Neo Corporate Public Company Limited (“Company”, “we”, “us”, or “our”) places importance on your personal data protection while receiving our products and services. We know you care how your information is collected, used, disclosed, and transferred to a foreign country. We will use the data that you have provided to us to offer you the products and services you need and want, appropriately tailored for you, which may be offered both from us and any companies within the data ecosystem of Neo group. The Company would like to thank you for putting your trust in the Company. We will handle your personal data with reasonable care in order to give you the best experience and customer service.
This privacy policy (“Privacy Policy”) applies to websites, social media channels, online communication channels, and all other locations where your personal data is collected. However, please read this Privacy Policy in conjunction with the terms and conditions of the particular service that you use.
According to this Privacy Policy, “Personal Data” means “any information in relation to a person which leads to the identification of such particular person as provided below”
The Company reserves the right to amend this Privacy Policy from time to time; therefore, please regularly check for the most updated version of this Privacy Policy. Any changes to this Privacy Policy will become effective immediately when we post the updated Privacy Policy on our websites. We will inform you of any significant changes and updates. In the case where such change or amendment deprives you of your rights concerning sensitive data pursuant to this Privacy Policy, the Company will ask for your consent in advance unless otherwise specified by law.
We may collect or obtain the following types of data, which may include your Personal Data, whether directly or indirectly from you, from other sources, or from Neo group, affiliates, subsidiaries, business partners or other companies. The nature of the collected Personal Data will depend on the communication context and the interaction between you and us, including the services or products you need or want from us and within Neo group.
If you have provided us with Personal Data of a third party (e.g., beneficiary, emergency contact person, referral, and references) e.g., name, surname, address, telephone number, personal income in a family, and personal information and other information for emergency contact, for filing an application or making a transaction with us; please inform this Privacy Policy for their acknowledgement and/or ask for consent from such third party for us, if required.
We will collect, use, or disclose sensitive data only when your express consent is obtained or as permitted to do so by law.
We will collect information of a minor, a quasi-incompetent person, and an incompetent person only when guardian’s consent is obtained. When consent is required, we will not collect information from a customer who it is explicitly known to us that he/she is under 20 years of age or from a quasi-incompetent person and an incompetent person without their guardian's consent. In the case where we learn that we have unintentionally collected Personal Data from any person under 20 years of age, a quasi-incompetent person, or an incompetent person without guardian’s consent, we will delete such data immediately or process only part of such data to the extent permitted by other lawful bases other than consent.
2.1 The purpose requiring your consent
Marketing and communications: We will collect, use, and disclose your Personal Data for providing you privileges and promotions, news, discounts, special offers, advertisements, notifications, information, marketing and communication regarding the products and services from Neo and its affiliates, subsidiaries, and/or business partners, which we cannot rely on other lawful bases.
2.2 The purposes and other lawful bases we use for processing your Personal Data
We may rely on (1) contractual basis, for our initiation or fulfilment of a contract with you; (2) legal obligation, for the fulfilment of the legal obligations; (3) legitimate interest, for the purpose of our legitimate interests and the legitimate interests of third parties; (4) vital interest, for preventing or suppressing danger to a person’s life, body, or health; and/or (5) public interest, for the performance of a task carried out in the public interest or for the exercising of the rights of government officials.
We may collect, use, and disclose your Personal Data for the following purposes:
If you fail to provide your Personal Data when being requested, we may not be able to offer or provide our products and services to you.
We may disclose or transfer your Personal Data to the below third parties who collect, use and disclose Personal Data in accordance with the purposes under this Privacy Policy. These third parties may be located in Thailand and areas outside Thailand. You can visit their privacy policies to learn more details on how they collect, use, or disclose your Personal Data as you are also subject to their privacy policies.
3.1 Neo Factory Co., Ltd.
As Neo Factory Co., Ltd. is part of Neo Corporate Public Company Limited and there will be collaboration and sharing between the companies of their services, products and systems for their customers including website-related platforms and other systems; therefore, it may be necessary for the Company to disclose or transfer your Personal Data to, or otherwise allow access to such Personal Data by other companies within Neo group for the purposes set out in this Privacy Policy. Please see the company list and the scope of internal activities within the data ecosystem of Neo group.
3.2 Our service providers
We may engage other companies, agents, or contractors to perform services on our behalf or to facilitate the provision of products and services to you. We may share your Personal Data to our service providers or third-party suppliers, including but not limited to: (1) developers of infrastructure, internet, technical infrastructure, software and websites, and IT service providers; (2) warehouse and logistic service providers; (3) payment service providers; (4) research agencies; (5) analytics service providers; (6) survey agencies; (7) auditors; (8) marketing, advertising media, and communications agencies; (9) call center; (10) campaign and event organizers; (11) sale representative agencies; (12) telecommunications and communication service providers; (13) payment, payment system, authentication, and dip chip service providers and agents; (14) outsourced administrative service providers; (15) data storage and cloud service providers; (16) verifying and data checking (Netbay and Department of Provincial Administration) service providers; (17) dispatchers; and/or (18) printing service providers.
In the course of providing such services, the service providers may have access to your Personal Data. However, we will only provide our service providers with the Personal Data that is necessary for them to perform the services, and we ask them not to use your information for any other purposes.
3.3 Our business partners
We may transfer your Personal Data to our business partners in the businesses of banking, finance, providing credit or loan, asset management, investment, insurance, credit cards, telecommunications, marketing, retailing, e-commerce, warehouse and logistics, wellness, lifestyle products and services, spa and fitness, reward and loyalty program, and data analytics, including seller or provider platforms which we may jointly offer products or services, or whose products or services may be offered to you. Data shared by this way will be governed by the third party’s privacy policy and not this Privacy Policy.
3.4 Social networking sites
We allow you to login on our sites and platforms without filling out a form. If you log in via the social network login system, you explicitly consent us to access and store public data on your social network accounts (e.g., Facebook, Google, or Instagram), including other data appeared during the use of such social network login system. Additionally, we may also send your email address to social networks in order to identify whether you are the user of the relevant social networks and in order to post personalized and relevant advertisement on your social network accounts as appropriate.
We also cooperate with other third parties in order to allow you to apply for their services or participate in their promotions. For example, certain companies would allow you to use your loyalty program number or online services login to receive or register for their services. Additionally, you may connect your social network account to your online services account or log into your online services account from your social network account. When you apply for those services, we will share your Personal Data to those third parties. If you do not wish to share your Personal Data in this way, do not provide your loyalty program number or reward program number to the third parties, do not use your online services account to register for receiving third-parties’ promotions, and do not connect your online services account with accounts on third-party services. Data shared by this way will be governed by the third party’s privacy policy and not this Privacy Policy.
3.5 Third parties specified by law
In certain circumstances, we may be required to disclose or share your Personal Data in order to comply with legal or regulatory obligations. This includes any law enforcement agencies, courts, regulators, government authorities or other third parties in the case that believe it is necessary to comply with legal or regulatory obligations, or to protect our rights, the rights of any third party or individuals’ personal safety, or to detect and prevent, or to handle fraud, security, or safety issues.
3.6 Advisors
Advisors shall include lawyers, technicians and auditors who assist in operating business, taking legal actions, or handling any legal claims.
3.7 Associations and organizations
We may transfer your Personal Data to other member associations, e.g., Thailand E-Payment Association (TEPA), Electronic Transactions Development Agency (ETDA), the Association of Confederation of Consumer Organization (ACCOT), Foundation for consumers, the Thai Chamber of Commerce, Thai E-Commerce Association, Thai Retailers Association, Thai Shopping Center Association, or the Ratchaprasong Intersection Group.
3.8 Assignees of right and/or obligations
Third parties as our assignee in the event of any reorganization, merger, business transfer, whether in whole or in part, sale, purchase, joint venture, assignment, transfer or other disposition of our business, assets or stock, or similar transaction, whether in whole or in part; shall comply with this Privacy Policy to respect your Personal Data.
We may disclose or transfer your Personal Data to third parties or servers located overseas, which the destination countries may or may not have the same equivalent level of protection for Personal Data protection standards. We will take steps and measures to ensure that your Personal Data is securely transferred and that the receiving parties have in place an appropriate level of protection standards or other requirements as required by law. We will request your consent for internationals transfer of your Personal Data where consent is required by law.
We will retain your personal data for as long as is reasonably necessary to fulfil the purpose for which we obtained it, and to comply with our legal and regulatory obligations. However, we may have to retain your personal data for a longer duration, as required by applicable law.
The Company is aware of the importance of maintaining the security of your Personal Data. Therefore, the Company puts a great effort in protecting your information by establishing appropriate security measures for your Personal Data which are in accordance with the confidentiality safeguard of Personal Data in order to prevent loss, unauthorized or unlawful access, destruction, use, alteration, or disclosure. The Company will ensure that the methods of collecting, storing and processing of your Personal Data, including physical safety measures follow the information technology security policies and guidelines of the Company.
If you visit our websites, we will gather certain information automatically from you by using cookies.
Cookies are small pieces of information or text issued to your computer when you visit a website and are used to store or track information about your use of a website and used in analyzing trends, administering our websites, tracking users’ movements around the websites, or to remember users’ settings. Some cookies are strictly necessary because otherwise the site would not be able to function properly. Other cookies allow us to enhance your browsing experience, customize contents to your preferences, and make your interactions with the website more convenient as they remember your username (in a secure way) as well as your language preferences.
Most Internet browsers allow you to control whether or not to accept cookies. If you reject, remove, or block the cookies, your user experience may be affected. Without cookies, your ability to use some or all of the features or areas of our websites may be limited.
Moreover, some third parties may issue cookies through our websites to serve advertisements that are relevant to your interests based on your browsing activities. These third parties may also collect your browser history or other information to determine how you reached our websites and the pages you visited when you leave our websites. Information gathered through these automated media may be associated with the Personal Data you have previously provided on our websites.
Subject to the applicable laws and exceptions thereof, you may have the following rights:
If you wish to contact us to exercise the rights in relation to your Personal Data or if you have any queries regarding your Personal Data under this Privacy Policy, please contact us or our Data Protection Officer