Personal Data Protection Policy of Real Quality Residence

Real Quality Residence Company Limited (hereinafter referred to as the "Company") have established a "Personal Data Protection Policy" in order to prevent leakage, use and modification of the customer's personal data provided to the company. In the event that you ("Data Owners") visit the company's website including using various services as shown on the website, desktop, mobile phone and tablets, and other upcoming devices such as requesting information, posting pictures, making appointments, sending comments for applying the membership or using services which shall request additional information etc. The company realizes the importance of the protection of customers' data, shareholders, directors, employees, vendors, contractors, village members in the project and/or persons related to the company's business (hereinafter referred to as the “Data Owners"). The data owners will receive complete protection of their personal data pursuant to the Personal Data Protection Act 2019. Therefore, the company shall issues this personal data protection policy to enable the data owners having knowledge of the company's personal data protection policy. This personal data protection policy explains how the company will treat personal data such as data collection, retention, use, disclosure including the rights of the personal data owners, etc.

The company would like you to read and understand in respect of the company's personal data protection carefully and in the event that you are unable to accept the said company's personal data policy for the use of this website whether in whole or in part, then; please immediately cease the use of this website. However, in the event that you continue to use this website, it shall be deemed that you accept the company's personal data policy in all respects.

The Company's Personal Data Policy

1. Definition

"Personal Data" means the information that can personally identify you or may be able to identify you either directly or indirectly such as your name, email address, company name, job title and company address, date of birth, home address, phone number, ID card number, identity of online service users such as social media accounts, marital status and family details, etc., but not including information of the deceased in particular.

“Sensitive Personal Data” means the information that is truly personal but it is sensitive and may be at risk of unfair discrimination such as race, political views, religious, philosophical beliefs, sexual behavior, criminal records, health information, disability, union information, genetic and biological information or any other information which it shall be affected the personal data owners in the same way as prescribed by the Personal Data Protection Committee. “Cookies” means the information placed on your computer by the web serve. After a cookie has been placed on your computer, the cookie will store or remember the user's information until the user closes the browser or until the user deletes or rejects cookies.

There are two types of cookies :

• A first-party cookie is created and stored by the website you are visiting directly. The website is displayed in the address bar.
• A third-party cookies which other websites were created. These websites own certain content such as advertisements or the images you see on the pages visited.

2. Scope of the company's personal data protection policy

This personal data protection policy is used under this website www.realasset.co.th and other websites of affiliated company, cookies, subdomains, or related websites and/or applications on mobile devices and tablets and other future devices for the said website which you have provided through the company's channels, both offline and online whether it is a visitor or registered users for the use of company's website.

If you log in, visit or register our website and other websites of affiliated company, cookies, subdomains, or related websites via the third person such as Facebook, Instragram, Google, Line, etc., you are required to comply with these terms and conditions upon accessing our website and other services which can be accessed within the platform on this website, however; the additional personal data protection related provisions may be posted in the service for your approval before accessing such service.

This personal data protection policy shall not apply to information which will be disclosed or transmitted to :

1. A third party services including a third party websites which you may access through our website; and
2. Other companies or organizations which have advertised their products or services on our website.
3. Purposes for collecting personal data

To give the consent to the company in order to perform the collection, retention, disclosure, processing or using personal data for the following purposes :

• to publicize, communicate, inform various news and information, present a project related to products and/or company services;
• the company will collect and use the necessary information in order to issue important documents for reservation transactions, sale and purchase contracts, various agreements, procurement, financial transactions, both in case of reservations/purchase orders via online channels (Online Booking) or regular channels;
• to prepare marketing plans, analyze, process data, create a database, survey customer opinions, conduct company activities, contact and coordinate including improving, developing processes, operating products and/or services of the company;
• to deliver for the third party or our business partners in connection with the product and/or company services such as in the case of hiring another person or agency to operate in respect of personal data of customers for parcel delivery, sending an e-mail, public relations, communication, informing various news, surveying opinion polls, statistical analysis of the business or activities of the company, etc. The company shall prohibit any person or agency that has been hired to collect, use, disclose information or to perform any other action than the purpose subject to this provision;
• to verify your identity, protect the security of your user account, inform you about upcoming changes (upon visiting the company's website, you may be asked to register with us and/or you may be required to provide your personal data to the company);
• to administer the website for internal operations, fix website problems, analyze data, test and research for safety, inspect for distortion and manipulation of user accounts, provide information for accessing and using the company's website and improve the user’s experience; and
• the company shall not use or disclose your personal data unless it is used or disclosed for the purposes stated above or it is a disclosure to the person in the company or the person involved in the contract or the company shall comply with the law or relevant rules and regulations or have your consent.

4. The period of storage of personal data

The company shall collect your personal data as long as necessary for the purpose or as required by law or until the data owners request the company not to keep and use such personal data anymore. The company has suitable security measures to prevent unauthorized access, collect, use, disclose, reproduce, modify and dispose such information or to prevent a similar risk without permission.

5. Collection of Personal Data

For collection, use and disclosure of personal data, the company will make your acknowledgment and give your consent through electronic systems or as determined by the company, except such the condition cannot give the consent. In case of collection, use, disclosing the information in respect of the sensitive personal data, the company shall ask for your explicit consent before proceeding unless such collection of personal data and sensitive personal data are exempted by the Personal Data Protection Act 2019 or provided by other laws.

The company may collect, use and disclose your personal data which the company receives directly or indirectly through documents, website, cookies, sub-domains or related websites, a third party such as Facebook, Instragram, Google, Line or specified by the company for the following personal data below :

• first name, surname
• nickname
• ID card number
• photos
• date of birth
• gender
• nationality
• address as per ID card
• address as per house registration
• address for sending information, documents, receipt
• workplace name, work address and its phone number
• e-mail address
• facebook account / line account / instragram account / wechat, google
• phone number, mobile phone number, facsimile number
• marital status - single, married, widow / divorced
• education
• occupation
• job position
• personal income
• family income
• ID card number
• photos of attending the event
• the behavior of browsing the website by the company uses cookies as a tool to collect information such as
• IP address
• the type of web browser used to access the web pages visited
• websites which refer to the company's website
• the history of visited websites
• the history of searing project information, products and/or services of the company
• duration of visiting the website and application, date and time of your visit to the website, and other statistics
• browser type
• preferences/favorites, interests such as product and service styles that interest you, hobbies, activities, social networks used in sports or travel.
• information for making decisions on whether or not to select products and services such as the reason for purchasing or choosing the house, budget, purpose, other products for comparison, reviews of products and services and information on visits to products and services.
• other information such as media that makes you aware of products and services, the reason you want to find a new residence, purchase purpose, usable space, room type, house type that interest you, what factors influence the purchase decision, duration of making a purchase decision and location that you are interested in purchasing.
• information that identifies your location when using the website, in the even that you enable the GPS system, it shall be considered that you give the consent to the company for collection and process the location of your area while using it, however; you are able to install programs or turn off the GPS system on your mobile phone if you wish to hide this information.
• information which you need to provide to us and the company can collect, use, disclose and process such personal data as required by law without having your consent as the following :
• to comply with a law or contract or it is necessary to provide information to enter into a contract or any other information as required by law and if you do not provide your personal data to the company, the company may not be able to do it for you as you wish or which the company has notified to you or has any other legal effect.
• for the legitimate interests such as storing your photos in company events, etc.
• for the benefit of investigation of the inquiry official or the judgment of the court.
• for the legitimate interest of the company or any person or juristic person other than the company.
• to prevent or suppress the danger to life, body or health of a person.
• to achieve objectives related to the preparation of historical or archival documents and for the benefit of public, education, research, statistical purposes which provide appropriate preventive measures.

6. Other rights of the data owners

The data owners are entitled to as follows :

6.1 entitled to access your personal data held by the company and obtain copies of those personal data including request to disclose the acquisition of your personal data without your consent.

6.2 entitled to transfer personal data and you are entitled to obtain your personal data in the event that the company has made the personal information in a readable format or commonly used by automated tools or equipment and can use or disclose personal data by automated means. Also, you are entitled to request the company to send or transfer the personal data in such form to another data controller when it can be done by automated means and have the right to receive personal data which the company has sent or transferred personal data in such form to another controller of personal data directly if technical condition can be done.

6.3 entitled to make the objection for its collection, use or disclosure of personal data, you are entitled to make the objection for the collection, use and disclosure of your personal data if your data is collected by the company without your consent or such data is collected, used or disclosed for the direct marketing purposes or for the purposes of research studies in science, history, statistics.

6.4 entitled to delete, destroy or suspend the use, you are entitled to request the company to delete, destroy or suspend the use of your personal data which the company has maintained or request the company to take action by turning personal data into non-personally identifiable information which owns such personal data.

6.5 entitled to rectification of personal data, you are entitled to request the company to correct the personal data which stored by the company to be the latest update content and complete and not cause any misunderstanding.

6.6 entitled to withdraw the consent, you are entitled to withdraw your consent for the collection, use and disclosure of your personal data, however; the company may collect such data for the purpose of monitoring the provision of services to you or comply with the law and the company will not use your personal data for any purpose.

The data owners can apply for the aforementioned rights by submitting a request to exercise the rights to the company in writing or an e-mail in the form specified by the company via “the company's contact channels" below. The company will consider and notify the result of said consideration according to such request of the data owners within 30 days from the date of receiving such request, however; the company is entitled to deny the right of the data owners as provided by law.

7. Exceptions to protection of personal data

In the event that it shall not be considered a violation of the personal data protection policy as the following :

7.1 such personal data has been made public since the time you disclose it to the company or be disclosed to the public by not the fault of the company.

7.2 disclosure of personal data with your consent whether in writing or permission by any other means.

7.3 disclosure of personal data as necessary due to comply with the law, order, regulation, court order, government agency or as other necessities as required by law.

8. Measures to Maintain the Security of Personal Data (Data Security)

The company has reasonable security measures in place to prevent infringement, access, collection, use, disclosure, copying, modification, disposal or similar risks without permission and has both management measures (Organizational Measure) and (Technical Measures) such as the security information system, customer confidentiality policy, establishing procedures to deal with infringements of personal data (Data Breach), etc. In addition, employees, staffs and external service providers of the company are also obliged to maintain confidentiality of personal data in accordance with the signed contract with the company.

However, the transmission of information via the internet is still limited to maintain security and the company cannot guarantee the security of the information which you disclose through online channels. Therefore, the company shall not be liable for any damages or losses incurred either directly or indirectly from unauthorized access to information which you provide on the company's website, except in the event that the company is neglectful.

9. Disclosure of Personal Data

The company may disclose your personal data to the third person in order to comply with the purposes related to the collection, use and disclosure of personal data as detailed mentioned above or with your prior consent as detailed below :

• The company's affiliates, supplier /outsource/service provider to which the company is a contractual party both in Thailand and abroad such as the cloud computing, service providers, marketing activities company, research company, information technology development company, financial business group, sales sponsors, financial institutions, business partners of the company by other persons or entities to whom the company discloses personal data may be collected and can only be used for the purposes specified in the details above.
• Government agencies or regulators to comply with the law or in accordance with the orders of government agencies such as the Revenue Department, Legal Execution Department, Royal Thai Police and any person as required by applicable laws or regulations or in other specific cases, such as in accordance with court orders, including auditors.
• For the exercise of the company's claims or is subject to contractual or legal disputes.
• Those interested in investing in the company and/or its affiliates for inspection and analysis the status of the business (due diligence) and either a joint investment or a sale of all or part of the business or assets.
• Disclosing information to the third person as your consent or you have informed the company to disclose or disclosing to use the service according to your wishes.

10. The Amendment of Personal Data Protection Policy

The personal data protection policy of company may be modified or amended without prior notice. However, if said amendment will be occurred, the company will display the current version of the said policy on the company's website.

11. The channels contact of company

Real Quality Residence Co., Ltd.
1768, New Petchaburi rd., Bangkapi sub-district, Huai Khwang district, Bangkok 10310.
Phone: facsimile: 66 (0) 2076-1232
E-mail: dpo@realasset.co.th
(Weekdays can be contacted at 9:00 AM - 5:30 PM except on Saturdays, Sundays and public holidays.)

Note: Real Quality Residence Company Limited is a subsiding of Real Asset Development Company Limited