Data Privacy Policy and Notice

1. Introduction

                Siam Wellness Group Public Company Limited and the Subsidiary Companies (hereinafter referred to in this policy as The “Group”) recognizes the importance of protecting the personal information the Group receives from the data subject. According to the Personal Data Protection Act B.E. 2019, therefore, this policy has been prepared to announce and clarify the collection, use, transfer or disclosure of personal information to the data subject and related agencies to know and understand, Rights and duties of the Group and of the Personal Data Subject as required by law

2. Definition

“Group” means Siam Wellness Group Public Company Limited and the Subsidiary Companies incorporated in Thailand such as Siam Wellness Lab Co., Ltd., Siam Wellness Resort Co., Ltd., Siam Wellness Education Co., Ltd. and Tiger Eyes Trading (Thailand) Co., Ltd.

“Personal Data Protection Law” means the Personal Data Protection Act B.E. 2019, including the relevant ministerial regulations, announcements and regulations (secondary laws) and which will be amended in the future.

“Personal Information” means any information about an individual that enables that person to be identified either directly or indirectly, but does not include the information of the deceased, especially in accordance with the law on protection of personal data and does not include information of legal entities.

“Sensitive Data” means personal data about race, ethnicity, political opinions, cult religion or philosophy, sexual behavior, criminal records, health information, disability, trade union information, genetic data, biological data, or any other information similarly affecting the subject of personal data as the personal data protection law stipulates.

“Data Subject” means the subject of personal data that the Group perform personal data processing including but not limited to customers who come to use the service, customers who purchase products and products, partners, contract parties, employees, consultants, directors, teachers, personnel of the Group, service partner, Students who come to study in a massage school, Shareholder of the group of companies, Visitors, agents and any person involved in the operations of the Group.

“Processing” means any processing of personal data whether it is collected, used, transferred or disclosed; including recording, organizing, modifying or altering, etc.

“Personal Data Controller” means a person or a juristic person who has the authority to make decisions about the collection, use or disclosure of personal data.

“Personal Data Processor” means a person or a juristic person who performs the collection, use or disclosure of personal data on the order or on behalf of the Personal Data Controller.

3. Personal data to be collected

3.1 The subject of personal data that the Group will collect, use, transfer or disclose is the following information subject:

3.1.1 Customers who are individuals who use the service including customers who come to use spa services, massage for health or massage for beauty regardless of any brand of the Group.

3.1.2 Individual customers who purchase products and any products of the Group including purchasing/ordering a Voucher from the Group of Companies.

3.1.3 Service users and patients who come for treatment in the Group’s physical therapy clinic.

3.1.4 Partners, contract parties, professionals and those involved in dealing with the Group; such as buyers, sellers, suppliers, procurement staff, service providers, contractors, consultants, professionals and others likewise.

3.1.5 Personnel who work for the Group, whether they are employees, consultants, teachers, trainers, directors of the Group receiving salaries, wages, benefits or any other compensation from the Group and includes family members of the Group’s personnel.

3.1.6 Partners refers to a service provider of health massage or massage for beauty purposes according to the SPA Act B.E. 2016 who come to provide services to the group of companies and includes family members of that service partner.

3.1.7 Students applying for and/or enrolling in courses and training for teaching and learning massage therapy with the Group.

3.1.8 Shareholders of the Group of Companies under the law governing Limited Companies, Public Limited Companies and Securities and Exchange Laws.

3.1.9 Applicants who wish to work with the Company and has contacted or submitted an application or personal profile details to the Group either by contacting or submitting to the Company directly or by contacting or submitting through representatives of the Group and includes persons in the applicant’s family and the reference person (if any).

3.1.10 Individuals who apply for any membership with the Company such as WellnessMe Loyalty Program etc.

3.1.11 Website visitors, service recipients, people interested in products and services and any other person contacted to request information, order, train or obtain services from the Group. including those who come in contact for any purpose, whether through electronic media or enter the building of the Group.

3.2 The Group will collect your personal data or information obtained from you as follows; Such collection depends on the relationship between the Group, Data and the context and type of information.

3.2.1. Your personal data, such as first name, family name, age, gender, photograph, date/month/year of birth, ID card number, Passport number or copy of driver’s license, face information, fingerprint, weight, height, signature, nationality, marital status, military service information, the information that appears in Related licenses including family member.

3.2.2 Contact information, including residential address, both used for contact and address according to the house registration, Phone number, E-mail, social media contact information (Social media), Location maps of homes, residences, and workplaces including contact information in case of emergency.

3.2.3 Financial and securities information, such as bank account numbers, prompt pay account numbers, credit card numbers, Securities holder registration number, share certificate number and information about various taxes.

3.2.4 Information about education, training and work, including education and training history, Certification of qualifications or academic transcripts, Result or grade (transcript) level of education, language proficiency, Professional license information, registration number including the renewal of registration duty information, Training and testing information provided by the Group or other relevant agencies, diplomas or certificates, Work history, achievements, salary or wages.

3.2.5 Employment Information work history, academic history, Employment history, including date of commencement, resignation, dismissal, information that appears on the job application, Tax Identification Number, social security card number, work permit forms and results of various assessments, Employment agreements, salary and other compensation.

3.2.6 Information about your use of goods and services, Product selection information, Information on completing a questionnaire or assessment before using the service, Information on modifications or corrections to other goods and services, Follow-up and feedback on product and service satisfaction, Complaints about the use of goods and services, membership card including any other personal information you provide as part of providing services or satisfying customers.

3.2.7 Sensitive personal data, such as ethnicity, religion, criminal history, various health information (such as congenital disease, aches, pains, injuries, history of surgery history of allergy to medicines, creams or other chemicals), health examination results, disability, biological information (eg fingerprint data, face dummy data), health insurance claim data, work evaluation results, job interview results, Disciplinary history data and teaching test results including case collection data of health massage students.

3.2.8 Information about usage and login of the group of companies, such as registration information for membership via online ordering information and booking services online with the Group Information on completing a questionnaire or assessment before using the service, Online job application information, Information obtained from your follow-up or contact with the Group of Companies.

3.2.9 Technical information, This includes information about your use of the Group’s websites and systems, Computer traffic data (Log) Information from usage logs such as device identifiers, computer IP address, Device ID, Device type, mobile network data connection information, geographic location information, Type of browser (Browser) log information, Information of applications or websites that you access before and after (Referring Website), records of system usage history, Login Log, Transaction Log, Customer Behavior, Login Statistics Access Time, The information you searched for, Use of system functions and information that the Group collected through cookies (Cookies) or other similar technologies.

3.2.10 Video and audio recording data, including video and/or audio recordings via CCTV (CCTV) or any device capable of recording images and sounds. It will store information such as face data, Movie data that appears on the CCTV including photos of car registrations, etc. Photos related to the use of goods and services dialogue, Evidence of access to the service, interview, training, teaching, Entering and exiting the premises of the Group.

3.3. Methods for collecting and obtaining your personal data

3.3.1 Collect and obtain personal information directly from you. The Group will collect and receive personal information from you directly from any channel in connection with the Group’s business operations; All types of transactions, applications, comments, criticisms, complaints, communication in any form including contacting or entering the building of the Group Video and audio recording through CCTV (CCTV).

3.3.2 Automatically collects and obtains personal information from you. The Group may collect your personal information electronically. from your access to the Group’s systems such as websites, browsers, or any system by using cookies and other similar technologies.

3.3.3 Collect and obtain personal information from you from other sources. The Group may obtain your personal information from other sources. such as relevant government agencies, including but not limited to Ministry of Public Health, Ministry of Education, Social Security Office, Department of Skill Development, Revenue Department, Stock Exchange of Thailand, Securities Depository, Securities and Exchange Commission, Insurance company, Insurance agent, Group personnel, applicants, contractual parties and professionals, service providers, etc., including public information.

                In this regard, when collecting such personal data, you will be informed from the Group about the Personal Data Protection Policy i.e. your rights, purpose of collection, legal base, and if it is required by law to be obtained with your consent. The Group will always seek your explicit consent prior to the processing of your personal data.

                In the event that the Group of Companies received or collected your personal data before 1 June 2022. The Group will process that personal data as required by law.

4. Legal bases and consent for collection, use, processing and disclosure of personal data

                The Group will collect, aggregate, use, process and disclose your personal data within the framework required by law. or where the Group has your consent. which is based on the following base

a. Legal base

4.1 It is necessary for the performance of the contract of the Group to which you are a party or subject to your request prior to entering into that contract (Contract Basis).

4.2 It is in compliance with the laws of the Group (Legal Obligation).

4.3 It is necessary for the legitimate interests of a Group of Companies or of a person or entity other than Group of Companies, unless such interests are less important than your fundamental right to personal data (Legal Interest).

4.4 To prevent or suppress danger to life, body or health of a person (Vital Interest).

4.5 It is necessary for the performance of duties in the performance of duties in the public interest of the Group or to perform Duty to exercise state powers granted to the Group (Public Task).

4.6 To achieve objectives relating to the preparation of historical documents or archives for the benefit of the public or in connection with research or statistics which have provided appropriate safeguards to protect your rights and freedoms. This is to be in accordance with the law (Research).

b. Consent base

                Consent you have given to the Group in the event that exceptions or references to the legal bases specified in section A above cannot be relied upon, unless the Group has solicited your specific consent for any Personal Data, the Group will process your Personal Data only for the purposes for which the Group has provided and with your consent. and if the Group will process any personal data that is your sensitive data. The Group may only do so as required by law or with your express consent.

5. Purpose of collection Use and disclose personal information under the law or with your consent.

                The Group will process your personal data. For the following purposes, details are as follows:

Purposes and legal bases used for processing	Details
5.1 For providing services to the group’s customers Legal bases used for processing pursuant to Section 4.1 – 4.4 and/or Consent Bases.	Health massage service, Massage for beauty, other spa services, onsen  – Receiving reservations, calling to confirm or postpone access to the service, Screening for diseases or prohibited characteristics before using the service as required by law, Providing massage services for some people who report aches or symptoms in the area to be massaged, Receiving payments that are not paid in cash, Refunds, Refunds to you in case of necessity or force majeure, Collection of user data for customer satisfaction, such as delivery of goods and gifts, etc., To listen to any feedback or assess satisfaction and for the legitimate interests of the Group. – The exercise of the Group’s rights, including the action required by law, Exercise of rights under the insurance policy of the group or your necessary litigation of the Group.  – For use in invoicing, Receipts, Tax Invoices and/or other financial documents as well as complying with the accounting standards.  Hotel Service; Hotel reservations, Meeting rooms, Banquet rooms, Restaurants, Registration of stays, Validation providing services in hotels such as Table Reservations, Swimming pools, Fitness Centers, etc. Use for the Group’s Lawful Interest  – The exercise of the Group’s rights, including taking action as required by law, The exercise of rights under the insurance policy of the Group or your necessary litigation by the Group.  – For use in invoicing, Pay service fees, Deposits, Issue receipts, Tax Invoices and/or other financial documents as well as complying with the accounting standards.
5.2 For selling products and products to customers of the company Legal bases used for processing pursuant to Section 4.1-4.3 and/or Consent Bases.	– Reservation, Quote, Promotion Offering, Buy, Sell, Deliver of goods and products, Providing you with information about the products and how to use the products and products of the Group including contacting for details for such purposes and using information to satisfy you such as sending various gift vouchers. and for the legitimate interests of the Group. – Entering into the contract, performance of the contract and any actions in accordance with the contract and the law Monitoring and Enforcement of Contracts and Laws Exercise of the Group’s rights and any necessary litigation. – for use in invoicing Receipts, Tax Invoices, and/or other financial documents as well as complying with the accounting standards.
5.3 For treatment and providing services to visitors to use services in a physical therapy clinic. The legal bases used for processing are subject to Section 4.1-4.4 and/or Consent Base.	– Accepting appointments to come to use the service and receive treatment including the next appointment to register the patient’s history, Making a medical registration, treatment, recording a registration of treatment as required by law. Issuing a medical certificate for your follow-up treatment and taking action for the legitimate interests of the Group. – The exercise of the Group’s rights, including taking action as required by law, Exercise of rights under the insurance policy of the Group or your Necessary litigation of the Group. – For use in invoicing Receipts, Tax Invoices, and/or other financial documents as well as complying with the accounting standards.
5.4 For entering into a contract and complying with contract with partners of Group companies Legal bases used for processing pursuant to Section 4.1-4.4 and/or Consent Bases.	– For the purpose of recruiting, inspecting, selecting and recording you as a contracting party with the Group, Entering into the contract, performance of the contract and any actions in accordance with the contract and the law. Applying for various licenses necessary for doing business, Monitoring and Enforcement of Contracts and Laws including the case of termination of the contract for the legitimate interests of the Group, Exercise of the Group’s rights and any necessary litigation. – For use in making payments Payment of goods, wages, compensation, invoicing Receipts, Tax invoices, withholding documents and/or other financial documents as well as complying with the accounting standards
5.5 For managing the personnel of The Group including employees, consultants, trainers and directors of the Group. Legal bases used for processing pursuant to Section 4.1-4.4 and/or Consent Bases.	Employees, Consultants, Trainers and Directors in the Group of Companies – For entering into an employment contract, performance of the employment contract with you, employment, termination of employment, management of foreign workers, disabled workers, Personnel Management Execution as commissioned. This includes compliance with the rules, regulations, discipline, announcements, orders and work regulations of the Group. Management of safety, occupational health, welfare and working environment, Skill development, inspection, investigation, compliance with contracts, rules, regulations, discipline, announcements, orders and regulations of the Group including as required by law. Performance evaluation, photo recording, Record audio and video, Voice recording of conversations, termination of employment, post-contract actions including litigation in accordance with the rights and duties of the parties. Execution of subpoenas or to comply with the law. – To comply with the law such as labor protection laws, Labor Relations Act, Social Security Act, Act on the Promotion and Development of Labor Skills Acts in accordance with the law relating to the request and employment of foreigners, Applying for a work permit for an alien or other relevant laws, Compliance with any rules and regulations of relevant agencies such as the Department of Labor, Protection and Welfare, Department of Skill Development, Department of Employment, Social Security Office, municipality, etc. – To apply for a license necessary for the business of a Group of Companies as required by law, such as a license for a spa establishment and health massage, Clinic license, hotel license etc. – For any administration related to the Social Security Fund, Provident fund, Compensation fund, Fund for Promotion and Development of the Quality of Life of Persons with Disabilities and Other Funds of the Group. – To manage welfare such as Group health insurance, medical expense reimbursement, Insurance money in case of injury or death, including keeping a history of illness, Welfare management; such as borrowing money from financial institutions or employers, etc. Training of group companies or government and private agencies, equipment supply, Facilities upon employment and welfare provided by the Group. – To administer the payment of salaries, taxes, compensation or other benefits to you upon employment; This includes keeping and recording records in accounting and taxation, withholding taxes, issuing payrolls. Salary slip including other tax and financial documents Director – In order to comply with the Civil and Commercial Code Company Partnership Act, Public Company Act, Securities and Exchange Act and other relevant laws, including rules, regulations, orders, announcements issued by relevant agencies such as the Stock Exchange of Thailand and the Securities and Exchange Commission. – Registration and applying for various licenses of the group of companies. Teacher, Trainer – For compliance to Private School Act or other relevant laws, including rules, regulations, orders, announcements issued by relevant agencies such as the Ministry of Education, Ministry of Public Health, Department of Skill Development, etc. – Requesting for teaching courses, including asking for permission to modify, Change the course of teaching, Teaching evaluation, history making, recording of teacher registration information, Appointment withdrawn report preparation, Conclusion of the test results and any action required by law.
5.6 For the selection, entering into contracts, management, training and performance of contracts and laws relating to health massage partners. Legal bases used for processing pursuant to Section 4.1-4.3 and/or Consent Bases.	– For the recruitment and selection as a service partner with the Group of Companies, disease examination and history, Entering into service contracts and training contracts, Management and compliance with service and/or training contracts, borrowing massage equipment, Massage evaluation including massage skills, allowing customers to make reservations for the next service, Entering and exiting establishments and providing services in health establishments in each branch of the Group. Adjustment of your posture at the Group massage school, Termination of a service or training contract and actions after the termination of a service and/or training contract. – For receiving the power of attorney to register as a service provider, Applying for a health establishment license to relevant agencies, Compliance with the Health Establishment Act and other relevant laws. – For the payment of compensation and any other benefits including the exercise of rights under your insurance policy, Entering into a contract of rights between the Group and you. – To be used to issue evidence of compensation for joining the service including withholding documents and other financial documents to you.
5.7 For use in recruiting and training courses teaching Students attending and training in a health massage course Legal bases used for processing pursuant to Section 4.1-4.3 and/or Consent Bases.	– For enrollment, apply for training, entering into a training contract, teaching registration and training, compliance with a training contract, actions related to teaching and learning, organizing exams, issuing scores, collecting and delivering documents for exams to enhance your labor skills as required by law, evaluation, testing, announcement of exam results issuing certificates, diplomas, certificates, and substitutes, Record audio and video Registration and student accounts, report preparation, test summary, Termination of the training contract, Actions after the end of the training contract including litigation in accordance with the rights and duties of the parties or to comply with the law. – For the purpose of compliance to Private School Act or other relevant laws, including rules, regulations, orders, announcements issued by relevant agencies such as the Ministry of Education, Ministry of Public Health, Department of Skill Development, etc. – For use in invoicing Receipts, Tax Invoices, and/or other financial documents as well as keeping and recording for the purpose of accounting data.
5.8 For use in the performance of the rights and duties of The group of companies to the shareholders Legal bases used for processing pursuant to Section 4.1-4.3 and/or Consent Bases.	– In order to comply with the Civil and Commercial Code Company Partnership Act, Public Company Act, Securities and Exchange Act or other relevant laws, including rules, regulations, orders, announcements issued by relevant agencies such as the Stock Exchange of Thailand and the Securities and Exchange Commission. Examination of the right to attend the shareholders’ meeting, shareholder meeting voting, receiving dividends, Notification of the list of shareholders of the group of companies to relevant agencies request for replacement of share certificates and the request to exercise the right as a shareholder including any action required by law.
5.9 For recruiting personnel of the group of companies Legal bases used for processing pursuant to Section 4.1-4.3 and/or Consent Bases.	– For application, nomination, consideration of qualifications and your selection, photo recording, Record audio and video Record, your conversations including disease and history checks to recruit, appoint or hire you as an employee, employee, student intern or personnel within the organization and for other administrative purposes that may be beneficial to you, such as contacting you to work, Sending job information, Apply for an internship including in the event that you are not selected. The Company may retain your information for calling you back for a new interview or for a job in the same position or other position that the Group deems suitable for you within the period. enough time. – To improve and develop the applicant selection system, Consideration of the manpower rate of the Group of Companies, public relations and for the legitimate interests of the Group.
5.10 Subscription or benefits with group of companies Legal bases used for processing pursuant to Section 4.1-4.3 and/or Consent Bases.	– Apply for membership applications such as WellnessMe or other group benefits such as cash card issuance or the purchase of massage vouchers, Applying an onsen membership card, etc. For the Group to send you information about the Group including receiving benefits, Examination of the use of various benefits that have been made with the Group, Verification of identity to claim any rights with the Group, The information about your use of the service will be collected in order to create satisfaction for the next service to you. and for the legitimate interests of the Group. – For use in invoicing Receipts, Tax Invoices, and/or other financial documents as well as keeping and recording for the purpose of accounting data.
5.11 Providing information and answering questions to you Legal bases used for processing pursuant to Section 4.1-4.3 and/or Consent Bases.	If you come to the Company or a branch of a Group of Companies, call to visit the website of the Group of Companies or come to inquire, press follow news or make a reservation for goods and services through the information systems of the Group such as Line, Facebook, Wechat, etc., the Company will process your personal information for providing information. Answer questions or take action as you wish. The Company may record your browsing data using cookies. However, the company will ask for your consent in such matters first.
5.12 For security The legal base used for processing in accordance with Sections 4.2-4.4 and/or the Consent Base.	– For the development of safety standards in the service and use of the service, Management and protection of information, technology infrastructures such as the provision of Wi-Fi services in the Group’s workplaces. In this section, the group of companies Encryption may be performed for security and verification purposes. – To control access to the building, parking lot and to ensure that each building establishment and the area of the Group is safe for you and visitors and their property, as well as, for the security of any information located or stored in the premises of the Group whether in document or electronic form. To monitor and observe the entrance and exit of the building, the place, the parking lot that is secured, protected room, Warehouse premises, server rooms and other areas (collectively, “Buildings and Premises”) to prevent entry and exit of the Group’s buildings and premises. and to prevent, detect and investigate security-related incidents such as theft, assault fire or other disaster. – For recording photographs, video and/or audio via CCTV (CCTV), video and audio recording of you and all persons including their property, such as vehicles, which enter the area under surveillance within or around the buildings, premises and facilities of the Group in order to protect life and assets to be safe including protection. Protect the premises facilities and the assets of the Group to be safe as well as to provide support and assistance to law enforcement agencies in the investigation, investigation, prevention, suppression and prosecution of both civil and criminal cases and actions to prevent potential crimes and/or to assist in the resolution of disputes arising in disciplinary proceedings or grievances including labor litigation. However, the Group will have a CCTV warning sign indicating that the CCTV camera is being used in the area as well.
5.13 For other purposes that the Group notify you at the time personal data is collected Legal bases for processing Consent base	The Group will notify you of any other purposes that cause the Group to want to use your personal data in addition to the purposes stated above or when the Group wishes to have a change to the original purpose set or when the Group is necessary to obtain your consent for the specific processing of personal data. By contacting you through the contact information you have provided to the Group.

In the event that the Group of Companies will use your personal data for purposes not listed above The Group will provide additional Privacy Policy Notices to explain the use of information for such purposes. You should read the additional Privacy Notice in conjunction with this Privacy Policy.

6. The necessity of entering into a juristic act and possible consequences of not providing information

Due to your personal information at the Group of Companies, Processing will be carried out for the purposes stipulated in Article 5 above, which are necessary for entering into a contract, providing services, complying with the law or is acting according to your wishes where your personal information is necessary for the achievement of that purpose. If you do not provide such personal information to the Group, Failure to provide such information may prevent the Group from performing its obligations to you or fulfilling its obligations to achieve such objectives. or may not be able to enter into a contract with you or even may affect the law If this is the case, the Company Group may be obliged to refuse or cancel the service. entering into a contract or any obligations to you whether in whole or in part

7. External entities or personal data to which your personal data may be transmitted.

7.1 The Group may disclose your personal information under the objectives set out above and in accordance with the rules prescribed by law to the following agencies and persons:

            7.1.1 Companies belonging to the Group of Companies This includes employees, staff, consultants, directors, managers, trainers, personnel or service associates of the Group. Relevant and necessary (need-to-know basis) for the processing of your personal data.

            7.1.2 Government agencies and other relevant agencies with which the Group must disclose your personal data. for the purpose for legal or other important and necessary purposes such as the Department of Health Service Support, Department of Labor Protection and Welfare, Department of Skill Development, Department of Employment, Social Security Office, Immigration Office, Municipality, Department of Provincial Administration, Royal Thai Police, Revenue Department, Department of Business Development, Department of Intellectual Property, Ministry of Education, Stock Exchange of Thailand and Securities and Exchange Commission, etc.

            7.1.3 Organizations requesting disclosure by virtue of law, such as the Department of Health Service Support, Stock Exchange of Thailand and Securities and Exchange Commission, etc., or requests for information to be used in connection with the judicial process. prosecution, litigation by virtue of law from relevant agencies such as the Royal Thai Police prosecutor’s office or the court

            7.1.4 Partners, business partners, service providers, service recipients, contractors, contractors, contractual parties and personal data processors employed by the Group. or assigned to perform, manage, take care of and take responsibility according to obligations to each other including but not limited to contractor, freight forwarder, shareholder meeting, organizer, accountant and auditor, internal auditor, Human Resources Manager, person in charge of security, Management or service providers, developing information technology systems for use in the business of the Group such as personnel management, financial accounting, marketing and customer-related operations, etc., or providing any other services that may benefit you.

7.2 Disclosure of your personal information to other parties will operate under the specified objectives or other purposes as required by law to do so only In addition, if the law requires your consent for the transmission of information. The Group will obtain your express consent.

7.3 In the event that the Group disclosing your personal information to other parties, the Group will take appropriate measures to protect the personal information disclosed and to comply with personal data protection standards and duties as required by the law on personal data protection

8. Transferring your information abroad

In the event that the Group will send or transfer your personal data abroad, The Group will monitor and take steps to ensure that the destination country or international organization that will receive your personal data has adequate personal data protection measures or the transfer of your personal data is a case that is exempt from personal data protection laws, including that you have given your consent to the transfer of your personal data abroad.

9. Period of retention of personal information

The Group will retain your personal data for the period necessary to fulfill the stated purpose of processing that personal data. The retention period of personal data will vary depending on the purpose for which it was collected. and process that personal data.

In addition, the Group will keep your personal information in order to comply with applicable laws, rules and regulations. taking into account the business practices for each type of personal data such as accounting information Customer relationship management Processing of legal claims or relevant authorities that have been requested, etc.

10. Personal Information of Minors

Minors are not the Group’s main target audience. However, in certain activities, minors may be involved, and from time to time the Group may have to collect and process personal data relating to individuals under the age of 20. Therefore, the Group will comply with the personal data protection laws in relation to the processing of personal data of minors. This includes seeking consent from a legitimate representative or an authorized person as required by the law on personal data protection.

11. Rights of the Personal Data Subject

Under the provisions of the Personal Data Protection Law You should acknowledge that you have legal rights regarding the collection, use, disclosure and/or transfer of your personal data in the following ways:

11.1 Right to access personal data

You have the right to access your personal data and request that the Group make copies of such personal data for you including asking the group of companies Disclosing the acquisition of your personal information to the Group are collected, used and disclosed without your consent. To the extent permitted by the law on personal data protection.

11.2 Right to correct personal data

You have the right to request that your personal data be corrected. If your personal information is inaccurate, not current, not exhaustive or causes misunderstanding.

11.3 Right to delete, destroy personal data or make personal information anonymous

You may request the Group to delete, destroy or otherwise make your personal information non-personally identifiable. The exercise of such rights shall be subject to conditions stipulated by law.

11.4 Right to suspend the use of personal data

You have the right to request that the processing of your personal data be suspended in the event that the Group is in the process of verifying the correctness of the personal data requested by you. or in the event that you find that your personal information is inaccurate until it is corrected or when personal data that needs to be deleted or destroyed but you ask for suspension instead or the suspension of use is in accordance with the law.

11.5 Right to object to the processing of personal data

You have the right to object to the processing of your personal data at any time. and group companies will do so In the following cases

            11.5.1. By relying on the legitimate interests of the Group or a third party, or public interest. To process your personal data except in the case where the Group is able to demonstrate more important legal grounds or the processing of your personal data is in order to establish a claim. Compliance or Exercise of Claims, or

            11.5.2 It is the processing of your personal data for direct marketing purposes.

            11.5.3 Process your personal data for scientific research purposes.

historical or statistical, unless it is necessary for the operation of the Group’s public interest missions.

11.6 Right to transfer personal data

You have the right to obtain personal data about you in a readable or generally usable format with an automated tool or device. Including the right to request the transmission or transfer of your personal data in such form to another personal data controller or yourself unless by technical condition it is not possible This is possible as required by the law on personal data protection.

11.7 Right to withdraw consent

In the event that the group of companies relies on your consent to process personal data You have the right to withdraw your consent to the processing of personal data that you have given consent to the Group. at any time during the time your personal data is in the possession of the Group.

11.8 The right to lodge a complaint

If you have any concerns or questions about the processing of your personal data by the Group, please contact the group of companies. By using the contact details in Clause 16 (How to Contact the Group) below in the event of a violation of the Personal Data Protection Law. You have the right to file a complaint with the Office of the Personal Data Protection Commission.

The Group will use its best efforts to the capability of the relevant systems to facilitate and process your request without delay. unless it appears the fact that The processing of the request imposes an unreasonable burden on the Group or risks infringing on the protection of others’ personal data. or is against the law or in the event that it is impossible in practice upon request.

12. Security in keeping personal information

The Group has established and/or chooses to store personal data with appropriate mechanisms and techniques. and have security measures in accordance with the law on personal data protection and related laws including limiting access to your personal data that can only be accessed by those involved. To prevent your personal information from being used, disclosed, destroyed or accessed without permission. In addition, the Group also has a policy for internal and external parties concerned to be aware and aware of data retention and to take care of personal data to have security standards for personal data protection.

13. Links to the Website Third Party Products and Services

Group services; There may be links to websites, applications, products, products. and third party services. Such third parties may collect certain information in connection with your use of the Service. This Privacy Policy applies solely to the processing of personal data for the purposes established by the Group Companies. The security or privacy of any of your information collected by such third party websites, applications, products or services. Even if you click on the links displayed on the Group’s services, you should exercise caution and check the privacy policy. Privacy policies or notices of those third party websites, applications, products and services.

14. REVIEW AND CHANGES TO THIS PERSONAL DATA PROTECTION POLICY

The Group may from time to time make changes to this Privacy Policy. To comply with any changes related to the processing of your personal data and to comply with the changes in accordance with the provisions of the Personal Data Protection Law or other relevant laws. The group of companies will notify you of any material revisions by means of appropriate and feasible communication channels. However, the Group recommends that you review this Privacy Policy from time to time.

15. Governing Law

This Privacy Policy It is subject to the enforcement and interpretation of Thai law. and the Thai courts have the authority to decide any disputes that may arise or in connection with this Privacy Statement.

16. How to contact

If you have any questions about this Privacy Policy, or wish to exercise your rights as set forth in Section 11 of this Policy. Please use the contact form on the website at www.siamwellnessgroup.com. You can also contact the group of companies. through the Data Protection Officer of the Group by using the following contact details:

Email : [email protected]

Telephone : 02-641-6619 ext. 113

or

send mail to

Data Protection Officer, Siam Wellness Group PCL,

BU Place, 22nd Floor, No. 567 Soi Sutthiphorn, Pracha Songkhro Road, Din Daeng, Bangkok 10400

This announcement of Personal Data Protection Policy will be effective on June 1, 2022 or when the Personal Data Protection Law comes into force.