This privacy policy applies to personal data of all customers, suppliers and other third parties collected by True Space Company Limited (“the Company”). When developing and updating our privacy program, we consider global and domestic principles, Laws that have been in effect and frameworks, including The Personal Data Protection Act B.E. 2562 (2019) (PDPA).

“Personal Data” means any information relating to an identified or identifiable natural person, directly or indirectly, but not including the information of the deceased persons in particular.

The personal data that we will collect related to our services, whether now or in the future, includes but is not limited to:

• Identification information (e.g., name, surname, title, date of birth, gender, nationality, photograph, image and identification number, unique device identifiers, geolocation, job title, information obtained from registration for membership, etc.);
• Contact information (e.g., home address, telephone number, email address);
• Usage and service behavior information of the Company and/or the companies in the True Group* and business partners of the Company and/or the companies in the True Group and True including the usage of network service or products related to the services;
• Information about the use of the Company’s service (e.g., the use of conference room, the participation in training, seminar or enhancing skill activity, etc.);
• Information about your device when using our service, including your device’s IP address, model information and device settings, network information used;
• Service behavior information including the history of using our services and products;
• Financial information (e.g., payment transaction, credit card number, and bank account number);
• Information about the use of the Company’s information technology system;
• Records of service usage to improve the quality of services and/or to resolve the service issues (e.g., information of recording security cameras, records of photo via electronic media or other medias, etc.);
• Service information necessary for specific customer groups (e.g., customers with visual impairment, and/or hearing impairment, etc.);
• Certain information required to comply with law, or requests from law enforcement agencies and/or court orders.

We may obtain your personal data through one of the following means:

• The Company receives personal data directly from you, where the Company will collect your personal data from various service processes including:
  • When you sign up for one of our services or when you receive one of our services, this includes processes of filling the request to exercise your rights;
  • When you voluntarily respond to our survey or email or any other means (e.g., Short Message Service – SMS, etc.);
  • When you use our products and services including telecommunication networks or products related to the Company’s services. We collect required information to support you (e.g., telephone number, calling time, data usage, service quality monitoring, including your location when using the service etc.);
• Information that we collect from other sources:
  • We may receive personal data about you from third parties, such as the hirer company that you are an employee, which are allowed to disclose your information by your consent under applicable law, including the companies in the True Group, agents and subcontractors. These third parties include but not limit to business partners, sub-contractors that help the Company to process the application and provide services by email, phone or document in which the disclosure person has the right to provide personal information lawfully or to be informed through various service processes in the Company that collects the information itself as described above.

We may collect, use, disclose and/or process your personal data for one or more of the following purposes:

• to fulfill the service contract agreement, enforce our terms of service and provide your use of services and/or access to the Site;
• to provide services, such as seminar, guidance, or to provide facilities, such as information technology, conference room;
• to administer our services for internal operations, including troubleshooting, network management and improvement, network optimization, and facilitating payment services;
• to conduct research, analysis and development activities, behaviors of yours using products and services to create a database and to provide services (including, but not limited to, data analytics, surveys, technology development and/or profiling), and to offer you with better products or services and/or benefits of the Company and/or of the companies in the True Group or business partners of the Company and/or the companies in the True Group;
• to inform and offer privileges, information, promotions and offers relating to application, buying or selling products or services of the Company and/or together with the companies in the True Group and/or business partners of the Company and/or the companies in the True Group;
• to apply or activate the services relating to application, buying or selling products or services of the Company and/or together with our affiliates;
• to carry out our marketing analysis, plans and activity campaigns of the Company and/or together with the companies in the True Group and/or business partners of the Company and/or the companies in the True Group;
• to prevent or suppress a danger to a person’s life, body or health;
• to comply with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction and/or any other necessity for the legitimate interests of us;
• as the purposes for which the applicable law allows us to collect, use, disclose and/or process your personal data without your consent;
• to use for identification and/or verification in registering our services;
• to identify verification for entering buildings or places;
• to facilitate service payments related to product and service usages or purchases;
• to provide after sales services, respond to your questions/concerns, facilitate any enquiries, suggestions, requests or complaints in respect of our services, compensation and resolve the issues;
• to research, monitor and analyze customer use of our network, products and services on an anonymous or personalized basis, in order to identify general trends, improve our understanding of our customers’ behaviors;
• to notify you of updates or announcements from the regulator and government agencies;
• to manage and fulfill your orders, send you invoices and purchase orders, notify the payment, prepare the receipts and tax invoices, collect payment for our services, or ask for payment;
• to protect and keep our services and network secure, and monitor the customer activities, to protect your personal safety and rights, safety of others and the Company;
• to protect and keep our place of business and True retail shop & service stores secure (e.g., closed circuit security cameras for safety and crime prevention).

After receiving personal data from various data sources, the Company will collect, use or disclose your personal data for the purposes specified in the previous session and will process your personal data only to the extent permitted by law. That is, it is based on a lawful basis for processing the data.

The Company has information security measure to maintain and the period of retention of your personal data as follows:

• Collection characteristics: We keep your personal data either in printed paper (hard copy) or in electronic document system (soft copy) with appropriately secured measures to prevent the loss, unauthorized access, change, and disclose of your personal data.
• We manage to put in place procedures to deal with any suspected personal data breaches. In case of substantiated complaints concerning breaches of customer privacy and losses of customer data, our security team will immediately investigate to solve the case.
• Retention period: We will not keep your personal data for any longer than we seem necessary for the purposes for which we collect and process it, or within the effective period of contract, or within the period of the exercise, or defense of legal claims.
• When your personal data for which we collect, use and process it, is no longer required for the purposes and by applicable laws, we will erase or destroy or aggregate and/or anonymize your personal data to an extent that it no longer identifies you within a reasonable time.

When the provision on the rights of the personal data subject under the Personal Data Protection Act B.E. 2562 comes into effect, you, as the data subject, have the following rights in relation to personal data:

• Right to withdraw consent
  • When you give us your consent for the specific purposes, you have the right to withdraw the consent for your specific purposes at any time, unless there are restrictions on legal rights or in connection with the contract that benefits to you.
  • You have the right to withdraw the consent about processing your personal data at any time that your personal data is with the Company.
  • If exercise the right to withdraw consent prevents the Company from delivering products or providing some services to you, the Company will inform you about the effect of withdrawing the consent.
• Right to access (or “Rights to be informed”)
  • You have the right to request access to and obtain copy of your personal data to and obtain which is being processed by us.

• Right to data portability
  • You are entitled to request us to send or transfer your personal data to other data controllers or directly receive your personal data for some reasons. However, the right to data portability applies only to the personal data that you submit to the Company and the collection, use and/or disclose of such personal data is done with your consent or where such personal data is necessary to be collected, used and/or disclosed in order to fulfill its obligations under a contract.
• Right to object
  • You have the right to object to the processing of your personal data for some reasons.

• Right to erasure
  • You have the right, in certain circumstances, to request the erasure of your personal data which is being processed by the Company.

• Right to restriction of processing
  • You are entitled to have the right, in certain circumstances, to restrict the processing of your personal data by our Company.

• Right to rectification
  • You have the right to ask for any inaccurate personal data held or processed by us to be corrected, and any incomplete data to be completed. For those inaccurate personal data or incomplete personal data, we will investigate and correct them.
  • Where a request to rectify inaccurate personal data is received, we may, in some circumstances, request you to provide proof of your identity or to provide additional documents and/or required information.

You may contact the staff of the Company to file a request to proceed with the above rights, as detailed in section 1, or contact designated channels specified by the Company. However, you do not have to pay a fee to use your rights. However, a fee may be charged accordingly if your request is found to be unfounded, repetitive or excessive.

The Company is legally obligated to collect personal data or in order to make a contract between you and the Company. If you choose not to provide personal data, the Company may not be able to provide services to you.

During the period you are using our services, the Company will send you information about marketing activities and campaigns about products and services of the Company including the companies in the True Group and/or business partners of the Company and/or the companies in the True Group, including Charoen Pokphand Group, advertisers as well as business partners which you will be interested in. If you want to withdraw the consent for being informed marketing communications, please contact our designated channels described in section 1 or specified by the Company.

During any use of the Company’s website Information relating to your access to this website will be saved in the form of a cookie. This cookie policy describes the meaning of functional cookies, their purposes. And how to delete cookies for your privacy by accessing our website, you consent to our use of cookies in accordance with the cookie policy detailed below.

• What are cookies?

Cookies are text files which are stored on a user’s computer and/or communication devices that you use, such as tablets and smartphones, via a web browser while you enter the Company’s website. Cookies will not cause harm to your computer equipment and/or communication devices. They used to store detailed log data, internet usage or your website visit behavior. You can learn more about cookies from https://www.allaboutcookies.org/

• How the Company uses cookies?

The Company will collect website information from all visitors through cookies or similar technologies and will use cookies for the purpose of improving the efficiency of accessing and using the Company’s internet services. The company collects cookies for the following purposes:

• To study the behavior of your website usage and to develop company websites to be able to use easily, quickly and more efficient;
• To enable you to sign in to your account on the Company’s website;
• To protect you from fraud and improve security;
• To analyze products and services, and offers of the Company products that may be relevant to you;
• To improve the marketing that you see on social media, applications and other websites.

You can refuse the collection of information via cookies through your browser settings, which may reduce the optimum performance of the website and application.

With the nature of the services including the products of the Company, the Company may collect, use or disclose personal data about individuals under 20 years of age. The Company will comply with the Personal Data Protection Law in connection with the processing of minors’ personal data. This includes requesting consent from legal representatives or a person using parental power as prescribed in accordance with the Personal Data Protection Act B.E. 2562.

The Company will process the personal data under the law applicable at present and the Company is entitled to continue to collect and use the personal data which has been collected prior to the effective date of provisions relating to collection, use and disclosure of personal data of the PDPA for the existing purposes. If you no longer want the Company to collect and use such personal data after the PDPA is fully effective, you may withdraw your consent through the channels to be further publicized by the Company.

This privacy policy is only applied to our products, services, and our websites. However, it may contain links to third party websites and services. We have no control over how third party websites and services process your personal data, and we are not responsible for such third party websites and services or their privacy practices.

The Company will update and alter this Privacy Policy from time to time to be compatible with the changing laws, regulations or operational requirements. In this regard, the Company reserves the right to change this policy on the website or any channels without prior notice.