Privacy Policy

STL Group Holdings Co., Ltd. and its affiliates (“company” or “we”) understand and recognize the importance of your personal data and your right to privacy, which should be protected under the law. Therefore, when we collect, use, or disclose your personal data, we are committed to protecting it and handling your personal data in compliance with data protection laws.

Therefore, we have established this Privacy Policy to outline the appropriate methods for handling personal data, to inform you about the purposes of collecting, using, or disclosing personal data, the relevant legal bases, the types of personal data collected, the duration of data retention, the rights of data subjects, and our contact channels.

1. Definitions

“Personal Data” or “General Personal Data” refers to information about an individual that enables the identification of that person, whether directly or indirectly, but does not include information of deceased persons.

“Sensitive Personal Data” refers to personal data that requires special protection, including data related to race, ethnicity, political opinions, religious or philosophical beliefs, sexual behavior, criminal records, health information, disability, trade union membership, genetic data, biometric data such as fingerprint models, facial recognition images, or any other data that similarly affects the data subject as prescribed by the Personal Data Protection Committee.

“Data Processing” refers to activities involving the collection, use, disclosure, deletion, or destruction of personal data.

2. Collection of personal Data

2.1  Generally, company will collect personal data directly from you such as during the purchase of products or services, signing of sales contracts, lease agreements, hire-purchase agreements, loan applications, filling out purchase order forms, surveys, registrations, or when you submit claims or requests for any rights. Additionally, we collect personal data when you contact us through any channels, including our website, in-store interactions, phone, email, and social media platforms such as Line, Instagram, or Facebook.

In some cases, we may collect your personal data from other sources, such as your employer, government agencies, our business partners whom you have authorized to disclose your data to us, or publicly available sources such as websites and internet search results, etc.

The personal data collected includes but is not limited to:

1. Identity Data such as name, surname, national ID number, passport number, date of birth, gender, nationality, age, signature, photograph, student ID number, employee ID number, driver’s license data (car and motorcycle), electronic system user ID, etc.
2. Contact Information such as address, phone number, email, and social media accounts (e.g., Line, Instagram, Facebook). It also covers geolocation and GPS tracking locations of our property, as well as emergency contact details, etc.
3. Financial or Transaction Data such as Bank account details, credit card numbers, wallet account numbers, income information, bank account transaction records, transactions history about our products or services, credit history, employment or occupational data such as employment certificates, salary slips, occupational data, etc.
4. User Account Information such as username and password, electronic system usage data, membership registrations, purchase registrations for our products or services, etc.
5. Technical Data such as data obtained through the use of our website or applications, including electronic device information, IP addresses, log data, browser types and settings, location data, online identifiers to enable ‘cookies’ and similar technologies
6. Communication Data with the Company such as audio and visual recordings when you interact with the company, etc.
7. Workplace Information such as information about your workplace or affiliated organization, work location, job position, etc.
8. Other Data such as images, video, audio from participating in company activities or promotions, information from applications, forms, surveys, opinions, satisfaction feedback, or details about inquiries or requests made to us, including any other personal data considered as such under personal data protection laws provided to us in any form or through any channel.

2.2 In the case of minors (individuals under 20 years of age) wishing to provide us with their personal data, by using our platform, products, or services, it is assumed that you have obtained consent from your legal representative, guardian, or custodian to allow us to collect and use such personal data.

2.3 We use cookies to collect personal data as specified in our Cookie Policy.

2.4 If you provide us with personal data of third parties, such as recipients of products or services you ordered or subscribed to, including names, contact details, or any other content provided to the company, you confirm that you have informed the data subjects and obtained their consent to disclose such data to us.

2.5 Generally, we do not intend to collect or use sensitive personal data such as religious beliefs, race, health information, etc., from you or others for specific purposes. You are not required to specify or mention such information. However, if it is necessary for us to use such data for any purpose, we will inform you and seek your consent on a case-by-case basis unless otherwise required by law.

If you provide us with a copy of your national ID card containing sensitive personal data such as religion and blood type, please obscure such data. If you do not obscure the information, you authorize us to do so, and the document with obscured data will be deemed complete and legally binding. If we are unable to obscure the data due to technical limitations, we will collect and use it solely as part of your identity verification documents.

3. Legal Basis for Processing Personal Data

The company will process, use, disclose your data for various purposes depending on the aspects of your relationship with the company, including but not limited to

Objectives	Legal Basis
For the purposes of verifying identity during inquiries, purchasing products, or services, applying for our services, registering for electronic system access, applying or being considered for participation in the company’s activities or projects, through any channels designated by the company.	Contractual Necessity Legitimate Interests
For the purpose of verifying and confirming identity in credit application processes with banks or credit providers or financial institutions, which are conducted through the company or its agents.	Contractual Necessity
For using products or services of the company, complying with the company’s internal processes, or contacting customers with respect to receiving or delivering documents, products, services, or following up on inquiries.	Contractual Necessity Legitimate Interests
For the benefit of evaluating, enhancing, and developing products, services, and sales promotion activities of the company, including conducting satisfaction surveys regarding the company’s products and services to meet your needs.	Legitimate Interests
For compliance with legal obligations and enforcement of legal claims, including reporting information to government agencies such as the Revenue Department, investigations by law enforcement officials, government agencies, or courts.	Legal Obligations
For establishing rights and enforcing legal claims, or defending against legal claims.	Legitimate Interests
For business planning, reporting, and forecasting, risk management, regulatory compliance, internal auditing, internal organizational management, undertaking assignments, benefits, such as mergers, divisions, or business transfers, performed in compliance with the law.	Legitimate Interests
For notifying benefits and promotional campaigns for marketing purposes, inviting participation in events, providing product or service information, including notifications without marketing objectives.	Legitimate Interests
For disclosing to representatives, contractors/subcontractors, and service providers for any operational activities, such as delivery service providers in regard to your orders or using your services, technology development contractors, banks, credit service providers when you apply for credit services through the company	Contractual Necessity Legitimate Interests
For internal security maintenance within the company’s premises, facilities, and electric charging stations or any other locations to prevent incidents that may occur to the company’s properties, as well as using as evidence and investigating the truth, recording images of individuals visiting the company or its premises and facilities through closed-circuit television (CCTV) cameras, including installing location tracking devices (GPS Tracking) for the use of the company’s properties.	Legitimate Interests
For collecting and using your personal data, including name, position, department, and photos, VDO related to the operations and activities of the company, for publicity purposes through various channels such as internal company emails, group company websites, Facebook, LINE, YouTube, or other online media of the company, or other media such as television, printed materials, etc.	Legitimate Interests
For managing your health and safety services	Vital Interest
To disclose to affiliated companies within the corporate group or business partners of the company for the purpose of promoting and presenting products, services, benefits, and other special offers.	Consent

4. Retention Period of Personal Data

The company will retain your personal data for the duration necessary to achieve the purposes for which it was collected, used, disclosed, or processed, as specified in this Privacy Policy. Factors guiding our determination of retention periods include the duration of our relationship with you, the provision of services to you, and any obligatory retention periods required by legal obligations, statutes of limitations, or for the establishment, exercise, or defense of legal claims.

5. Disclosure of Personal Data

In the course of fulfilling the purposes outlined in this policy, the company may disclose your data to external parties as described below:

5.1 Subsidiaries, Affiliates, Manufacturers, and Related Companies: For business operations, internal management, offering additional products and services that may be of interest to you, and conducting activities as specified in this Privacy Policy.

5.2 Government Agencies and Legal Authorities: This includes officials exercising legal powers such as courts, police, and the Revenue Department.

5.3 Agents, Contractors, and Service Providers: For various operational purposes, including transportation providers, document storage and destruction services, printing companies, marketing agencies, research services, IT development, banks, credit service providers in case of credit service applications through the Company, the National Credit Bureau, auditors, lawyers, legal advisors, hospitals, or medical facilities.

5.4 Business Partners: For joint product launches (co-branding), involving business partners of the Company, or third parties with your consent, contractual obligations, or as required by applicable law.

5.5 Assignees: This includes parties to whom rights, duties, and benefits are transferred from the company, or those authorized by assignees to act on their behalf, in cases such as restructuring, mergers, acquisitions, separation or business transfers.

5.6 Other External Parties: Such as participants in events or training organized by the company, announcements of selected candidates through the company’s communication channels, or publicizing news related to our activity, event, or project to the media and the public.

6. Transfer or Disclosure of Data to Abroad

The Company may store data on servers or cloud services located in other countries and may process data using software or applications provided by international service providers. However, any transfer or disclosure of data will comply with the Personal Data Protection Act.

7. Data Subject Rights

As a data subject, you have the following rights under the applicable law:

7.1 Right to Withdraw Consent: You can withdraw your consent for the processing of your personal data at any time. However, we may continue processing your data if there is another legal basis for doing so.

7..2 Right to Access: You have the right to access your personal data and request a copy.

7.3 Right to Rectification: You have the right to request the correction of inaccurate or incomplete personal data.

7.4 Right to Erasure: You have the right to request the deletion or destruction of your personal data, or to anonymize it, subject to legal grounds for continued processing.

7.5 Right to Object: You have the right to object to the processing of your personal data by us based on legitimate interests as outlined in our policy.

7.6 Right to Data Portability: You have the right to request the transfer of your personal data to another party.

7.7 Right to Suspend: You have the right to request that we suspend the processing of your personal data, such as when you request corrections to your personal data or when you challenge our legal basis for processing your personal data.

7.8 Right to Lodge a Complaint: You have the right to lodge a complaint with the relevant legal authority if you believe that the collection, aggregation, use, and/or disclosure of your personal data by us violates or fails to comply with applicable laws.

The exercise of these rights may be subject to limitations under relevant laws, and there are cases where it is necessary for the company to refuse or be unable to comply with your requests. We will promptly consider and inform you of the outcome of your request within 30 days from the date we receive such request, in accordance with the data protection laws.

8. Use of Cookies

We use cookies and similar technologies to collect information about your visits to our website. This is to enhance the efficiency and experience of using our website, applications, or platforms in accessing our services via the internet. The purposes for which cookies are used include:

1. To enable continuous and secure access to your account on our website, applications, or platforms.
2. To record your usage data on the website, including various content information, your user account, product orders, service usage, and participation in various company activities.
3. To study your usage and visit behaviors on the website to develop and improve the website to better meet your needs, making it easier, faster, and more efficient to use.

If you do not wish to have your usage data collected through cookies, you can set your browser to refuse cookies.

9. Security measures of your personal data

9.1 The company has implemented appropriate security measures to safeguard personal data in accordance with confidentiality principles to prevent loss, unauthorized access, destruction, use, alteration, or disclosure of personal data unlawfully or without permission, following the company’s information security standards.

9.2 There is a process to handle personal data breaches.

9.3 In cases where the company has agreements with third parties to use personal data for processing, including system development and maintenance, third parties are limited to using your personal data only as specified or instructed. These third parties are also required to agree to maintain confidentiality and protect your personal data.

10. Contact Channels

If you have any questions or wish to exercise any rights as a data subject, or if you have any complaints, you can contact us at:

STL Group Holdings Co., Ltd.

Address: 46 Ramkhamhaeng Road, Huamark, Bangkapi, Bangkok 10240

Phone: 02-114-3888

Email: support@stlgh.com

Website: www.stlgh.com/support

11. Changes to the Privacy Policy

The company reserves the right to update, change, or amend this privacy policy in whole or in part in the future as deemed appropriate and in accordance with the law. Any updates, changes, or amendments will be announced to you through appropriate channels.

Last updated: June 2024