

We implement effective security measures, including organizational and technical measures, to prevent unauthorized or improper access, use, alteration, modification, or disclosure of personal data.

We need to retain various types of your data for different periods. Generally, we will keep your personal data as long as you are a customer of ours for the following purposes:

Establishing Legal Claims: To establish, exercise, or defend legal claims or to comply with legal obligations.
Security and Prevention: To ensure security, prevent illegal activities, prohibited activities, or breaches, and to protect you, others, and ourselves from misconduct.
Customer Data Research: As part of our internal research to study customer data.
Accounting and Compliance: For accounting purposes, dispute resolution, and tax compliance.

When we no longer have a reason to retain your data, we will delete it from our servers or retain it in an anonymized form only.

7. If You Choose Not to Provide Us with Personal Data

We are required to collect personal data by law or to fulfill the contracts we have with you. If you choose not to provide this personal data, we may not be able to provide you with our services, and we might have to cancel the products or services we offer to you.

In some cases, we may request additional personal data that would enhance your experience with our products or services. We will clearly specify when we need to request such data. You have the right to choose not to provide this additional information, and it will not affect the core products or services you have with us.

8. Your Rights to Control Your Personal Data

When the provisions of the Personal Data Protection Act come into effect, you can exercise various rights concerning your personal data, subject to the guidelines and conditions specified below:

Withdrawal of Consent
- When you provide consent to us for a specific purpose, you may withdraw that consent at any time, unless there are legal limitations or if the consent is related to a contract that benefits you.
- You have the right to withdraw your consent at any time. You can manage your consent settings through the application you use.
Notification of Incorrect Personal Data
- You have the right to inform us if your personal data is incorrect, incomplete, or outdated. We will review and correct it accordingly.
- You also have the right to access and update your personal data through the application you use.
Accessing, Receiving Copies of, and Transferring Personal Data
- You have the right to request access to and obtain copies of your personal data from us, including requesting your data in electronic form or having it transferred to other organizations and companies, within the scope defined by the Personal Data Protection Act.
Objecting to Processing, Temporarily Suspending, and Deleting or Destroying Personal Data
- You have the right to submit requests to object to the processing of your personal data, temporarily suspend its use, and request the deletion or destruction of your personal data, within the scope defined by the Personal Data Protection Act.

You can contact our staff to exercise the above rights. We reserve the right to refuse requests that are unreasonable, do not comply with legal requirements, and/or are impractical. Additionally, we reserve the right to refuse requests within the limits set by the law. You may also file a complaint with the Personal Data Protection Office through the designated channels.

9. Cookies and Cookie Usage

We may collect, use, and disclose cookies and similar technologies when you use our services and products, including accessing our website and applications, for the following purposes:

To protect you from fraud and enhance security.
To study how visitors interact with our website, app, and other services so we can make improvements.
To determine which of our products, services, and offers may be relevant to you.
To tailor the marketing you see on social media, apps, and other websites.

You can refuse to allow the collection of data through cookies by adjusting your browser settings. However, this may reduce the optimal performance of our website and applications.

10. Minors

We do not intend to collect personal information from minors, defined as individuals who are under 20 years of age or who have not reached the age of majority through marriage as defined by law ("Minors"). We do not permit Minors to apply for or purchase our products, goods, or services unless we have obtained consent from the Minor (if permitted by law) or from the Minor’s parent or legal guardian, or when there is another legal basis for doing so.

If you are a parent or legal guardian of a Minor and are aware that your child or the Minor under your guardianship has provided personal information to us, please contact us. You can exercise your rights within the scope defined by data protection laws and other applicable laws.

If you are a Minor and need our services and products, please have your parent or legal guardian provide consent for you to give your personal information to us by contacting us using the details provided above.

In cases where we need to seek consent from a Minor to use personal information for purposes that the Minor cannot consent to alone under the Civil and Commercial Code, we will obtain consent from the Minor’s parent or legal guardian according to the requirements set forth by data protection laws.

11. Use of Personal Data for Original Purposes

We are entitled to collect and use your personal data that we collected prior to the effective date of data protection laws related to the collection, use, and disclosure of personal data. We have the right to continue collecting and using this personal data for the original purposes. If you do not wish for us to continue collecting and using such personal data, you can adjust your consent settings in the application you use.

12. Changes to the Privacy Policy

We may update this privacy policy from time to time to comply with changing laws, regulations, or operational requirements. We will clearly notify you of any changes through our website and/or by sending you an email notification. If you do not wish to accept or agree to any updates to this privacy policy, you may choose to discontinue using our services.