DTGO Corporation Limited, its subsidiaries, joint ventures, and all business units (“DTGO”, “we”, “us”, or “our”) recognize the importance of protecting your personal data. This Privacy Policy sets out how we collect, use, disclose and manage (collectively referred to as “process” or “processing”) your personal data, whether the collection is taking place via our websites, applications, any other online platforms, or offline in-person.

This Policy applies to our customers, agents, vendors, suppliers, business partners, contractors, service providers, including their representative and any visitors of our offices (collectively referred to as “you”, “your” or “yours”, “data subject”). 

"Personal Data" means any data that identify you as an individual or relate to an identifiable individual, including but not limited to your name, address, profile picture, email address, phone number, IP address, shopping habits, preferences and information about your lifestyle.

Overview

This Privacy Policy contains the following issues:

• What kind of your personal data we collect 
• How we collect your personal data  
• How we process your personal data  
• Whom we share and disclose your personal data with  
• How long do we retain your personal data 
• Your privacy rights and how you can exercise your rights 
• How do we protect your personal data  
• Changes to this policy 
• How to contact us 

What kind of your personal data we collect

DTGO provide various types of businesses or services, including property development, retail and resale, hotel and hospitality, research and innovation, in line of our businesses, services, and activities, DTGO may collect Personal Data of collect and process includes:  

• Contact data (including names, postal addresses, email addresses, and telephone numbers)
• Account data (including log-in details, email address, and other information provided through your account);
• Data of our Business Partners (including ID Card, household registration no., address, and emails);
• Data you provide to us for example when you fill in forms or during events you attend, or when you answer questions during a conversation or in a survey;
• Any data which relate to our products and services;
• Any other data you provide when you choose to participate in competitions, promotions, events and any activities relating to our business. This may include information you submit to us through “Contact Us” or similar features, whether online or offline; and
• Data collected by Cookies and Similar Technologies, including IP address. This type of collection takes place while you are using online platforms.

How we collect your personal data 

DTGO collect your personal data directly from you in a variety of sources including, but not limited to:

• Online platforms: we may collect your personal data when you register for an account, participate in a survey, contest or promotional offer, subscribe to receive promotional communication or otherwise connect with us.
• Offline interaction: we may collect your personal data from offline, such as when you visit our offices, contact us via phone, or attend our events or give us business cards. 
• In the course of our contracts with you.

We may also collect your personal data from other sources, including open-source material, our business partners, third parties connected to the data subject (for example, another service provider who provides services to the data subject).

How we process your personal data 

DTGO generally process your personal data for the following purpose;  

• providing our products and services; 
• improving the quality of our interactions and services, and facilitating you in using our product or services; 
• contacting you in relation to any competition, contest, surveys you may have entered into with us; responding to your request or complaint; complying with our legal obligations such as financial reporting equirements imposed by our auditors and/or government authorities, and to cooperate with law enforcement agencies, government authorities, regulators and/or the court order in connection with proceedings or investigations;  learning about your online or offline activities which is relevant and interesting to you as well as targeting our marketing for benefits of you;  
• analyzing our activities (interactions with customers, sales, number of appointments or calls) 
• inviting you to free events or promotional activities sponsored by us; 
• sending you offers, promotion or update about our products or services; or 
• other purposes as we may notify you when we request your consent for collecting your personal data.

We may also process your personal data for other purpose if we have obtained your consent, or the processing is permitted or required by laws, including (i) to comply with our legal obligations under Laws (ii) to prevent or suppress a danger to life, body, health of person (iii) to perform a task carried out in the public interest or in the exercise of official authority (iv) for legitimate interests pursued by [MQDC] or by a third party with the reasonable necessity and employee’s expectations. (For example, to sell any part of our business or its assets or to enable the acquisition of our businesses or assets, in whole or part, by third parties, to prevent fraud or criminal activity, misuses of our products or services as well as the security of our IT systems, architecture, and networks).

Notwithstanding the foregoing, we may use your anonymized data for any purpose without your consent.

Whom we share and disclose your personal data with 

DTGO will not share, sell or otherwise disclose your personal data to a Third Party without your consent, except as permitted or required by Laws and to the extent, the disclosure serves the purposes as abovementioned.

In the course of our business activities and to fulfil the purposes, your personal data may be disclosed, either in Thailand or outside Thailand, to the potential recipients, (in each case including its respective employees and director), as follows;

• Other entities in DTGO: when providing personal data to one entity in DTGO may result in that data being accessible by all entities in DTGO . The Disclose will require to conduct activities in a manner consistent with the Binding Corporate Rules and relevant guidelines in relation to personal data protection.
• our supplier or service providers (IT systems providers, cloud service providers, database providers and consultants providing services in relation to any matter on which DTGO  is instructed) where disclosure to that provider of services is considered necessary to fulfill the purposes set out above;
• our business partners who offer products or services jointly with us or with our subsidiaries or affiliates;
• potential parties with whom  DTGO intends to merge or sell the whole or a part of the  DTGO; or
• the government authority or government officer by virtue of the provisions of specific laws to maintain the stability of the State, or to maintain the public order or good moral, and fully comply with the procedures as prescribed by such laws.

Where DTGO discloses or transfers personal data to any third parties, other than DTGO entities, DTGO will enter into an agreement with the third party setting out the respective obligations of each party in place to protect data against unauthorized or accidental use, access, disclosure, damage, loss or destruction.

How long do we retain your personal data 

We will only retain the personal data for as long as necessary to fulfill the purpose (as set out above) for which that we collected it, and to the extent permitted by Personal Data Protection Act B.E. 2562 or other applicable laws. We have prepared schedules to specify the appropriate retention periods to ensure that when we no longer need to use your personal data, and we will remove it from our systems and records and/or take steps to anonymize it so that you can no longer be identified from it.

Your privacy rights and how you can exercise your rights 

Under Personal Data Act B.E. 2562, you may have the following rights that you may exercise in relation to your Personal Data processed by us, as follows: 

1. the right to receive a copy of your personal data processed by us and obtain other information about how do we collect/process your personal data and why we process your personal data. Your personal data will generally be provided to you in electronic form. 
2. the right to rectification of inaccurate, incomplete, or misleading Personal Data relating to you. 
3. the right to request the erasure, destructive, anonymization of your personal data. 
4. the right to request to restrict the processing of your Personal Data.
5. the right to ask that we transfer the personal data to another data controller (or ask us to do so if technically feasible) where our lawful basis for processing the personal data is consent or necessity for the performance of our contract with you and the processing is carried out by automated means.
6. the right to object to any processing which is based on our legitimate propose or other legal ground.
7. the right to withdraw your consent, at any time, where we process personal data based on consent at any time. However, we may continue processing your personal data based on another legal basis.

If you would like to exercise your rights, ask questions, or complain about unlawful processing, you may send your request by filling out the form https://www.bluecarbonsociety.org or to dpo@dtgo.com and we will require you identify before serving your request. We will respond to you in writing via email or mail, as soon as practicable, within 30 days upon receiving your request with clear information.  

However, based on legal grounds as specified in Personal Data Protection Act B.E. 2562, we may not be required by laws to complete your request, as such rights may be conditional or because we have to balance your rights against our rights and obligations to process your Personal Data and to protect the rights and freedoms of others. 

You also have the right to lodge a complaint to the Data Protection Committee if the response is rejected and you are dissatisfied with our reasons or the response is not provided to you within the period.

How do we protect your personal data

DTGO have implemented (have required the third party to implement) an appropriate technical, and physical measures to safeguard and protect Personal Data from unauthorized or unlawful Processing and against accidental or unlawful destruction, loss or alteration or damage, unauthorized disclosure of, or access to, Personal Data.

Change to this Privacy Policy

We reserve the right to update this policy for any reason, including but not limited to complying with relevant the Law of Thailand, Thailand government policy, regulatory and other obligations of a similar nature. Any updates will appear on our website at https://www.bluecarbonsociety.org. Any changes to this Privacy Policy will become effective upon publishing Privacy Policy.

How do you contact us

DTGO is deemed to be a Data Controller under Personal Data Protection Act B.E.2562. If you have any question or would like to exercise your rights, you may contact us at the following address: 

Attn:Personal Data Protection Office 

Address:DTGO Corporation Limited, No. 695, Sukhumvit 50, Sukhumvit Road, Prakanong, Klongtoey, Bangkok, 10260.

Email:dpo@dtgo.com

Phone:02-742-9141