Privacy Policy

Raimon Land Public Company Limited (“RML” or “We”), strictly abide by our customers’ privacy. When RML use your personal data to run our business and provide service to you, your personal data is protected under the Personal Data Protection Act B.E. 2562. RML are committed to safeguarding your personal data.

As the data controller, RML is obliged by the law to inform you of our privacy policy which explains the way we collect, use, disclosure, analyze, or data process your personal data as well as your rights to your personal data as the data subject. RML reaffirm that we comply with the law to protect your personal data.

RML reserves the right to amendment this Privacy Policy from time to time to reflect changes in applicable laws or the way we handle personal data. The updated Policy will supersede earlier versions and will apply to personal data provided to us previously. You are encouraged to re-visit our Policy on our website or application. In case any modification deprives your rights of sensitive data in relation to this Privacy Policy, RML will first obtain your consent, except as otherwise required by law.

1. Definition

Personal Data (General) Personal Data means any information related to a person, which enables the identification of such person, whether directly or indirectly but not including the data of the deceased persons or anonymized data such as name address e-mail address Identification Number and/or information relate to a juristic person as determined by Department of Business Development such as Tax identification Number, address register.

Sensitive Personal Data Sensitive Data is special category of personal data that needs appropriate protection and carefully collect, use, or disclose. Sensitive Data pertains racial, ethnic origin, political opinions, cult, religious or philosophical beliefs, sexual behavior, criminal records, health data, disability, trade union information, genetic data, and biometric data.

Date owner means the owner of the personal data whose data is collected, used or disclosed, including but not limited to the customers, shareholders, trading partners, service provider and the interested parties.

Biometric data means personal data resulting from specific technical processing relating to the physical, physiological, or behavioral characteristics of a natural person, which allow or confirm the unique identification of that natural person, such as facial images or dactyloscopy data or fingerprints data.

Public data means data that the data owner has disclosed to the public such as online profiles which requires social media credential such as Facebook, Instagram, Twitter, Line and other online platforms and other further platforms which is used to connect or use the company’s services i.e. social media account ID, interests, likes and friends list of the data owner which the data owner have a control and can keep it private via the online settings provided by the service provider.

2. Sources of collect your Personal Data

1. Directly from the data owner via channels are following:
   • You register with us by creating an account on our website or application.
   • You make a query with us relating to your interested property/ project.
   • You make an appointment with us to visit the project site.
   • You provide information to us when you visit the project site.
   • You participate in our marketing activity through an electronic platform, social media, or an offline platform.
2. From Cookies: RML received your personal data from cookies when you visit our website. This data helps us provide you better, faster, safer services and for your own privacy when you use the service and/ or enter the platform.
3. From Third Party: RML received your personal data from a third party that collects, uses, or discloses your personal data as instructed by us or on our behalf. Your personal data will not be used other than the purposes for which we instructor require such third party to do. We require such third party to protect confidentiality of your personal data and to have measures to protect your personal data as required by the Thai personal data protection law.
4. From Public Record and/or Non-Public Record: Personal data which can be collected from the public records and non-public records, which the company has the right to collect as per the law.
5. Personal data collected from the government’s organization or authorized agencies.
6. Personal data received from the subsidiaries.

RML collects your personal data as necessary to provide the service to you and to correspond to your queries as well as to carry on our business in a way that you would normally anticipate.

3. Purposes for Collection, Use or Disclosure of Your Personal Data

General purposes

• For our legitimate interests or any other person and your interests, which do not override your fundamental rights; and/or
• For the performance of a contract to which you are a party, or to take steps at your request to enter a contract; and/or
• For compliance with a law to which we are subjected or for preventing or suppressing a danger to a person’s life, body, or health; and/or
• For compliance with laws and regulations, internal policies, and procedures, including auditing, and/or
• For processing your transactions with us or to provide products and services to you; and/or
• For the security and safety purposes, in connection with the properties that RML own or manage, or events organized by us or conducted at our properties; and/or
• To carrying out research and statistical analysis, including development of new products and services or evaluation and improvement of our existing products and services; and/or
• For facilitating business asset transactions; and/or
• For assisting you with your requests, enquiries, and feedback.

Marketing purposes

• If you have given your consent, we may use your personal data for the purposes of marketing our products and services and those of our strategic partners and business associates for marketing and communication purposes. e.g., informing you of our latest activities, special offers and promotions and/or for informing you of our latest to products and services which are of special interest and relevance to you, etc.

Legitimate interests and other legal basis for processing

In addition to collecting, using, disclosing, and processing your personal data with your consent or for performance of a contract entered with you, we may also do so to support our legitimate business interests (provided that this does not override your interests or rights), are followings:

1. Managing our business
   RML may disclose your personal data to third parties who provide services to us, including our service providers and data processors (providing services such as hosting and maintenance services, analysis services, e-mail, messaging services, handling of payment transactions, marketing, human resources, and professional services) and our consultants and professional advisors.
2. Guests at our properties
   If you make a reservation or stay at the properties that RML own or manage, RML may
   • Use and disclose your personal data to assist you in making arrangements that you request for, such as arranging for tours, airport transfers, restaurant reservations etc.; and/or
   • Send you pre-stay communications, post-stay communications and satisfaction surveys; and/or
   • Invite you to join our customer loyalty programs or subscribe to our mailing lists; and/or
   • Evaluate your preferences to improve and customize your experience for current and future reservations and stays at our hospitality properties.
3. Job seeker
   
   • If you are a job seeker, in addition to the specific position which you have applied for, RML may disclose your personal data to companies within the RML’s Group for the purpose of offering additional employment opportunities.
4. Investor/shareholder
   If you are an investor or shareholder of the Raimon Land Public Company Limited, RML may use your personal data to
   • Send you the Company’s information; and/or
   • Manage investor / shareholder relations; and/or
   • Comply with regulatory requirements.

How RML Collect, Use or Disclosure of your Personal Data

RML collect your personal data as necessary and to the extent that is related to provision of our service to you, where it is necessary is follow:

RML reserved the right to process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

4. Security and Retention of Personal Data

RML will process the information only until it is necessary. RML identify the purpose and the necessity to collect and process the data. This shall also be in accordance with the law. RML shall store the data for a period after the agreement has expired but will be in accordance with the period and prescription of law. RML has a suitable location to store the personal data for each type to store the personal data even if the prescription has expired such as when there is a case etc.

RML shall secure your personal information as per the administrative safeguard, technical safeguard, and physical safeguard to prevent it from the processing of data by a third party. Therefore, there shall be confidentiality, integrity, and availability. This is to prevent the violation of personal data. RML has determined the privacy policy, regulations, and rules on personal data protection such as information technology security standards and preventing a third party to receive information from the company to use or disclose for any other purposes or unlawfully or illegally using the data. RML alters and modifies the policies, regulations, and rules from time to time as deems suitable.

5. Collection of personal data

RML will collect the data directly provided by the data owner to the customer or the personal data collected by giving services or by the company’s business.

Personal data means the data that can identify a natural person. A natural person who is identified means a person who can directly or indirectly be identified via the following information:

• Name
• E-mail
• House or office address
• Telephone number
• ID Card no.
• Passport no.
• Date of birth
• Nationality
• Gender
• Credit card number
• IP address

Search history means data which does not identify a natural person such as browser type, domain, visited websites, time of visiting the website, address of the website for supporting the customer. The log will be collected from the RML’s application.

System information means data which is automatically collected by the company when you login into the RML’s website. It could be collected by the cookie, web beacons, login file, script, technical data such as IP Address, browser type, domain, visited websites, time of visiting the website, address of the website, data while being searched or was looked at when the RML’s browser was open and the behavior of using the application.

Address data means the data received via GPS, WiFi, compass, IP Address accelerometer or the public post.

Cookies is text files located in your computer to be used to store details of log data on your internet use or your website's visiting behavior. RML use Cookies to collect your data on visiting to our website to help us provide better, faster, and safer services and support your privacy when you use our services through our website. RML use Cookies in the following cases:

• Cookies for website operations (Functionality Cookies): RML use this type of cookies to help us remember your device or browser. Thus, RML can quickly create content in consistent with your personal interests as well as provide the service and platform more convenient and beneficial to you. By disabling this cookie, you can set up your device by watching helping methods on your browser or device.
• Cookies for analytics (Analytic cookies): We use Analytics Cookies providing by Facebook and Google for analyzing how visitors use our website with the objective of offering products or services via Social Media. In case you do not allow those third parties process your personal data, just do not click the button "Allow all cookies" and you still be able to visit our website as normal.

Utilization of Sensitive Personal Data

To sell the products or services of the company or to collect the personal data in some cases, RML has the necessity to collect the sensitive data such as racial or ethnic origin, political opinions, religious or philosophical beliefs, person’s sex life, criminal records, data concerning health, trade union membership, the processing of genetic data, biometric data or health data etc. In such cases, RML shall inform and request for the data owner’s consent to use the sensitive data as per the company’s purpose.

6. Disclosure of Personal Data

Disclosure to Raimon Land Group:

RML may disclose or share your personal data with organizations within the Raimon Land Group for the purposes described at Part 3. Purposes for Collection Use or Disclosure of Your Personal Data above.

Remark

- Please see the name list of the Companies under Raimon Land Group in appendix1

Other disclosure:

RML may also disclose your personal data for the purposes described at Part 3. Purposes for Collection Use or Disclosure of Your Personal Data above or as required or permitted by law; to:

• Our third-party vendors and service providers, who are engaged to provide business, support, operational and/ or administrative functions such as auditing, legal, marketing, payment, fulfilment, and delivery of orders.
• Third parties that we conduct joint marketing and cross promotions with.
• Regulatory authorities, statutory bodies, or public agencies, including to support their investigations.
• Financial Institutions (both local and international institutions) and included funds for financial facilitating.

When disclosing personal data to third parties, RML will (where appropriate and permissible) enter contracts with these third parties to protect your personal data in a manner that is consistent with all applicable laws and/or ensure that they only process your personal data in accordance with our instructions.

7. Transfer of Personal Data to Other Countries

In the event, RML has to transfer, assign and/or send the data oversea, the company will determine the standard of covenants and/or joint venture with agency or organization which will receive the data to have an acceptable standard for data protection and to coordinate with the law. This is to ensure that the personal data will be secured i.e.

• RML has the necessity to store and/or transfer, assign the personal data for storing; and/or
• Processing of data in the Cloud; The company shall consider the organization which has international standard for security and shall store the data by entering the password or by any other means which will not identify the personal data.

8. Utilization of personal data for marketing

Apart from the purposes mentioned above and under the law, the company shall use the personal data for the purpose of marketing such as to send promotion documents via the post, e-mail or any other methods including the direct marketing. This is to provide additional benefits to the data owner who is the customer of the company.

You may choose to deny the communication for the purpose of marketing except the necessary communication and/or services such as invoice of installments payment and receipt etc.

9. Your Rights

You have the rights at law in relation to our collection, use, disclosure, and processing of your personal data. Such rights include:

Withdrawal of consent

• If a consent is given to the company to collect, use and disclose your information (consent prior or after the enforcement of the data protection laws), you have the right to withdraw the consent at any time when the data is with the company except that your rights have been limited by law or agreement which is for your benefit.

Access your Personal Data

• You may ask us if we hold your personal data and, if we are, you can request access to your personal data. This enables you to receive a copy of and information on your Personal Data we hold about you, included request RML to disclose the way the data was collected without the consent.

Transfer the Data

• You may request your personal information which the company has altered so it can easily be read or used via the automatic equipment or tools and may use the or disclose the data automatically. You also have the right to directly send or transfer the personal data in the automatic form to the data controller except there are any technical errors.

Object

• Where we are processing your personal data based on a legitimate interest (or those of a third party) you may object to processing on this ground. However, RML shall collect, use and disclose the personal data only for the part where the company can provide lawful reasons that is supersedes your basic rights or which is in accordance with the law or used to fight a case, as the case maybe.

Erasure

• You may ask us to delete or remove your Personal Data that we hold about you in certain circumstances.
  To delete, destroy or change the form of the data into an anonymous data or to withdraw the consent shall be done under the law and agreement with the company only.
  Such utilization of rights may have an impact on the performance of the agreement or services as the data owner would be anonymous. There will be limitations and may cause the data owner not receive benefits and news from the company.

Restriction

• You may withdraw consent for our use of your personal data or ask us to suspend the processing of certain of your Personal Data when RML is under the process of considering the amendment of personal data or request to object or any other events where the company no longer needs to store the information and shall delete the Personal Data, but you have requested to restrict instead.

Amendment

• You have the right to amend your personal information to be correct, present and compete which will not cause misunderstanding.

Utilization of rights

• The rights can be utilized by filing the form and submitting it to the responsible agency.
  However, your rights many be limited by the related laws. If necessary, RML may deny or may not proceed as per the request such as to act in accordance with the law or court’s order, for the public interest, injunction due to possible breach on rights and liberty etc. If the company denies the request, a reason shall be provided by the company.

Duration for utilizing the rights

10. Privacy policy of other websites

This Privacy Policy is used for our service and our website use only. If you click on a link to another website (although via our website). You will have to study and comply with the privacy policy displayed on that website separate from ours.

11. Amendments to This Policy

RML review and may amend this Policy from time to time to reflect changes in applicable laws or the way RML handle personal data. The updated Policy will supersede earlier versions and will apply to personal data provided to us previously. You are encouraged to re-visit our Policy from time to time to keep yourself updated on these changes. A copy of our current Policy is available on our website or other platforms.

12. Contact

If you have any feedback or issues in relation to your personal data, or about this Policy, or wish to make a complaint to us, you may contact the applicable Data Protection Officer, as the address below:

Appendix1: The List of Companies and Business Partner under Raimon Land Group

• Raimon Land Public Company Limited
• Raimon Land Unixx Co., Ltd.
• Raimon Land Sathorn Co., Ltd.
• Raimon Land Twenty Six Co., Ltd.
• Raimon Land Silom Co., Ltd.
• Raimon Land Thirty Eight Co., Ltd.
• Siam Spoon Co., Ltd.
• Asangha Realty Co., Ltd.
• Raimon Land Nineteen Co., Ltd.
• Raimon Land Twenty Four Co., Ltd.
• Raimon Land Development Co., Ltd.
• Raimon Land Estate Co., Ltd.
• Raimon Land Services Co., Ltd.
• RML 548 Co., Ltd.
• Raimon Land Residence Co., Ltd.
• Taksin Properties Co., Ltd.
• Raimon Land Digital Co., Ltd.
• Raimon Land Holding Co., Ltd.
• Raimon Land Twenty Eight Co., Ltd.
• Phayathai Land Co., Ltd.
• Kamala Bay Co., Ltd.
• Kamala Hilltop Co., Ltd.
• Sirey Holding Co., Ltd.