ROVULA (Thailand) Company Limited (“Company” or “we”) recognizes the importance of the protection of personal data. Therefore, we have issued our Personal Data Protection Policy (“Policy”) in order to prescribe the process of data collection, storage, usage disclosure, and otherwise processing of your Personal Data (“Process” or “Processing”), and to also provide you with details on the rights you, as the Data Subject, are entitled to. As such, the Company would like to announce this Policy with the following:
“Act” means the Personal Data Protection Act B.E. 2562, as amended from time to time, including any applicable rules, regulations, and notifications issued by virtue thereof. “Data Subject” means an individual who can be identified by Personal Data, whether directly or indirectly. For the purpose of this Policy, Data Subject may refer to our individual client, contact person and/or authorized representative of our corporate clients, individual supplier/service provider, contact person and/or authorized representative of corporate supplier/service provider, or any other individual accessing our website at https://www.rovula.com (“Website”). Data Subject may also be referred to as “you”. “Personal Data” means any information relating to a person which enables the identification of such Person, whether directly or indirectly, but not including the information of deceased persons in particular. “Sensitive Personal Data” means any Personal Data of a particular person which is sensitive and presents significant risks to the person’s fundamental rights and freedoms, which includes data regarding racial or ethnic origin, political opinions, cults, religious or philosophical beliefs, sexual behavior, criminal records, health data, disabilities, labour union information, genetic data, biometric data, or any data which may affect the Data Subject in the same manner, as prescribed by the Personal Data Protection Committee. “Personal Data Protection Committee” means the Committee appointed under the Act, which is in charge of the duties and authorities to govern, issue criteria or measures or provide any other guidance as prescribed by the Act.
2. Collection of Personal Data
In provision of the Company’s services to the Data Subject, the Company will collect Personal Data within the purpose, scope, and lawful and fair methods as necessary and required for such provision of services, and for the purposes described herein this Policy. Accordingly, the Company will inform the Data Subject to gain acknowledgment and, if legally required, consent through electronic or other methods as specified by the Company. In case the Company needs to collect your Sensitive Personal Data, the Company shall request explicit consent from the Data Subject before or at the time of such collection, except for when the collection without explicit consent is allowed by the Act, or other applicable laws. The Personal Data which the Company will collect includes: (a) Identification information such as full name, date of birth, nationality, address, profession, telephone number and email; (b) Information related to banking information such as bank account number and details; (c) Certificates, permit and/or licenses relating to drones and controlling of drones;
3. Sources of Personal Data
The Company has received Personal Data directly from the Data Subject, and the Company will collect your Personal Data from the following steps of provision of our services: (a) When the Data Subject registers for membership, or applies for any of the Company’s services; (b) Voluntarily, when the Data Subject fills out any survey, or any communication with the Company via email or any other communication methods; (c) Through the use of the Company’s Website via Data Subject’s browser’s cookies;
4. Purpose of the Processing of Your Personal Data
The Company Processes your Personal Data for the following purposes or activities: (a) To proceed with your request to enter into a contract with us in order to receive our services; (b) To perform our contractual obligations, including, to provide services to you according to our agreement; (c) To enable and facilitate you in register as a user on our Website, and to enable you to access and obtain services on our Website; (d) To analyse, assess and improve our products and services; (e) To analyse, assess and improve the functionalities, layouts and contents of the Website, and to ensure that our Website will function properly and securely; (f) To process your Personal Data for tax and financial-related matters; (g) To communicate with you regarding any of your inquiries, concerns, requests or complaints; (h) To monitor, detect and investigate whether the Website is used for illegal or unlawful activities; (i) To comply with and/or perform our legal obligations under applicable laws, rules, and regulations to which the Company are subject; and (j) To process your Personal Data for purposes necessary for our lawful business operations. Where your Personal Data is required for the purpose of proceeding with your request to entering into a contract with us, or to perform contractual obligations, failure to provide Personal Data in said circumstance may result in us being unable to proceed with your request or to perform our contractual obligations, including, without limitation, our inability to provide you with our services, either in whole or in part. If your Personal Data is required for the purpose of performing legal obligations, failure to provide your Personal Data in such circumstance may result in us or you being in violation or non-compliance with the applicable laws, rules or regulations. The Company will not Process your Personal Data for purposes which are different from the purposes that have previously been notified to you, except for when: (a) the Data Subject has been informed of such a new purpose, and prior consent is obtained; or (b) the collection and/or Processing of Personal Data for such new purpose is permitted by the Act.
5. Disclosure and Cross-border Transfer of Your Personal Data
The Company may disclose your Personal Data to the Company’s affiliates or third parties who/which provide services or goods to us, domestically and internationally, including, our business partners, suppliers, information technology service providers, auditor, accounting firm, auditing firm, and legal counsel. Company shall govern the above-mentioned persons to treat the Personal Data as confidential and not to use the data for purposes other than those specified in this Policy. For cross-border transfer of your Personal Data, the destination country of which the recipient of your Personal Data is located at may not have adequate personal data protection standards as required by the Act. Notwithstanding that, we will implement and procure the recipient of your Personal Data to implement adequate personal data protection standard to ensure that your Personal Data will be securely protected and to ensure that any such cross-border transfer will be carried out in accordance with the Act and any other applicable laws and regulations. The Company may disclose your Personal Data to relevant third parties in the event of business transfer, merger and acquisition, or any other similar types of transaction. The Company may also disclose your Personal Data as required by laws and regulations, such as disclosing it to a government agency, state enterprise and regulator. Also, the Company may disclose it by virtue of laws, such as requests for the purposes of litigation or prosecution, or order of the governmental authorities or courts, or requests made by the private sector or other persons involved in the legal proceedings.
7. Rights of Data Subject
6. Storage of Personal Data
The Company shall retain and Process the Personal Data for as long as necessary only for purposes described herein this Policy. Generally, the Company will store your Personal Data for as long as you still use the Company’s services, and for a period of 10 years from the date of which the Data Subject ceases to use the Company’s services, unless otherwise required by applicable law. After the end of the period specified in this Clause 6, the Company will delete, destroy or de-identify your Personal Data within 30 days, unless otherwise required by applicable law.
The Data Subject is entitled to request any actions regarding their Personal Data as per the following: (a) Right to withdraw consent; (b) Right to access: to request access to and obtain a copy of the Personal Data, including to request the disclosure of the acquisition of the Personal Data obtained without his or her consent; (c) Right to rectification; (d) Right to erasure; (e) Right to request the suspension of Processing; (f) Right to data portability (if any); and (g) Right to object to the Processing of Personal Data. Data Subject may request to exercise any of these rights by sending or submitting a request to exercise right to the Company in writing or via email, using the form prescribed by the Company and the Contact Information provided in Section 10. below. The Company will respond with your request to exercise any of the rights above within a reasonable period. However, for the request to exercise the right to access, we will respond to such request within 30 days from the date of receiving your request. Notwithstanding that, should there be any circumstances which render us to be unable to respond to your request within said period, we will promptly inform you of such delay accordingly. Your entitlement to exercise any such rights is subject to limitations and conditions imposed by the Act and therefore, the Company may deny your request pursuant to the terms of said Act. You are also entitled to lodge complaint to the personal data protection supervisory authority in Thailand if you opine that our Processing of your Personal Data does not comply with the Act. However, we would encourage you to first contact us to resolve any of your issues or concerns before lodging complaints to said authority.
The Company is using the “cookies” on the Website. The Company's cookies will tag your hard disk to enable the Company to study and collect required data about your usage of the Website and information therein. Such collected data shall be used for the following purposes: (a) to enable you to sign in to our Website; and (b) to study your Website usage in order to improve the usage to be easier, faster and more efficient.
9. Review and Changes of Policy
The Company may review and update this Policy from time to time to ensure that it remains in adherence to applicable laws, any significant business changes, and any suggestions and opinions from other organizations. Where the change involves with change in purpose of the Processing, we will notify you of such new purpose, and if legally required, to take necessary actions to obtain your consent prior to such change becomes effective. This Policy is last updated on 12 April 2021.
10. Contact Information
If you have any inquiries or concerns regarding this Policy or how we handle your Personal Data, or if you wish to exercise any of your rights to your Personal Data as described above, please contact us at: ROVULA (Thailand) Company Limited 33, 31, 31/1, 1st Floor, Bhiraj Tower at Sathorn Building, South Sathorn Road, Yannawa, Sathorn, Bangkok 10120 Thailand.
Tel: 02-078-4000 Email: [email protected]