PRIVACY, COOKIES AND DATA PROTECTION POLICY

Minor Corporation Public Company Limited and Minor Lifestyle Group (“We”) respect your privacy and are committed to protecting your Personal Data including maintaining the security of your Personal Data. We have created this privacy statement to inform you of details of the collection, use, and disclosure of Personal Data including various rights yours according to law.

This Privacy Statement is in a layered format so you can click through to specific points listed below.

Details of the Data Controller and Minor Lifestyle Group of Companies
How do we collect your Personal Data
Purpose for collecting your Personal Data
Personal Data we collect about you
Minors, incompetent person, quasi-incompetent person
Disclosure of Personal Data
International transfers
Cookies
Data Retention
Security of your personal data
Your rights
Liability
Changes to this Privacy Statement
Contact the Data Protection Officer

Details of the Data Controller and Minor Lifestyle Group of Companies

Our Brands	Company name	Address	Website
Minor Smart Kids	Minor Corporation Public Company Limited	88 The Parq Building, 12Fl. Ratchadaphisek Road, Klongtoey Subdistrict, Klongtoey District, Bangkok 10110	www.minorsmartkids.com
Minor Plus	Armin Systems Company Limited		www.minorpluscard.com
Charles & Keith	Armin Systems Company Limited		www.charleskeith.co.th
Bossini	Armin Systems Company Limited
Anello	Minor Fashion Company Limited
Joseph Joseph	Minor Lifestyle Company Limited
Zwilling J.A. Henckels	Minor Lifestyle Company Limited
Berghoff	Minor Lifestyle Company Limited

How do we collect your Personal Data

This privacy statement also aims to provide information about how we collect and process your Personal Data through your use of this website and other services (both online and offline channels such as Call Center, etc.) (the “Services”), which allows you to access this Privacy Statement includes any information you may provide when you use our following services.
1. Using our services, such as using services at our stores, contacting our customer service, applying for a Minor Plus card accessing websites/ mobile applications/ social media pages owned or controlled by us
2. Participating in activities that we organize, such as participating points collection activities, and prize redemption activities that we and our business partners organize together
3. Security system when you visit our service location information about you may be collected through the CCTV system and/or other security systems installed within the location.
In any case that you provide the Personal Data of another person to the company, you represent that you have received consent or authorized by laws to provide their information to the company for the purposes specified in this notice. You will be responsible for any information provided that is false or inaccurate and for any direct or indirect damages incurred by the company or with the data subject.
Purpose for collecting your Personal Data

We will process Personal Data as described in this statement and will always comply with Thailand's applicable personal data protection laws in the following cases:
1. When we receive your consent for cases where consent is required by law.
2. To carry out your request before entering a contract or for the performance of a contract between you and the company.
3. It is necessary for the legitimate interests of the company or of another person or legal entities unless such benefits are less important than your basic rights in Personal Data.
4. It is a case where the company must comply with the law.
5. To prevent or stop danger to an individual's life, body, or health (if any).
  
  We collect, use, or disclose your Personal Data to the extent permitted or required under applicable law for the following purposes:
  - To perform the contract, process, and manage the purchase or use of the Company's products and services for you including applying to be our member, user verification steps, order preparation, changing or canceling an order, order delivery, redeeming accumulated points, participating in your account and program and access to the site and services through various channels both online and offline.
  - To answer your questions, act according to the complaints you have made to us or do anything to respond to your inquiries or other activities on the site or any other customer service platform.
  - Communicate with you by post, telephone, email, telephone messages, and our Live Chat regarding orders or purchases. Your use of the service participating in your account and program contests or sweepstakes in which you have entered and your request for information.
  - To inform and communicate with you by telephone messages, e-mail, and through our site and other online channels about our brands, products, news, events, offering our products, services, and promotions including co-branded offers and offers of the group of companies and business partners.
  - Personalized marketing and promotions
  - Ask for feedback or participate in surveys (including customer satisfaction surveys), market research, and/or analysis for statistical and aggregated purposes so that we may monitor, develop, and improve the quality of our products and services and test and develop our systems and prevent the use of our services in a wrong or inappropriate way.
  - To develop our products, services, and related operations.
  - To carry out business planning, reporting, and forecasting.
  - To manage risks, audit supervision, and corporate management within the organization, such as to detect and prevent corruption, and to check requests for using the company's internal information system.
  - To comply with laws, regulations, rules, requirements, and our legal duties. To report or disclose information to government agencies according to law, such as the Revenue Department, or when receiving a summons, warrant of seizure from the police government agencies, courts, or other law enforcement agencies for investigation according to legal processes and other regulations including for the establishment of legal claims complying with or exercising legal claims or raising legal claims to fight.
  - To transfer rights, duties, and any benefits according to the contract between you and the company, such as a merger or contract transfer which was done in accordance with the law.
Personal Data we collect about you

We may collect, use, store, and transfer various types of personal data about you which we provide for different purposes as follows:
1. Personal Data related to your identity verification such as first name, family name, date of birth, national identity number, passport number, gender, and photos.
2. Contact information such as email, address, and phone number, if you contact us through our social media sites. We may collect your usernames and other relevant details.
3. Personal Data related to your user or member accounts such as account name, password, and customer profile details participating in programs with our other relevant business partners.
4. Personal Data related to your orders and payments such as billing address, credit card number, and debit card number.
5. Other personal Data such as geolocation information, information relating to your use and interaction with our website and social media, information requested by government agencies to carry out their legal duties, information about collecting points, information on interest in products and marketing activities, demographic information, your comments or feedback, your questions or suggestions, and information on other issues that you may be interested in us, and also your photos at our events.
6. Sensitive Personal Data
  Generally, we do not collect your sensitive Personal Data (this includes race or ethnicity, religious/philosophical, beliefs, sexual behavior, political opinions, labor union membership, genetic, and biometric data) and we do not collect any information regarding criminal record. However, only for customers who use our “Dermatoglyphics Analysis” product (life guide to success) of Minor Smart Kids, we must collect, use, or disclose their fingerprint information for analysis services as you enter into a contract to purchase Dermatoglyphics Analysis product (our life guide to success).
Minors, incompetent person, quasi-incompetent person

Our website is intended to be serving only persons who are at least sixteen (16) years of age. Nevertheless, if you are a person under 20 years of age (a “minor”) or a person who does not have the legal capacity to give consent, you confirm that you have received consent (on a case-by-case basis) from the following persons:
1. The holder of parental responsibility over the minor in the event that the minor’s giving of consent is not any act which the minor may be entitled to act alone or when the minor is below the age of ten (10) years.
2. The guardian with authority to act on behalf of the data subject who is an incompetent person.
3. The custodian with authority to act on behalf of the data subject who is a quasi-incompetent person.

Disclosure of Personal Data

We may disclose your Personal Data to the following third parties:

Our service providers	We may share your personal data with third-party service providers who provide data processing services to us, such as credit card and payment processing, to facilitate the delivery of our products and online services and advertising tailored to your interests. Our third-party service providers will only process Personal Data as needed to perform their functions. They are not permitted to share or use the Personal Data for any other purpose.
Group of companies	We may share your Personal Data among our Group of Companies to send marketing communications, and perform the service requested by you (including customer services) and internal (audit/compliance) investigations.
Our business partner	We may share your Personal Data with business partners with whom we may jointly offer products or services. You can tell when a third-party business partner is involved in a product or service you have requested because their name will appear, either alone or with ours. If you choose to access these optional services, we will share your Personal Data with those partners. An example of a business partner would be a third-party loyalty program where you will earn points through the use of the Services, including the MinorPlus loyalty program. Besides, we may transfer your Personal Data to our business partners such as banks, telecommunications providers, retail, and e-commerce, with whom we jointly offer products or services, or whose products or services may be offered to you. Personal Data shared in this way will be governed by the third party’s privacy policy and not this privacy statement.
Social networking sites	We allow you to log in on our sites and platforms without the need to fill out a form. If you log in using the social network login system, you explicitly authorize us to access and store public data on your social network accounts (e.g. Facebook, Google, Instagram), as well as other data mentioned during the use of such social network login system. In addition, we may also communicate your email address to social networks in order to identify whether you are already a user of the concerned social network and in order to post personalized, relevant adverts on your social network account if appropriate.
Government Authority	In certain circumstances, we may be required to disclose or share your Personal Data in order to comply with a legal or regulatory obligation. This includes any law enforcement agency, court, regulator, or government authority.
Professional advisors	Advisors, lawyers, technicians, and auditors who assist in running our business and defending or submitting any legal claims.
Business Reorganization	We may share your Personal Data in case of any sale, assignment, or other transfer of our business or transition of service to another provider. We will ask for your consent if required by applicable law.

International transfers

We may transfer your Personal Data to another jurisdiction, insofar as it is necessary to fulfill the purpose for which Personal Data was collected. Your Personal Data may be transferred to the following locations:
- Countries where our corporate offices and/or our servers are located.
- Countries in which we manage and operate outlets, and/or sales offices, and
- Countries where our third-party service providers, advisors, and consultants are located, which changes from time to time.
Where Personal Data is transferred to a country with a lower level of data protection as compared to the country in which the information was collected, we take all reasonable steps to ensure that your information and privacy are protected in line with the applicable legal obligations. Whenever we transfer your personal data, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- Where we use certain service providers, we may use data processing contractual clauses that provide sufficient protection measures and enable the enforcement of the data subject’s rights. Or
- We could use the consent of the data subjects as well as any other legal basis that the applicable law provides.
Cookies

We use cookies (small text files stored in your browser) and other techniques such as web beacons (small, clear image files used to track your movement on our website), to collect your information about how you use our website and web-related services. We use these to compile statistical reports on website activity, you can choose to refuse cookies or set your browser to notify you each time a website attempts to install a cookie. For more information about cookies, visit www.aboutcookies.org or www.allaboutcookies.org. You can find information on how to turn off cookies on that website.

The types of cookies we use on this site include:
1. Strictly Necessary Cookies: These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you that amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
2. Analytics Cookies: We use these cookies to analyze and identify the behavior of our web visitors. We will track the IP address on the device you are using to identify you when visiting our website. When possible, we combine your online web behavior data with the Personal Data that you have previously supplied to us. This data will be used to analyze behavior on our website and to personalize your experience.
3. Advertising Cookies: These cookies may be set through our site by our advertising partners. They can be used and shared by those companies to build a profile of your interests and show you relevant adverts on other sites. This is based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
4. Engagement Cookies: These cookies are used to provide additional functionality to the site and may affect your experience if they are turned off. They are used to allow enhancement widgets for live chat to provide customer support or alert widgets drawing your attention to updates and exclusive offers. These cookies may track your customer journey to personalize the support and messaging given.
If you wish to block the cookies, please visit:
- Google AdWords - http://www.google.com/settings/ads
- Facebook Pixel - You may disable any of these cookies or similar technologies via your browser settings.
- Twitter Advertising - You may disable tailored advertisements via your Twitter settings by visiting the “Promoted content” and “Personalization” sections.
- Google Analytics - You may disable any of these cookies via your browser settings or by downloading a browser add-in: https://tools.google.com/dlpage/gaoptout.
- You may disable any of these cookies via your browser settings or change your cookies settings.
Data Retention

Your Personal Data collected, used, or disclosed for the purposes described here will be stored only to the extent necessary during the term of your participation in the Services with us, or for the period necessary to fulfill the purposes outlined in this, including during a transition period (e.g. for the compliance of our obligations regarding data retention as established in applicable laws), if any. We will retain your Personal Data as long as required or permitted by applicable law. Afterward, we will remove your Personal Data from our systems and records or take steps to anonymize it so that you can no longer be identified from it.
Security of your personal data

We have put in place appropriate security measures to prevent your Personal Data from being lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors, and other third parties who have a business need-to-know, they will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Your rights

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data.

Rights	Details
Right to withdraw consent	If you have given your consent for us to collect, use, and/or disclose your Personal Data. You have the right to withdraw your consent at any time throughout the period that your Personal Data is with us. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. In the case you withdraw your consent, we may not be able to provide you with certain services or it may affect you about recent updates on products and/or services, for example, you will not receive offers of products and/or services, or benefits, new promotions or offers that are more desirable and consistent or meet your needs. Which we will advise you if this is the case at the time you withdraw your consent.
Request access to your Personal Data	Request access to your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
Request correction of your Personal Data	Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
Request transfer of your Personal Data	Request the transfer of your Personal Data to you or to a third party. We will arrange for such Personal Data to be in a format which is readable or commonly used by ways of automatic tools or equipment and can be used or disclosed by automated means. Note that this right only applies to Personal Data that you initially gave consent for us to collect, use, and disclose or where we used Personal Data to perform a contract with you.
Request restriction of processing your Personal Data	Request to restrict processing of your Personal Data This allows you to request that we stop processing your Personal Data in the following situations: 1. If you want us to establish the accuracy of your data 2. Where our use of your data is unlawful. but you do not want us to delete that information 3. In cases where you would like us to keep the information even if we no longer need it because you need it to establish, exercise, or defend legal claims. 4. You have objected to our use of your information, but we need to check whether we have overriding legitimate grounds for using that information.
Request the erasure of your Personal Data	You have the right to request deletion or destruction of your Personal Data or make it non-identifiable if you believe that your Personal Data has been collected, used, and/or disclosed in violation of applicable laws or if we consider that it is no longer necessary to retain it for the purposes involved in this policy or when you exercise the right to withdraw consent or use the right to object.
Object to processing of your Personal Data	You have the right to object to the processing of your Personal Data because you feel that the processing affects your fundamental rights and freedoms, you also have the right to object to our processing of your Personal Data for direct marketing. In some cases, we may demonstrate legitimate grounds for processing your information.
Right to file a complaint	You have the right to file a complaint with the supervisory authority under the Personal Data Protection Act (“PDPA”) anytime the Company violates or does not comply with the PDPA.

We may need to request specific information from you to help us verify your identity and ensure your right to access your Personal Data (or in exercising your other rights). This is a security measure to ensure that Personal Data will not be disclosed to any person who has no right to receive it, we may also contact you to request additional information about your request in order to speed up our response. You will not be charged a fee to access your Personal Data (or to exercise any other rights).

However, we may charge a reasonable administrative fee. If your request is baseless, redundant, or excessive. or we may refuse to comply with your request. We will inform you of the reasons for refusing and the consequences of exercising your rights.

You can request to exercise your rights through the following channels:

Rights	Details
Rights	MinorPlus Application	Brand Customer Service Support	Branch	Privacy.lifestyle@minor.com
Right to withdraw consent	🗸	-	-	🗸
Request correction of your Personal Data (Customer profile)	🗸	🗸	🗸	🗸
Request access to your Personal Data	-	-	-	🗸
Request transfer of your Personal Data	-	-	-	🗸
Request restriction of processing your Personal Data	-	-	-	🗸
Request the erasure of your Personal Data	🗸	🗸	-	🗸
Object to processing of your Personal Data	-	-	-	🗸
Right to file a complaint	-	🗸	🗸	🗸

Liability

You guarantee that you have informed any third parties whose Personal Data you are providing, if you have done so, of the points covered in this Privacy Statement. In addition, you guarantee that their authorization has been obtained to provide their Personal Data to us for the indicated purposes.

You will be liable for any false or inaccurate information provided and for direct or indirect damage caused to us or to third parties.
Changes to this Privacy Statement

We keep our Privacy Statement under regular review. At the top of this page, you will see the date on which the Privacy Statement was last revised, and it is also the date from which any changes will become effective. Your use of the Services following these changes means that you accept the revised Privacy Statement. If you would like to review the version of the Privacy Statement that was effective immediately prior to this revision, please contact us at privacy.lifestyle@minor.com
Contact the Data Protection Officer

If you wish to exercise the rights relating to your Personal Data, please contact us
1. By post: 88 The Parq Building 12th Fl., Ratchadaphisek Road, Klongtoey Subdistrict, Klongtoey District, Bangkok 10110 Thailand
2. By email: privacy.lifestyle@minor.com or dpo@minor.com