We, HOMERUN PROPTECH CO., LTD., strictly abide by our customers’ privacy. When we use your personal data to run our business and provide service to you, your personal data is protected under the Personal Data Protection Act B.E. 2562. As the data controller, we are obliged by the law to inform you of our privacy policy which explains the way we collect, use or disclosure your personal data as well as your rights to your personal data as the data subject. We reaffirm that we comply with the law to protect your personal data.

1. Definition of Personal Data

Personal Data can be divided in 2 categories ;

Personal Data (General)

Personal Data means any information related to a person, which enables the identification of such person, whether directly or indirectly. For example name, address, e-mail, address Identification Number. Sensitive Personal Data Sensitive Data is special category of personal data that needs appropriate protection and carefully collect, use or disclose. Sensitive Data pertains racial, ethnic origin, political opinions, cult, religious or philosophical beliefs, sexual behavior, criminal records, health data, disability, trade union information, genetic data and biometric data.

2. Personal data that we collect from you

We collect your information when :

• You use our website
• You provide information to us through our website or applications;
• You provide information to us when you make enquiry via online or offline channel.

We only collect your personal data as necessary to provide the service to you and to correspond to your queries as well as to carry on our business in a way that you would normally anticipate. We may collect, use, store and transfer different types of personal data about you which we have grouped as follows :

3. Sources of Personal Data

1. We receive your personal data directly from you through the following channels :

• You register with us by creating an account on our website or application.
• You make a query with us relating to your interested property/project.
• You contact us for providing your properties
• You make an appointment with us to visit the project site.
• You provide information to us when you visit the project site.
• You participate in our marketing activity through an electronic platform, social media, or an offline platform.
• You contact us to offer products and services

2. We receive your personal data from a third party that collects, uses or discloses your personal data as instructed by us or on our behalf. Your personal data will not be used other than the purposes for which we instruct or require such third party to do. We require such third party to protect confidentiality of your personal data and to have measures to protect your personal data as required by the Thai personal data protection law.

3. We receive your personal data from cookies when you visit our website. This data helps us provide you better, faster, safer services and for your own privacy when you use the service and / or enter the platform.

4. Purpose of collection, use and disclose of personal data

We may use your personal data to the extent permitted by the personal data protection law. We only collect your personal data as necessary and to the extent that is related to provision of our service to you, where it is necessary :

• For our legitimate interests or any other person and your interests, which do not override your fundamental rights
• For the performance of a contract to which you are a party, or in order to take steps at your request to enter into a contract
• For compliance with a law to which we are subjected or for preventing or suppressing a danger to a person’s life, body or health.

We explain in the table below about how we use your personal data, and which lawful basis we rely on to do so.

We may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

5. Disclosing or sharing your personal data

1. We may have to disclose or share your personal data with selected third parties as follows :

• Our affiliated companies
• Online advertising platforms
• Marketing companies or consultants
• Regulator such as the Office of the Personal Data Protection Committee
• Professional advisors and consultants

We require that the third parties above protect confidentiality and protect your personal data in accordance with requirements under the Thai personal data protection law. They may use your personal data only for purposes as instructed by us. Your personal data will not be used other than the purposes for which we instruct or require them to do so.

2. Upon request, we may disclose your personal data to a relevant authority for compliance with a law such as prevention of a danger to a person, legal compliance, setting for an indictment, exercising legal rights, and preventing fraud.

6. Retention policy and retention period of personal data

We collect your personal data in our information system and provide standard security to keep our information systems and the use of your personal data secure with following measures :

• Restrict access to personal data which may be accessed by employees, agents, contractors and other third parties. They can only access your personal data on our instructions, and they are subject to a duty of confidentiality and protection of personal data.
• Provide technological methods to prevent unauthorized access to computer systems.
• Destroy your personal data for security purposes when such information is no longer needed for legal and business purposes.
• Put in place procedures to deal with any suspected personal data breach and will notify a regulator of a breach where we are legally required to do so.

Retention period of personal data

• We will keep your personal data for as long as necessary to fulfil the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements.
• To determine the appropriate retention period for personal data, we consider the amount, nature, purpose and sensitivity of the personal data, the potential risk of harm from unauthorised use of your personal data, and the applicable legal requirements.
• We collect your personal data obtained from cookies when you use our website. We will keep your personal data for no more than 13 months or as required by relevant laws.

7. Right of Data Subject

Data subjects have the right to proceed to the extent permitted by law as follow

• The data subject shall have the right to withdraw his or her consent at any time. When processing personal data, you give us consent throughout the duration of your personal data with us (The Right to withdraw).
• The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, request for a copy of his or her personal data, including request to disclose personal data acquisition that you did not give us consent to (The Right to Access).
• The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her (The Right to Rectification).
• The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay (The Right to Erasure).
• The data subject shall have the right to obtain from the controller restriction of data processing (The Right to Restriction of Processing).
• The data subject shall have the right to transmit their personal data to another controller without hindrance from the controller to which the personal data have been provided (The Right to Data Portability).
• The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her. (Right to Object)

You can contact the DPO or company’s staff in order to proceed with the request to exercise the above rights.

8. Marketing activities and promotion

We may conduct marketing activities and promotion or use third parties as instructed by us to do so

• In case that we use your personal data for a purpose of providing a direct marketing to you, we will be able to do so only when you give us explicit consent and we have already informed you the purpose of your personal data’s use on direct marketing. However, you can withdraw your consent on direct marketing with us at any time through our opt- out system.
• In the case of your participation in our sale promotional activities such as gaming activities or other activities through various social network channels for promoting our products and services to the public, we will not process your data for direct marketing unless you give us an explicit consent to use your personal data for direct marketing and we have already informed you the purpose of your personal data’s use on direct marketing. However, you can withdraw your consent on direct marketing with us at any time through our opt-out system.

9. Cookies Policy

HOMERUN strictly respects the privacy right of every website visitor or user. There may be cookies or any other similar technologies on our website or application to provide you with improved experience of using our service and to allow us to develop service quality to meet your best satisfaction while your data will be properly protected. HOMERUN announces implementation of Cookie Policy ("Cookie Policy") for this website.

Cookie is a small data file downloaded and stored in your device when visiting a website. After, the cookie will be sent to the previous site you visited or other website supported by such cookie. Cookie enables the website to memorise your device to improve the best service for visitors. We use Cookies for storing your website browsing history to enhance our services for the better, faster and more secured function. For your privacy purpose, when visiting our website, we will use cookies for the following circumstances:

Strictly Necessary Cookies : This type of cookie is important to the function of our website, including the cookies that secure your browsing through data and website.

Functional Cookies : Functional Cookies memorise your device or browser to allow preparing the content that meets your personal interest faster, and to facilitate the service and platform application. Targeting Cookies : Targeting Cookies memorizes your settings when browsing the website and link you visit in order to collect information on your visiting behavior and access. It also improves and edits any content appeared on the website to match your interest, including tests for our advertisement performance. The cookies may present the advertisement that matches your choice the most. We may share this information with the third party for such a purpose.

Statistic Cookies : HOMERUN uses the Analytics Cookies provided by Google, with the target to collect in depth data on your browsing details on our website. Such information includes the visited websites, clicked link, duration of visiting in each webpage. We will use this information for analysis of user's behavior to optimize the best function on the website.

When browsing our website, you acknowledge that we will use various Cookies for the objectives mentioned above, and we may collect, use or disclose your personal data which is deemed as a part of such Cookies for the objective as specified in our Privacy Policy Notice.

In the event our website is linked to the third party's website, the said person may use its own Cookie Policy. We suggest that you study the Cookie Policy of the said person before browsing their websites.

Website visitor or user can use a web browser's cookie control to change the cookie setting. For further details on the settings, please see the Cookie Setting section.

Most of the browsers are set to accept cookies by default. However, you can delete or refuse the cookies on the browser setting page. Your adjustment may affect the browsing experience display format on the website. Please see below for setting each web browser.

However, HOMERUN would like to inform that disabling some cookies may affect function or disable some operation of the website.

10. Privacy policy of other websites

This Privacy Policy is used for our service and our website use only. If you click on a link to another website (although via our website). You will have to study and comply with the privacy policy displayed on that website separate from ours.

11. Change of privacy policy

We will review our privacy policy regularly. In case of changing privacy policy, it will be announced on our website or other platforms.

12. Contact

Details of the data controller If you need use your rights to your personal data under the Personal Data Protection Act B.E. 2562, you can contact ;

HOMERUN PROPTECH CO., LTD.
Contact Address : 170/57 Ocean Tower 1 Building, 18th Floor, Ratchadapisek Road, Klongtoey Suspan-district, Klongtoey District, Bangkok 10110
Contact Tel : 02-018-9999
E-mail : dpo@apthai.com