PRIVACY POLICY

1. INTRODUCTION

   This Privacy Policy explains what information we collect, use, store, disclose and process when you use: our website at www.trueid.ph (the “Website”), our software application that you have downloaded to your mobile device/s (“App”), products, content and all interactive services (“Services”) provided by True Digital Group Co., Ltd., its parent company, affiliates and subsidiaries (“TrueID”, “us” or “we”).

   TrueID respects your privacy and is committed to protecting your personal data and upholding your data privacy rights.

   This Policy is incorporated into and made part of our Terms and Conditions of Use.

2. DEFINITIONS AND CONSTRUCTION

   Unless otherwise provided in this Privacy Policy or the context otherwise requires, the capitalized terms herein shall have the same meaning as provided in the Data Privacy Act of 2012, its implementing rules and regulations or other issuances of the National Privacy Commission.

3. WHO WE ARE AND WHAT WE DO

   True Digital Group Co., Ltd. is a subsidiary of True Corporation Public Company Limited, a leading communications conglomerate in Thailand. True Digital Group’s ambition is to transform Thailand and the region for digital revolutions. Its registered office address is No. 101 True Digital Park Building, 9th – 12th Floor, Sukhumvit Road, Bang Chak Sub-District, Phra Khanong District, Bangkok, 10260, Thailand.

   For purposes of this Policy, True Digital Group Co,. Ltd. is the Personal Information Controller under the Data Privacy Act of 2012 (the “DPA”), since it determines what personal data is processed or the purpose or extent of its processing. Nonetheless, where your Personal Data is disclosed to third parties under a data sharing agreement, the third parties in such case are also Personal Information Controllers.

4. TYPES OF PERSONAL DATA

   We collect and process Personal Data from users, as described below:

   • Identity data including first name, middle name, last name, username or similar identifier, nickname/alias, title, date of birth and gender;
   • Contact data including billing address, permanent and current address, personal and work email addresses and telephone numbers;
   • Financial data including bank account and payment card details necessary to complete the transaction;
   • Transaction data including details about payments to and from you and other details of products and services you have purchased from us;
   • Technical data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website or App;
   • Profile data including your username and password, your purchases or requests, your interests, preferences, feedback and survey responses;
   • Usage data including information about how you use our website, products and services including sites visited, cookies, applications downloaded, videos or photos recorded uploaded or downloaded;
   • Third-party account data including information associated with third-party accounts you use when you create your TrueID account, to authenticate such account, including your list of friends or followers.
   • Marketing and communications data including your preferences in receiving marketing from us and our third parties and your communication preferences.

   If you give us Personal Data or any information about another person, then you confirm that you can:

   • provide consent on his/her behalf for the collection and/or processing of his or her Personal Data;
   • receive notices on his/her behalf; and
   • warrant that you have secured his/her consent for us or have the right to allow us to collect, use, store, disclose and otherwise process his/her Personal Data.

   Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

   The Website or App is not intended for children and minors (under age eighteen). As a parent or legal guardian, please do not allow your children to submit any Personal Data, transact, or otherwise interact with us through this Website or any other form of communication, without your express consent.

5. HOW YOUR PERSONAL DATA IS COLLECTED AND PROCESSED

   We collect your Personal Data when you visit the Website, use the App or provide your Personal Data to us through e-mail or other means.

   When you create your TrueID account and authenticate with a third-party service (e.g. Facebook or Google), we collect, use, store and process information associated with that third-party account, such as your list of friends, or followers. We will never publish something through your third-party accounts without your express permission.

   We use cookies, web beacons, tracking pixels and other tracking technologies when you visit our Website our use or App to enhance user friendliness and engagement and to keep the Website or App operating as smoothly as possible. For our detailed policy on the deployment and use of cookies, please consult our Cookie Policy.

6. PURPOSES OF COLLECTION AND PROCESSING

   You acknowledge, agree and consent to our collection, use, access, retention, disclosure and processing of your Personal Data for the following purposes:

   • to deliver, perform and improve our Services;
   • for the creation and securing of your account on our network;
   • to identify you in our system as a Website or App user;
   • to improve the quality of your experience when you interact with our Website or App;
   • to respond to your inquiries and requests;
   • to send you an email to request you to verify ownership of the email address provided when your account was created;
   • to send you e-mail notices, such as security or support and maintenance advisories;
   • to provide technical support for the Services;
   • to enforce the legal terms that govern your use of our Website and/or App;
   • to develop new services or products;
   • to customize or personalize our Services and content for you;
   • to send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of TrueID;
   • to prevent fraud or other illegal activities including without limitation, copyright infringement on or through the Website or App;
   • to meet any applicable law, regulation, legal process or enforceable governmental request such a court order or subpoena, law enforcement or government agency request or similar processes or requests;
   • for the establishment, exercise or defense of legal claims;
   • to enable or allow our advisers or other third parties to conduct audits, due diligence or other reviews;
   • to fulfill any other purposes related to the above purposes.

   In respect of purposes other than the foregoing, we will ask for your specific consent.

7. DISCLOSURE OF YOUR PERSONAL DATA

   You acknowledge, agree and consent to TrueID disclosing your Personal Data to third parties to achieve the purposes set out above, including without limitation:

   • to third party advisers, suppliers and service providers we have engaged to perform business or operating activities, including the following:

     • provide technical, operational or customer support;
     • fulfill user requests;
     • host and maintain our databases;
     • facilitate creation of accounts;
     • conduct quality assurance testing;
     • investigate, prevent, or take action, in our sole discretion, regarding potentially illegal activities, suspected fraud, situations involving potential threats to any person, us, or the Services, or the violations of our policies or the law;
     • otherwise support our services and our operations;
   • with our parent company, affiliates, subsidiaries, and other members of the TrueID group;
   • with our business partners who sponsor contests or promotions or jointly offer services or features with TrueID;
   • to meet any applicable law, regulation, legal process or enforceable governmental request such a court order or subpoena, law enforcement or government agency request or similar processes or requests;
   • to detect, prevent, or otherwise address fraud, security or technical issues or for other risk management purposes;
   • to protect or defend the legal rights, privacy, safety or property of TrueID (and its parents, subsidiaries or affiliates, or their employees, agents and contractors), or our users or members of the public, whether in urgent or non-urgent circumstances;
   • as a requirement of business transfer, if TrueID or one of our business units undergoes such business transactions like a merger or acquisition by another company, sale of all or part of our assets, or if a substantial portion of our or a business unit’s assets is sold or acquired;
   • in the unlikely event that we go out of business or enter into bankruptcy, where customer information including your Personal Data would be required to be transferred to a third party;
   • for the establishment, exercise or defense of legal claims.

   Some of these third parties may be located in another jurisdiction, and therefore transfer and disclosure of Personal Data to them will be cross-border.

   When the processing of information is outsourced to a third party, the processing will be subject to written agreements between us and the third parties processing the data in accordance with the requirements of the Data Privacy Act of 2012 (as amended from time to time). TrueID shall use contractual or other reasonable means to provide a comparable level of protection while the information are being processed by a third party.

   In certain instances, where we share your Personal Data to third parties who also control the processing of your Personal Data (deciding what information is collected, or the purpose or extent of its processing), the disclosure shall be covered by a data sharing agreement in accordance with the requirements of the Data Privacy Act of 2012.

8. DATA SECURITY

   We have put in place appropriate technical, organizational and physical security measures to protect your Personal Data against unauthorized access or unauthorized alteration, disclosure or destruction. These safeguards vary based on the sensitivity of the information we collect and store.

   The Personal Data we collect about you is stored on a secure, password-protected server and only authorized personnel have access to such information. We use industry-standard encryption technologies with respect to the receipt and transfer of the Personal Data you submit to us on the Website and/or App. Nevertheless, you acknowledge that despite our best efforts, no transmission over the internet and no data storage method can be guaranteed to be safe all of the time.

   You also acknowledge and agree that you will protect against unauthorized access of your account and other user information by choosing strong passwords and keeping your password and account secure (e.g. by signing/logging out after using our Services). You understand that we have the right to assume that any access using your account and password is made by you as the owner of the account.

9. DATA BREACHES

   We shall comply with applicable law, rules, regulations and other issuances on handling data breaches and security incidents, including where required, notification to your or the regulator as where there is an unauthorized acquisition of sensitive personal information or information that may be used to enable identity fraud has been acquired by an unauthorized person, and is likely to give rise to a real risk of serious harm to the affected data subject.

10. DATA RETENTION

    You acknowledge, consent and agree that your Personal Data shall be retained or stored for such period as may be required by applicable law, or as may be needed to enable us to fully, effectively and efficiently achieve the Purposes.

11. YOUR LEGAL RIGHTS

    You have rights under data privacy law and regulations, which include:

    • The right to access your Personal Data;
    • The right to make corrections to your Personal Data;
    • The right to object to the processing of your Personal Data including processing for direct marketing, automated processing or profiling.
    • The right to erasure or blocking of your Personal Data from our filing system (i) if there is no other legal ground or overriding legitimate interest for the Processing, or (ii) when there is substantial proof that your Personal Data is incomplete, outdated, false, unlawfully obtained, used for a purpose not authorized, or no longer necessary for the purposes for which they were collected.
    • The right to be indemnified for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of Personal Data, taking into account any violation of your rights as a data subject as provided by the DPA.
    • The right to lodge a complaint with the National Privacy Commission subject to its guidelines for the exercise of such right.
    • The right to data portability which means that where your Personal Data is processed by electronic means and in a structured and commonly used format, you have a right to obtain a copy of such data in an electronic or structured format that is commonly used and allows for your further use, subject to the NPC’s standards, procedures and other rules for the exercise of such right.
    • The right to transmissibility of rights which means that should you pass away or be incapacitated or incapable of exercising your rights above, your lawful heirs and assigns may invoke your rights in your stead.

    The immediately preceding rights are not applicable if your processed Personal Data are used only for the needs of scientific and statistical research and no activities are carried out or no decisions are taken in relation to you, on the basis of such data. Your rights as a data subject remain shall be subject to all other limitations provided by law.

12. UPDATES

    TrueID reserves the right to make changes to this Privacy Policy at any time by giving users notice on this Website page or within the App. You consent to be bound by the terms of this Policy as may be updated from time to time. Please periodically review our Privacy Policy in our Website or App for amendments or other updates.

13. DATA PROTECTION OFFICER

    The Data Protection Officer is the individual principally responsible for ensuring TrueID’s compliance with applicable laws and regulations for the protection of privacy and security.

    Data Protection Officer
    Address: 25/F Menarco Tower 32nd St. Fort Bonifacio Global City, Taguig
    Mobile Number: +63 966 765 5384
    Email Address: DPO.ph@truedigital.com

    If you have any questions, complaints, concerns or comments on our Privacy Policy, we welcome you to contact our Data Protection Officer using the contact details provided above.