Privacy Policy

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Privacy Policy

Lunique Real Estate Company Limited

            Lunique Real Estate Co., Ltd. recognizes the importance and strictly adheres to the rights regarding the privacy of personal data owners. This privacy policy sets out the fundamental principles of the company in managing all personal data received, whether directly or indirectly. As the Personal Data Controller, the company has a duty to strictly inform you about the privacy policy of personal data owners, which describes the collection, use or disclosure of your personal data, your rights as a personal data owner, and we affirm that we strictly comply with this law to protect your personal data.

            Please read this privacy policy carefully to understand how we manage your personal data and your rights regarding your personal data. This privacy policy may change at any time while our relationship with you continues. Therefore, you should revisit this privacy policy from time to time if there are significant changes to our privacy policy that may affect your rights to personal data. We will notify you without delay by announcing it on our website.  

            We recommend that you review the privacy policies of any other websites linked from this website to understand how those websites collect, use, or process your personal data. Lunique Real Estate Co., Ltd. cannot endorse or guarantee any statements or actions made on those websites and we disclaim any responsibility if they fail to adhere to the privacy policies they have published.

  1. Definition of Personal Data

            According to the Personal Data Protection Act, personal data refers any information related to individual that can identify that person, whether directly or indirectly, excluding information of deceased individuals. Personal data can be divided into two categories as follows:

            1.1 General Personal Data

            This refers to personal data that is not sensitive personal data, such as name, surname, gender, date of birth, age, email address, phone number and ID card number.

            1.2 Sensitive Personal Data

            This refers to personal data that requires special protection and must be handled with extra caution in terms of collection, use or disclosure of such information. Examples include personal data related to race or ethnicity, political opinions, religious or philosophical beliefs, sexual behavior, criminal records, health or disability information, union membership, genetic data, biometric data such as facial images, fingerprints, X-ray films, genetic information, iris scans, voice recognition data and any other information that similarly affects the data subject as prescribed by the regulatory authority.

  1. Collection of Personal Data

2.1 Generally, we collect your personal data in the following methods:

We collect your data when:

– You visit our website.

– You provide information to us through the website or application.

– You provide information to us through inquiries made via online channels or traditional methods.

            We collect your personal data to the extent necessary to provide services to you, to respond to your inquiries, and to conduct business in a manner that you can reasonably expect us to use your personal data for that purpose.

            We may collect, use, or disclose various types of your personal data, which can be categorized as follows:

Contact data

            These include information such as name, address, email, phone number, the residential projects you are interested in, budget range for purchasing a project, and reasons for buying a residence.

Usage Data

            These include information such as the websites you accessed before entering our platform, the pages you visit, the amount of time you spend on page, the products or information you search for on the platform, the time and date of your website visits, and data on your website clicks.

Technical Data

            These include information such as your computer’s IP address, browser type, time zone settings, location, operating system, and the platform and technology of the device used to access the website.

Communication Data

            These include information such as email, records of conversations, and other communication-related data.

Contract-related Data

            These include information such as identification number, passport number, address, credit card number, date of birth, and gender.

  1. Sources of Personal Data

3.1 We obtain personal data directly from you through the following channels:

            3.1.1 When you contact our staff, including customer service representatives, to request information about residential projects you are interested in, such as via telephone (which may be recorded), mail, face-to-face meetings, social media platforms, and email.

            3.1.2 When you use our electronic services, interact with us through our website, or use services on our website.

            3.1.3 When you participate in our promotional activities through electronic channels, social networks, or traditional methods.

            3.1.4 When your image is captured by our CCTV cameras while you are at our premises, or through video footage taken by us or our representatives when you participate in events at our location.

            3.1.5 When you submit a job application or provide documents, including your work history and/or resume, for consideration for positions such as staff, directors, representatives, or other roles.

            3.1.6 When you are contacted by our marketing representatives or customer service staff, and you respond.

            3.1.7 When we request information about you and receive personal data related to your relationship with us, such as from business partners, public agencies, former employers, referees, and relevant agencies.

            3.1.8 When you submit various forms to us, including job application forms and any registration forms; and/or

            3.1.9 When you provide your personal data to us for other reasons.

3.2 Personal data obtained from cookies when you visit our website. This information helps us provide better, faster, and more secure services, as well as enhance your privacy when you use our services and/or access the platform.

3.3 Your personal data that we receive from external parties (Third Parties) who collect, use, or disclose personal data on our behalf or under our instructions will not be used beyond the purposes we have defined or instructed. We require these external parties to maintain confidentiality and protect your personal data in accordance with the standards of Thailand’s personal data protection laws.

  1. Purpose of Collecting, Using, and Disclosing Personal Data

            We will collect, use, disclose, transfer, or process your personal data in accordance with applicable data protection laws, for the benefit of all or part of the business, as further described below.

Objective

Data Type

Legal Basis for Processing Personal Data

1) To provide services or support related to information about projects you are interested in, whether through Lunique’s platform, third-party vendors, or for other customer service purposes.

– Contact Information

– Communication Data

1) For the necessity to comply with service contracts.

2) For the legitimate interest of providing information about projects you are interested in.

2) To notify you about projects and the status of transactions, whether conducted through Lunique’s platform or by third-party vendors, and for other customer service purposes.

– Contact Information

– Communication Data

1) For the necessity to comply with contractual obligations.

2) For the legitimate interest in providing services related to projects that align with your needs.

3) To enter into agreements related to real estate transactions.

– Contact Information

– Contractual Information

For the necessity of fulfilling related contractual obligations.

4) To verify and manage financial transactions related to payments you have made via the internet or online.

– Contact Information

– Contractual Information

For the necessity of fulfilling related contractual obligations.

5) To monitor data downloads from the platform, develop the layout, design, and content of various pages on the platform, and customize for users. This includes identifying users, analyzing statistical and behavioral data, and delivering information we believe may be useful to you or that you have requested from us, including information about our products and services and those of third-party vendors, unless you have opted out of such communications.

– Technical Information

– Usage Data

For the legitimate interest in analyzing personal data to gain insights into user behavior and trends, target customers, and improve the website to better meet user needs.

6) Risk management or the assessment, detection, inspection, prevention of, or remediation for breaches of terms and conditions, internal policies, applicable industry standards, guidelines, laws, or regulations.

– Technical Information

– Usage Data

1. For the necessity of preventing breaches of relevant terms, laws, or regulations.

2. For the prevention of fraud or violations of internal policies and applicable industry standards.

7) This disclosure of information may be required by laws or regulations of any country, as mandated by governmental authorities or external entities, including card service providers or other payment networks. Such disclosure may also occur in compliance with court orders, legal requests, or other legal requirements or processes applicable in any country to us or our affiliates.

– Contact Information

– Communication Information

– Usage Data

1. To ensure that the disclosure of information complies with the applicable legal regulations of the relevant country and aligns with orders received from legal authorities.

2. To respond to investigations or requests from regulatory authorities.

3. For security purposes or to comply with financial-related policies.

8) Other lawful business purposes, such as protecting you and other users of Lunique’s payment accounts from loss, safeguarding lives, ensuring the security of our systems and products, and protecting our rights and/or other assets.

– Contact Information

– Communication Information

– Usage Data

– Technical Information

1. To respond to emergency situations related to safety and to prevent potential loss or damage.

2. To protect data from unauthorized access or inappropriate use.

3. To ensure compliance with legal requirements.

 

  1. Disclosure or Sharing of Information

            The Company may disclose your personal data to affiliates or third parties who have collected it with your consent for the purposes mentioned above. This is done to complete transactions with you, manage other relationships with you, comply with legal requirements, regulations, marketing, and other necessary requests for data sharing with such third parties. The Company requires that any third parties to whom we disclose or share your personal data maintain confidentiality and protect your personal data solely for the purposes for which we have specified or directed them to act. These third parties are not permitted to use your personal data beyond the specified purposes. The Company may also disclose or share your personal data with other entities as follows:

– Affiliates

– Marketing Companies or Consultants

– Online Advertising Platforms

– Business or Professional Consultants.

– Regulatory Authorities, such as the Personal Data Protection Committee.

            Upon request, we may disclose your personal data to relevant authorities to comply with the law, such as to prevent threats to life or bodily harm, for law enforcement purposes, legal proceedings, the protection of legal rights, or to prevent fraud.

  1. Data Retention and Retention Period

            The Company will retain your personal data within our system and implement standard security measures to ensure that our system and the use of your personal data are secure, with the following measures:

            – Access to personal data is restricted to only those individuals who need to use such data. Individuals authorized by the Company to access personal data are required to strictly adhere to the Company’s personal data protection measures and maintain the confidentiality of such data at all times.

            – Technological measures are implemented to prevent unauthorized access to the computer system.

            – Arrangements are made to securely destroy your personal data when it is no longer necessary for legal or business purposes.

            – A process is in place to handle cases of personal data breaches or suspected breaches, and any such breach shall be reported to the Personal Data Protection Committee under the conditions prescribed by law.

Retention Period of Personal Data

            – The Company retains your personal data for the period necessary to fulfill the purposes of our services and in accordance with the timeframes prescribed by accounting standards, legal standards, and other relevant regulations.

            – In determining the retention period for personal data, the Company will consider the volume, nature of use, purpose of processing personal data, potential risks arising from unauthorized use, and the timeframes prescribed by applicable laws.

  1. Rights of Data Subjects

            Data subjects have legal rights to request the exercise of various rights under the provisions of the law and the policies currently in effect or as may be amended in the future, as well as the guidelines established by the Company.

7.1 Right to access

            Data subjects have the right to access their personal data held by the Company and to request copies of such data. They also have the right to request information on how their personal data was obtained, especially if it was collected without their consent.

            We will respond to your request as soon as reasonably possible but not exceeding thirty (30) days after receiving your request.

7.2 Right to data portability

            You have the right to request access to your personal data if the Company has made it available in a commonly used and readable format. Additionally, you have the right to request that the Company transfer or transmit your personal data in such a format to another data controller where feasible using automated means. You also have the right to request the direct transfer of your personal data from the Company to another data controller, except where such transfer is not technically feasible.

7.3 Right to object

            Data subjects have the right to object at any time to the collection, use, and disclosure of their personal data if it is conducted for legitimate interests of the Company or others, or for public interest tasks.
If an objection is raised, the Company may continue to collect, use, and disclose personal data only if it can demonstrate that such actions are more important than fundamental rights, are necessary for compliance with the law, or are required for legal claims, as applicable.

7.4 Right to erasure

            The data subject has the right to request the deletion, destruction, or anonymization of their personal data if they believe that the data has been collected, used, or disclosed unlawfully, or if they believe that the company no longer needs to retain the data for the purposes stated in this policy. This right also applies when the data subject exercises their right to withdraw consent or object to the processing of their personal data as mentioned above.

7.5 Right to restrict the processing of your collected personal data

            The data subject has the right to request the temporary suspension of the use of their personal data in the following cases:

– During the process of verifying whether the personal data collected by the company about you is accurate, up-to-date, complete, and not misleading.

– When your personal data should be deleted or destroyed due to non-compliance with the law, but you request the restriction of processing of that personal data instead.

– In any other case where the company no longer needs the personal data for the purposes for which it was collected, used, or disclosed, but you require the data to be retained for the establishment, exercise, or defense of legal claims.

– While the company is awaiting verification to reject your objection to the collection, use, or disclosure of your personal data.

7.6 Right to rectification

            The data subject has the right to request the correction of their personal data to ensure that it is accurate, up-to-date, complete, and not misleading.

7.7 Right to lodge a complaint

            The data subject has the right to file a complaint with the relevant regulatory authority if they believe that the collection, use, or disclosure of their personal data is being carried out in a manner that violates or does not comply with applicable laws.

7.8 Right to withdraw consent

            If the data subject has given consent to the company to collect, use, and disclose their personal data (whether the consent was given before or after the Personal Data Protection Act came into effect), the data subject has the right to withdraw their consent at any time while the company holds their personal data, unless there are legal or contractual limitations that benefit the data subject.

  1. Marketing activities and promotions

            The company may carry out marketing activities and promotions or engage third parties to do so under the following circumstances:

            – If we use your personal data for direct marketing, we will only do so with your explicit consent and after informing you of the purpose of using your data for direct marketing and you may withdraw your consent for direct marketing at any time through our unsubscribe system.

            – In the case of participating in the company’s promotional activities, such as games or activities on various social network channels to promote our products and services to the public, we will not process your data for direct marketing unless you provide explicit consent for us to use your personal data for direct marketing. We will inform you of the purpose of using your data for direct marketing, and you may withdraw your consent for direct marketing at any time through our unsubscribe system.

  1. Websites and services of third parties

            Website of Lunique Real Estate Co., Ltd. may provide links to other websites and services (including applications operated by external parties) for your convenience and information. These services and websites may operate independently from us and may have their own notices and privacy policies. We strongly recommend that you review these policies before using those services or engaging in any activities on those websites. To the extent that we do not own or control the linked websites you visit, we are not responsible for the content, privacy practices, or quality of those services.

  1. Contact channels

            If the data subject wishes to exercise their rights, or if they have any questions or complaints (additional), they can contact us through the following channels:

Company name              Lunique Real Estate Co., Ltd.

Address                         No. 66 Moo 12, Nong Prue, Bang Lamung, Chonburi, 20150.

Website                        www.luniquerealestate.com

Telephone no.               (+66) 96 667 2784

E-mail                           marketing@luniquerealestate.com

  1. Appropriate Authority

            If the data subject wishes to report a complaint or if the company does not address their concerns in a satisfactory manner, the data subject can contact and/or file a complaint with the Office of the Personal Data Protection Committee using the details provided below.

            The Personal Data Protection Committee.

            Telephone no: 02-142-1033

            E-mail: pdpc@mdes.go.th

            Or send letter to: 120 Moo 3, Ratthaprasasanabhakti Building (Building B) Government Complex

                                    The Office of the Personal Data Protection Committee.

                                    Ministry of Digital Economy and Society.

                                    Chaeng Watthana Rd, Thung Song Hong, Lak Si, Bangkok 10210ช

  1. Updates to Personal Protection Privacy Policy

            The company reserves the right to update, modify, or amend this Privacy Policy in the future, or as changes in legal regulations occur. The company will notify you of any changes through our website.

            Users may provide feedback on the Privacy Policy through the contact channels listed in Section 10. However, users agree that the company’s decision shall be final.