Personal Data Collection Objectives

To give consent to the Company to store, process or use Personal Data for the following purposes:

• To disseminate various news information related to products and services of the Company and present projects in which customers may be interested
• To prepare marketing plans, analyze, and process usage data including improvements of products and services of the Company
• To send such Personal Data to third parties or business partners of the Company with products and/or services

Personal Data Maintenance Policy

This policy is used for the maintenance of Personal Data of Soken Development Group Company Limited, a subsidiary company and/or a joint venture company (“Company”) for Personal Data provided through the Company channels, both offline and online, such as visiting projects, websites, applications, social media (“Platform”) created for the purpose of searching for, visiting, and using products and services of the Company and/or its partners, such as:

• Residential projects including condominiums, single-family homes, town homes, commercial buildings, and other projects
• News and promotions of products and services
• Any procedures taken regarding products and services

Before using this website or application, the User must read the terms, conditions, and Personal Data Maintenance Policy. If the User does not accept the terms and conditions, and Personal Data Maintenance Policy, use of this website must be terminated immediately. If you use of the website is continued, it is deemed that the terms, conditions, and Personal Data Maintenance Policy are accepted and followed. The Company’s Personal Data Maintenance Policy is as follows:

1. Definitions

“Personal Data” means information about an individual which enables identification of such person, whether directly or indirectly.

“Cookies” means information sent from a website to the computers of visitors to the website while browsing.

“Log” means data that results from the use of an application which include the source, destination, route, time, date, quantity, duration, type of service, or anything else related to the use of the application.

2. Personal Data Collection

2.1 The Company shall collect Personal Data which the Company receives directly or indirectly which consists of:

• Personal Data such as first name, last name, gender, age, nationality, date of birth, marital status, address, occupation, place of work, postal code, email address, telephone number, credit card, personal monthly income, and cars used
• Information on personal interests such as product and service types, hobbies, social network channels used, and sports or travel
• Information about product and service choices, such as reasons for purchasing, choice of residence, budget, purpose, and other products used for comparison, opinions about products and services, product and service viewing information
• Information that identifies your geographic location while using the website. In the event that you enable the use of the GPS system, it is deemed that consent is given to the Company for collection and processing of location information during use. Location information can be concealed by installing relevant programs or by turning off the mobile phone GPS system
• Conduct for searching information on the website. The Company has the right to use Cookies as a tool for collecting information, such as
• IP address
• Web browser type used
• Web page used
• Time of browsing
• Websites that refer to the Company’s website
• Application usage behavior with a log of usage from the Company’s application
• Required Personal Data provided to the Company which shall be processed as required by law without the need for consent, including:
• Providing information to comply with laws or for entering into a contract. If the User fails to provide such Personal Data, the Company may not be able to proceed with the User’s request, or it may result in other legal consequences
• Providing information that is necessary for legitimate interests, such as collecting the User’s photos to organize various activities of the Company
• The Company shall obtain the User’s consent for any other Personal Data

2.2 The Company shall collect Personal Data only as necessary, or as required by law. The Company may collect Personal Data by converting it into anonymous information.
    
In the case that there is a connection to websites or advertisements other than those of the Company, the Personal Data Protection Policy shall be as specified by such websites. The Company has no involvement whatsoever.

2.3 Personal Data Collection method, such as:

• via Company channels such as electronic documents, verbally case by case or
• through the channels of partners/other service providers such as Facebook and Line for creating profiles or agents

2.4 Minors

• The Company shall not collect Personal Data from minors under the legal age limit (“Age Limitation”). Those below the age limit must not use the Company’s services or provide any Personal Data to the Company
• Parents of a minor below than the age limit who are aware that the minor has provided Personal Data to the Company may contact the Company to exercise their rights
• Minors below the age limit who wish to receive the services and products of the Company must request their parents to give consent to the Company to provide the minor’s Personal Data

3. Personal Data Collection, Usage and Disclosure Objectives

3.1 To carry out transactions as intended such as registration to receive information and promotions. The Company shall store and use only basic information such as first and last names, email address, telephone number for reply or in the case of online booking. The Company shall collect and use information necessary to issue important documents for booking transactions.

3.2 To improve the performance of websites and applications, create a marketing plan, analyze usage data, and evaluate services including improving and developing the Company’s products and services

3.3 To disseminate various news information related to the Company’s products and services including benefits and related promotions of products and services or any changes regarding the Personal Data Maintenance Policy in the future

3.4 To adhere to the Contract which includes third parties whose services the Company uses, such as sharing location information in the event that the Company uses the service to determine the location of another party’s area.

3.5 To take legal action, such as to prevent threat to a person’s life, body, or health. Research studies or statistics to ascertain the appropriate protection measures have been put in place to protect the User’s rights and freedoms

3.6 For other purposes notified while collecting the User’s Personal Data or other relevant purposes

3.7 The Company shall not use or disclose the User’s Personal Data unless it is used or disclosed as necessary for the purposes specified above, or is disclosed to Company personnel or contractual parties or to take legal action, or government agencies, or regulatory agencies, or with the User’s consent

4. Persons Who May Receive Personal Data Collected

4.1 Partners of the Company and employees of related companies

4.2 Authorized representatives of the Company in offering products and services of the Company including the contractor representatives

4.3 Other persons including agents or contractors who deal with the Company’s products and services in the organization of marketing activities, presentation of Company information including improving the quality of the Company’s products and services, such as accepting payments, preparation of information, documents, technology systems, document transmission, and research

4.4 Condominium juristic persons or housing development juristic persons and/or condominium management or housing development management

4.5 Government agencies or regulatory agencies, or any person to whom the Company must disclose information under laws, regulations, orders related to the Company or according to agreements the Company has with government agencies or any other person

5. Data Security

5.1 The Company uses Secure Socket Layer (SSL), a security standard for information transmitted over the internet including entering encrypted data and establishing a firewall using Secured Socket Layer (SSL), a technology for entering data through a code. This is for protection against data trapping as it is transmitted over the internet. Entering the data through this code makes it impossible for interceptors to understand the meaning of the data. This technology is also used for verifying the authenticity of websites.

The Company shall regularly improve and test its technology systems to ensure the highest and most reliable security of Personal Data. The Company reserves the right to change the security tools if the Company sees that such technology has a higher level of security maintenance.

5.2 In the case where the Company has made an agreement with a third party to develop and maintain the system and the allocation of resources or services on behalf of the Company, such third parties who carry out work for the Company or act on behalf of the Company must agree to maintain Personal Data security.

6. Personal Data Owner rights

6.1 The Personal Data Owner has the right to request access to, and a copy of, the Personal Data collected and which is under the control of the Company. The Personal Data Owner may request disclosure of the receipt of Personal Data for which consent has not been given, except for the protection of the Personal Data Owner or the rights and freedoms of other persons, which is contrary to or inconsistent with the provisions of the law or court orders, or other cases as specified by law.

6.2 The Personal Data Owner may terminate the Company’s use or disclosure of Personal Data for which consent has not been given. After termination, the Company may not be able to offer services as specified. However, the Company may keep Personal Data in order to check the provision of services, or to carry out legal proceedings. The Company shall not use Personal Data for other purposes.

6.3 In the case that the Company fails to maintain Personal Data security as required by law, the Personal Data Owner may request the Company to destroy, delete or temporarily suspend use or convert Personal Data into anonymized form.

6.4 Any other rights as specified by law, such as the right to amend Personal Data, suspension of use of Personal Data, and the right to object to the processing of Personal Data with certain reasons.

6.5 The Personal Data Owner may exercise the rights above by notifying the Company through the Call Center at 1246. The Company shall consider and notify the Personal Data Owner of results of the request within 30 days from the date the request is received.

7. Marketing and promotion

• In the event that the Company sends information about marketing and promotion including products, services and businesses that are of interest, if the User has agreed to receive such information and wishes to terminate receipt of such information, the User may notify the Company through the Call Center by calling

8. Exceptions to Personal Data Maintenance

• The following are not considered actions in violation of the Personal Data Maintenance Policy, such as

8.1 Personal Data that has already been disclosed to the public at the time of disclosure to the Company, or has been disclosed to the public without the fault of the Company

8.2 Disclosure of Personal Data with consent, whether in writing or consent by any other means

8.3 Disclosure of Personal Data as necessary according to laws, orders, regulations, court orders, government agencies, or according to any other necessity

9. Personal Data Collection Period

• The Company shall keep Personal Data for as long as necessary for the purpose of providing services or carrying out the specified objectives.

10. Improvements to Personal Data Maintenance Policy/ Contacting the Company

10.1 The Company may make amendments to details regarding the Personal Data Maintenance Policy in whole or in part. If such amendments are made, the Company shall update the Personal Data Maintenance Policy on the website.

10.2 Users may express their opinions on the Personal Data Maintenance Policy at “Contact Us.” Users agree that the Company’s discretion is final.