Personal Data Protection Policy Notice of Sugar Club

Sugar Club (“Sugar Club”) is committed to providing quality services to meet your expectations. Sugar Club attaches great importance to protecting your personal data and compliance with applicable laws and regulations. Therefore Sugar Club has prepared this statement on how we collect, handle and process data for our customers and visitors and to inform you of the protection of your personal data and your rights as the personal data subject

Sugar Club would like to inform you as the Personal Data Subject who is:

(1) A person who has been in contact with Sugar Club, whether it was a visitor or a customer of the Sugar Club

(2) An employee, personnel, officer, representative, shareholder, director, personal contact, an agent or a person related to a juristic person, a person under (1) above, a group of assets, or a body of persons who have been in contact with Sugar Club, whether they were a customer of Sugar Club or were not.

About protecting your personal information that Sugar Club receives or will receive from business operations and providing services through venues, websites, telephones, electronic channels, applications, social media or other sources to ensure that Sugar Club will take care of your personal information. And will collect, use or disclose your personal information only if Sugar Club deems it necessary, correct and appropriate and notifies you of your rights as the personal data owner.

1. Personal data of the personal data subject that Sugar Club will collect, use and disclose consists of:

1.1 information that can identify the owner of the personal data. Whether directly or indirectly

(2) Personal information such as name – surname, gender, date of birth, age, and information on or in documents such as identification cards, passport, residence certificate, alien identification card, work permit, social security card, driving license, car registration or house registration, signature, taxpayer identification number information about family members educational background, occupation, status, membership, work history and other benefits that are not compensation for work insurance-related information

(3) Contact information such as the address according to the house registration. Address for sending documents. Electronic postal address (Email Address). Home phone number, mobile phone number and fax number. Your name or details for use through applications or digital channels such as LINE, Google, Facebook, YouTube or Twitter, WhatsApp or WeChat and contact information provided to Sugar Club through its services.

(4) Financial information and financial transactions including payment deposits. Movements of deposits into accounts. Income and Expenditure Information. Information about an act or alleged offence within Sugar Club. Prosecution and the execution of information about insurance or investments. Information relating to shareholders and their assets. Information about paying or receiving payments. Information for compliance with local laws and regulations.

(5) Information relating to the Sugar Club’s dealings, i.e. information Sugar Club receives via its venues, telephones, and electronic or digital channels. Social media Information from CCTV and off-site services. Such information may be displayed or recorded in written form. Recording tapes or recordings of transactions Photographs or moving pictures

(6) Technical data These are the IP Address, Media Access Control (MAC), the ID number attached to the device connected to the network and the network (MAC Address), Log, Device ID ( Device ID), application interface information (APIs), cookies (Cookies), plug-in type and version, browser, operating system and platform. Internet system or mobile phone network geolocation information Settings. Information on the device and other technical information from using Sugar Club applications and operating systems

(7) Usage Information Including the name or code for using the service (Username), the password for using the service (Password), and information about searches. Time of use on websites, platforms, applications, timestamp of the last click, favourites, Q&A, log files, and communications

(8), Behavioral data, such as data about personal interests or preferences, nature of use or use of data.

1.2 Personal data that is sensitive information which Sugar Club must first obtain your consent before being collected, including biological data (e.g. biometric data, fingerprint and audio identity), criminal history, health information, or any other information as announced by the Personal Data Protection Committee.

2. Purpose of collecting, using and disclosing your personal information.

Sugar Club will collect, use and disclose your personal data in accordance with the rules outlined in the law, namely: (1) necessity according to a contract or request or service that you have made to Sugar Club; to then comply with any contract or request or service you have made with Sugar Club; (2) legal obligations which Sugar Club must comply with under the law; (3) Sugar Club’s legitimate interests or other persons or juristic persons (4) the necessity to prevent harm to the life, body or health of persons; (5) the necessity for the public interest or the exercise of government rights, or (6) your consent if it is not required by the criteria specified in (1) to (5), for one of the following purposes:

2.1 For communication or to provide information related to or related to the products or services or information that you use or will use with Sugar Club.

2.2 For the execution of the agreement specified in your request (e.g. an employment application) or the contract you have entered into with Sugar Club or related to contracts (e.g. employment contracts) or requests that you make with Sugar Club, such as the transfer of documents or to comply with agreements entered into between Sugar Club and other parties that are necessary and relevant to the provision of services to you;

2.3 In order to manage your relationship with Sugar Club and provide details or history of using a service provided by Sugar Club or for offering a service to you in the future.

2.4 To verify your identity according to Sugar Club’s, know your client process, including checking and confirming your information and following up with any guidelines required by law and the Sugar Club.

2.5 For any action as required by the laws of Thailand, be it requested or recommended to comply.

2.6 For management and internal management of Sugar Club, such as supervision, improvement or the audit of Sugar Club’s internal operations.

2.7 For the management of various risks such as

(1) Preventing, dealing with or reducing risks that may arise from illegal actions which may happen to you, a Sugar Club customer, personnel of the Sugar Club and Sugar Club by using it in considering the improvement of the security system related to the use of various channels, operations and security systems for the Sugar Club’s information technology operations

(2) Security, such as recording images of visitors through CCTV and those entering the building for security purposes.

2.10 To provide and offer you products, services and service options, including offering services or products from Sugar Club’s business partners.

2.11 For verification of contractual obligations or to check commitments according to you or your contractual party

2.12 For the management of services and complaints such as checking transactions from clubs and restaurants, venues and in-house services that deal with financial transactions and checking wrong financial transactions or the transmission of information within Sugar Club or between Sugar Club and other people or our business partners to support complaints. Or to be used as supplementary data for adjusting work processes related to such matters.

2.13 For statistical analysis or research related to the Sugar Club’s business operations or for companies in the Sugar Club, including affiliates and business partners.

2.14 For strategic adjustments for the benefit of evaluating Sugar Club’s performance or services.

2.15 For evaluation, development and improvement of products or services or take action to enforce Sugar Club’s rights, which may provide information derived from such analysis to Sugar Club for financial forecasting or updating services within the group’s companies and affiliates.

2.16 For organising promotional projects or activities, meetings, seminars, recreation and on-site visits

2.17 For cloud storage and other systems that Sugar Club uses to store information

2.18 For the performance of duties in accordance with the conditions that Sugar Club and its business partners are a party to or to enforce legal or contractual rights binding Sugar Club.

2.19 To connect or facilitate your access to the website, employment applications and goods or services offered by Sugar Club or its business partners

The collection, use or disclosure of your personal information, such as sending or transferring your personal information to Sugar Club’s business partners in accordance with the rules set out in this statement.

3. Persons or entities who may have disclosed your personal information from Sugar Club.

Sugar Club may be required to disclose your personal information to other persons or entities located in Thailand or abroad in order to achieve the objectives stated in this letter, namely

3.1 Business partners of Sugar Club such as business alliances in finance, accounting services, shareholders, marketing, transportation, telecommunication, health centres, insurance or life insurance companies, or any person(s) that are involved in the promotion of the Sugar Club or their affiliates, data analysis Platform contributors or a person whose name or logo appears in any contracts, websites or other service channels of Sugar Club.

3.2 Persons involved in Sugar Club’s services For example, those who act as intermediaries in various Sugar Club transactions or payment system providers. Sugar Club’s service partners outsource service providers, operators or sellers of goods or services to Sugar Club. Or Sugar Club representatives both domestically and internationally to which Sugar Club is a contractual party, such as an infrastructure development service provider, internet network service provider, telecommunication and Communication Service Providers, technical infrastructure provider, Electronic system development or information technology service provider, Logistics and Warehousing Service Providers, Cloud service provider, for doing research, data analytics provider. Communication service provider, Survey service provider, Organisers of events and activities, Verification and authentication system provider, Service provider for checking and reading data with electronic devices, Verification and verification service providers, credit rating agency, courier service, recording service providers and service providers regarding security or fraud prevention.

3.3 Individuals or agencies as required by law Sugar Club may be required to disclose your personal information to comply with laws, rules, regulations and regulations or orders of government agencies, government agency regulators or in cases where the Sugar Club believes that such action is necessary to comply with the law to protect the rights of Sugar Club or other persons for the safety of others or to prevent, investigate or deal with fraud, security or safety issues in various fields

3.4 Consultants in various fields of Sugar Club such as financial, legal, technical, website and auditor experts

or accepting the transfer of the Sugar Club’s claim This includes those involved in corporate restructuring, business transfers, investments, mergers and acquisitions. The purchase or sale of assets or businesses by persons involved in such operations.

3.5 Consultants in various fields of Sugar Club such as financial, legal, technical, website and auditor experts.

3.6 Associations, organisations, clubs and agencies Such as employment agencies.

3.7 Various websites and social media Such as Facebook, Google or Instagram.

4. Retention of your personal information and the retention period of your personal data

4.1 Retention of your personal data

Sugar Club has established measures for the security of personal information, both in document format and electronic form to prevent the loss, access, use, change, alteration or disclosure of personal information without right or unlawful.

4.2 Period of retention of your personal data

Sugar Club will collect your personal information for the purposes stated by Sugar Club in this statement. As required by law and up to 10 years from the date you terminate your relationship with Sugar Club, unless Sugar Club has other necessities as required by law or such personal data is information that cannot be deleted or destroyed due to technical limitations.

5. Sending your personal information abroad. In the event that the Sugar Club has a necessity to send or transfer your personal information to persons residing in foreign countries, such as your counterparty or representative, affiliates or organisation in a foreign country or destination recipient of such information where they may be insufficient standards for personal data protection as required by law, Sugar Club will provide an appropriate process so you can be sure that your personal information sent to the recipient will be safe

6. The website system that Sugar Club uses to collect information.

To access Sugar Club’s website system, Sugar Club automatically collects certain information from your use for the purposes set out in this statement. For example, Sugar Club may use the information that cookies and similar technologies have recorded or collected to be used in statistical analysis or in other activities of the website system, or Sugar Club businesses to help Sugar Club provide you with a good experience whilst using the website as well as to improve the efficiency and quality of Sugar Club’s website system services.

7. Rights of personal data subject

You, the owner of the personal data, have the following rights:

7.1 Right to request access and obtain a copy of personal data.

You have the right to request access and obtain a copy of personal information about you, which is under Sugar Club’s responsibility or request Sugar Club to disclose the acquisition of such personal data that you did not give consent.

You have the right to obtain personal data about yourself that you have provided to Sugar Club based on your consent or necessity under this statement or as announced by the Personal Data Protection Committee. In the event that Sugar Club has made such Personal Data in a form readable or generally usable by means of an automated tool or device and that the Personal Data can be used or disclosed by any means, including having the right to (1) request that Sugar Club transmits or transfer personal data in such form to other personal data controllers whenever possible by automated means; and (2) request personal data that Sugar Club sends or transfers in such form to other personal data controllers directly except by technical conditions if it is not possible.

7.2 Right to object.

You have the right to object to the collection, use or disclosure of your personal information by Sugar Club in the event that: (1) Sugar Club collects your personal information due to the necessity of performing its business or group businesses for Sugar Club’s public interest; or the exercise of government rights or for Sugar Club’s legitimate interests or other person or juristic person; (2) Sugar Club collects, uses or discloses your personal information for marketing purposes; or (3) Sugar Club collects, uses or discloses your personal information for the purposes of research studies or statistics.

7.3 Right to request the deletion or destruction of personal data

You have the right to ask Sugar Club to delete or destroy or make your personal information non-identifiable in the event that:

(1)Your personal information is no longer necessary for Sugar Club to keep for the purpose; or (2) You withdraw your consent, and Sugar Club does not have statutory authority to continue using or disclosing that personal information; or (3) You object to the collection, use or disclosure of your personal information collected by Sugar Club due to the necessity of carrying out its mission for the interest of Sugar Club or the exercise of government rights or for the Sugar Club’s legitimate interests or other person or juristic person and Sugar Club cannot refuse such objection; or (4) You object to the collection, use or disclosure of personal information for direct marketing purposes; or (5) Your personal information has been collected, used or disclosed without legality unless Sugar Club is obliged to collect your personal information for legal compliance, Establishment of legal claims or the use or defence of any Sugar Club’s claim(s).

7.4 Right to request to suspend the use of personal data

You have the right to suspend the use of your personal information in the event that (1) Sugar Club is in the process of reviewing the request to exercise the right to correct the personal information to be current; (2) Sugar Club collects, uses or discloses your personal information unlawfully (3) Sugar Club is not obliged to collect, use or disclose that information for one purpose but you require Sugar Club to collect your personal data for your benefit by law; or (4) you wish Sugar Club to suspend the use of your personal data because it is in the process of proving or verifying objection(s) to your personal data.

7.5 Right to request to correct personal data

You have the right to ask Sugar Club to correct your personal data to be accurate, current, complete and not misleading.

7.6 Right to withdraw consent. 

You have the right to withdraw your consent to Sugar Club from which you consent to Sugar Club collecting, using and disclosing your personal information at any time. You have the right to notify the revocation of consent for personal data Sugar Club collected before the Personal Data Protection Act B.E. or collected via an employment agency used by Sugar Club.

 7.7 Rights of complaint

You have the right to complain to an agency or legal authority. In the case of Sugar Club or personal data processors, including employees or contractors of Sugar Club who violate or fail to comply with the law on personal data protection.

In the event that you wish to exercise any rights under Clauses 7.1 to 7.7 above. You can make a request to Sugar Club through Sugar Club or any other channels as specified by your manager. When Sugar Club has received your request, Sugar Club will consider your request in accordance with the rules and conditions prescribed by law and will complete your request and notify you of the result of consideration and action within 30 days from the date Sugar Club has received the request and complete supporting documents.

In the event that you exercise the rights of the subject of such personal data, this may prevent you from receiving certain services from Sugar Club whilst Sugar Club considers or processes your request.

Sugar Club will not charge a fee from you as a result of any request for the exercise of rights unless Sugar Club deems that the request for the exercise of your rights is excessive or without any other reasonable cause. In this case, Sugar Club may charge a fee for processing your request but will inform you of the rates should this become applicable. You can request to exercise the rights of the personal data subject from the date the Personal Data Protection Act B.E. 2562 came into force.

8. Changes to this Personal Data Protection Notice

Sugar Club may change this Personal Data Protection Notice from time to time as it deems appropriate, and Sugar Club will notify you through its websites and applications. Sugar Club recommends that you read and review the details in the Personal Data Protection Notice whenever such amendments are made.

Contact

If you wish to contact or would like to know more information or explanations about the collection, use and disclosure of your personal information, including the request to exercise the rights of the personal data subject under this statement, you can contact Sugar Club

Sugar Club

37 Sukhumvit Soi 11, Bangkok, Thailand 10110

+66 (0) 613 913 111

www.sugarclub-bangkok.com
info@sugarclub-bangkok.com