This privacy policy is to let you know how the Company collect, use and disclose personal data, as well as to identify the relevant processing purposes and also describe your rights as a data subject.
1. WHO ARE WE?
This privacy policy applies to personal data of all customers, suppliers and other third parties collected by Thana Digital Life Co., Ltd. (individually and collectively, "we", "our", "us", or "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).
If you have any questions or concerns about our privacy practices, we welcome you to contact us via

• Address: TRUE Corporation Public Company Limited Attn: Data Protection Officer 18 True Tower, Ratchadaphisek Rd., Huai Khwang, Bangkok 10310 Thailand
• Contact channel: Pongsiri_ana@truecorp.co.th

In addition, you can contact the Personal Data Protection Officer via email Pongsiri_ana@truecrorp.co.th

Upon receive your questions or concerns, our representative will contact you within a reasonable time to response to your questions or concerns. In some case, we may request for further information to verify your identity.

2. WHAT IS PERSONAL DATA?
"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.

3. WHAT PERSONAL DATA WE WILL COLLECT
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, date of birth, gender, nationality, photograph, citizen card and identification number, unique device identifiers, geolocation, etc.);
• Contact information (e.g., home address, telephone number, email address);
• Usage and service behavior information of the Company and/or True Group companies* or business partners of the Company and/or True Group companies including the usage of network service or products related to the services;
• 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);
• 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.

4. THE SOURCES OF PERSONAL DATA
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.);
  • When you visit the Company's website through your browser’s cookies;
• Information that we collect from other sources: We may receive personal data about you from third parties, which are allowed to disclose your information by your consent under applicable law, including True Group companies, 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.

5. THE PURPOSES OF PERSONAL DATA PROCESSING
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 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 True Group companies or business partners of the Company and/or True Group companies;
• 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 True Group companies and/or business partners of the Company and/or True Group companies;
• 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 True Group companies and/or business partners of the Company and/or True Group companies;
• 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 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 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.

6. HOW WE PROCESS YOUR PERSONAL DATA
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 may disclose personal data and any information about your use of the service or any other information that the Company collected as described in section 3 above to the Company and/or True Group companies or business partners of the Company and/or True Group companies, including Charoen Pokphand Group companies*, legal government agencies, Information technology service providers, banks, payment and transaction service providers, customer support service providers, service providers, marketing and advertising management service provider, business consultants Including any juristic persons or any other person in which the Company and/or you are a party or having legal relations.
In addition, the Company may have to send your personal data to the regulatory authorities for investigation and may use the results of such data audits to prevent fraud. In addition, the Company may disclose your information to individuals or juristic person outside of True Group companies, where the Company may sell or transfer some of its business or assets, or vice versa. There may be plan to acquire or merge with external persons or entities. If there is a change in the Company's business in parts that are sold, acquired or merged with other companies (As the case may be) your information may be used in the same way as described in this Privacy Policy.
In the event that the Company employs other persons to act as a personal data processor, the Company will investigate personal data protection measures and arrange to sign an agreement to control and protect personal data appropriately and in accordance with the rules prescribed by required law.
In some circumstances, we may need to transfer your personal data to another person, foreign branch offices, or international organizations in some countries that may not have appropriate safeguards. In such case, the Companies will make sure that transferring of such information is lawful as specified by the Personal Data Protection Committee, for example your personal data may be disclosed to other companies within True Group companies in accordance with the Binding Corporate Rules (BCRs) or other information transfer agreements.
We conduct internal and external inspection for customer data protection on a regular basis.

7. HOW AND HOW LONG WE KEEP YOUR PERSONAL 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.

8. YOUR RIGHTS AS A DATA SUBJECT
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 has the right to refuse that is a dishonest exercise of the right, unreasonable requests, requests that are not provided by law and/or requests that cannot be fulfilled. In addition, the Company has the right to reject your request in accordance with the rules stipulated by the law.

9. IF YOU REFUSE TO GIVE US YOUR PERSONAL DATA
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.
Besides the case that the Company processes personal data for performing of the contract and complying with the laws, in some cases, the Company may require your consent for the collection, use or disclosure of your personal data in accordance with the purposes of personal data processing specified in section 5 to provide you with the best benefits and/or for the Company to be able to provide services that meet to your needs appropriately.

10. MARKETING ACTIVITIES AND CAMPAIGNS
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, True Group companies, the Company's selected partners or True Group companies' selected partners, including Charoen Pokphand Group companies, which you will be interested in. You can cancel your consent for being informed marketing communications via channels specified by the Company.

11. COOKIE POLICY
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? he 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.

12. PERSONAL DATA OF MINORS
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.

13. COLLECTION AND USE OF PERSONAL DATA FOR THE ORIGINAL PURPOSE
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.

14. PRIVACY POLICY OF OTHER WEBSITES
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.

15. CHANGES TO OUR PRIVACY POLICY
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.


LIST OF TRUE GROUP COMPANIES
* True Group companies are True Corporation Public Company Limited, True Move H Universal Communication Co., Ltd., True Move Co., Ltd., True Distribution and Sales Co., Ltd., True Music Co., Ltd., Telecom Asset Management Co., Ltd., True International Communication Co., Ltd, BFKT (Thailand) Limited., Clearing House for Number Portability Co., Ltd., True Visions Group Co., Ltd., True Visions Public Company Limited, Cineplex Co., Ltd., True Visions Cable Public Company Limited, Satellite Service Co., Ltd., Panther Entertainment Co., Ltd., AP&J Productions Co., Ltd., True Media Solutions Co., Ltd., True United Football Club Co., Ltd., SM True Co., Ltd., Thai News Network (TNN) Co., Ltd., True4U Station Co., Ltd., True CJ Creations Co., Ltd., True GS Co., Ltd., True Touch Co., Ltd., Asia Wireless Communication Co., Ltd, True Voice Co., Ltd., True Multimedia Co., Ltd., True Internet Corporation Co., Ltd., True Life Plus Co., Ltd., True Axion Interactive Ltd., Internet Knowledge Service Center Co., Ltd., KSC Commercial Internet Co., Ltd., True International Gateway Co., Ltd., True E-Logistics Co., Ltd., True Icontent Co., Ltd., True Digital Park Co., Ltd., True Internet Technology (Shanghai) Co., Ltd., True Digital Group Co., Ltd., Crave Interactive Limited, Crave Interactive B.V., Crave Interactive Inc., PT True Digital Indonesia, True Digital Philippines Inc., Telecom Holding Co., Ltd., Bangkok Inter Teletech Public Company Limited, K.I.N. (Thailand) Co., Ltd. (Foreign), MKSC World Dot Com Co., Ltd., True Incube Co., Ltd., True Trademark Holdings Company Limited, Gold Palace Investments Limited, Golden Light Co., Ltd., Goldsky Co., Ltd., Transformation Films Co., Ltd., Queue Q (Thailand) Co., Ltd., True-Kona Cayman GP, LINE Games-True-Kona Global Fund Limited Partnership.

LIST OF BUSINESS PARTNERS
* Charoen Pokphand Group companies are as follows;
CP ALL Public Company Limited, Counter Service Co., Ltd., Thai Smart Card Company Limited, 24 Shopping Company Limited, All Now Logistics Company Limited, CPRAM Company Limited, CP Retailink Company Limited, All Wellness Company Limited, All Guardian Co., Ltd., All Now Management Co., Ltd., Gosoft (Thailand) Company Limited, M A M Heart Company Limited, Panyatara Company Limited, All Training Co., Ltd., Panyapiwat Institute of Management, Panyapiwat Technological College, Panyapiwat Institute of Management Demonstration School, Charoen Pokphand Foods Public Company Limited, CPF (Thailand) Public Company Limited, C.P. Merchandising Company Limited, CPF Trading Company Limited, Chester's Food Company Limited, CPF Food And Beverage Company Limited, CPF Restaurant and Food Chain Company Limited, CPF Food Research and Development Center Company Limited, International Pet Food Company Limited, CPF Training Center Co., Ltd., Bangkok Produce Merchandising Public Company Limited, CPF IT Center Co., Ltd., CP Hilai Harbour Company Limited, Dak Galbi Group Company Limited.

Ascend Group companies are True Money Company Limited, Ascend Nano Company Limited, Ascend Wealth Mutual Fund Brokerage Securities Co., Ltd., Ascend Assurance Broker Co., Ltd., Ascend Innovation Co., Ltd., Ascend Commerce Company Limited, Chilindo Company Limited.

Makro Group companies are Siam Makro Public Company Limited, Siam Food Services Company Limited.

Lotus Group companies are Ek-Chai Distribution System Company Limited, Lotus's Money Services Limited, Lotus’s General Insurance Broker Limited, Lotus’s Life Assurance Broker Limited.

TYPES OF OUR BUSINESS PARTNERS WITH WHOM THE COMPANY MAY SHARE PERSONAL DATA (MIGHT BE UPDATED IN THE FUTURE)
Charoen Pokphand Group companies are such as;
CP ALL Public Company Limited, Counter Service Co., Ltd., Thai Smart Card Company Limited, 24 Shopping Company Limited, All Now Logistics Company Limited, CPRAM Company Limited, CP Retailink Company Limited, All Wellness Company Limited, All Guardian Co., Ltd., All Now Management Co., Ltd., Gosoft (Thailand) Company Limited, M A M Heart Company Limited, Panyatara Company Limited, All Training Co., Ltd., Panyapiwat Institute of Management, Panyapiwat Technological College, Panyapiwat Institute of Management Demonstration School, Charoen Pokphand Foods Public Company Limited, CPF (Thailand) Public Company Limited, C.P. Merchandising Company Limited, CPF Trading Company Limited, Chester's Food Company Limited, CPF Food And Beverage Company Limited, CPF Restaurant and Food Chain Company Limited, CPF Food Research and Development Center Company Limited, International Pet Food Company Limited, CPF Training Center Co., Ltd., Bangkok Produce Merchandising Public Company Limited, CPF IT Center Co., Ltd., CP Hilai Harbour Company Limited, Dak Galbi Group Company Limited.Thana Digital Life Co.,Ltd.

RED ANCHOR (THAILAND) COMPANY LIMITED
Axion Interactive Incorporated
Axion Ventures Inc.

Ascend Group companies are such as True Money Company Limited, Ascend Nano Company Limited, Ascend Wealth Mutual Fund Brokerage Securities Co., Ltd., Ascend Assurance Broker Co., Ltd., Ascend Innovation Co., Ltd., Ascend Commerce Company Limited, Chilindo Company Limited, Ascend Food Company Limited.

Makro Group companies are such as Siam Makro Public Company Limited, Siam Food Services Company Limited.

Lotus Group companies are such as Ek-Chai Distribution System Company Limited, Lotus's Money Services Limited, Lotus's General Insurance Broker Limited, Lotus's Life Assurance Broker Limited.

Companies in financial industry
Companies in automotive industry
Companies in digital asset industry
Companies in e-Commerce industry
Companies in real estate and construction industry
Companies in agricultural and food industry
Companies in consumer goods industry

As at present, the Privacy Policy has been last reviewed on 21 July 2023.