Privacy policy

Acceptance of terms of use and other policies

EVLOMO Technologies Co., Ltd. (“EVLOMO”, “we,” “us,” and/or “our”) recognizes the importance of protecting your personal data for you, (1) a former, existing, or prospective individual customer of our products, goods, and services, (2) an employee, staff, officer, representative, authorized person, director, agent, or other individual related to our corporate customers (collectively referred to as “corporate customer”) or (3) any individual that we have obtained his/her personal data (e.g. emergency contact person, spouse, parent, descendant, relative, child, employer, agent, beneficiary or reference person), where persons in (1) - (3) are collectively referred to as “you”, and those persons in (1) and (2) are referred to as “customer”. We know you care about how information about you is collected, used, disclosed, and/or cross-border transferred. We and our affiliates and subsidiaries within EVLOMO group will use information you share with us to provide our products, goods, and services you need and want that we appropriately tailor to you.

This privacy policy (“Privacy Policy”) applies to our products, goods and services distributed to customers through our retail stores, websites, mobile applications, sales representatives, event booths, call centers, social networking sites, online communication channels, pick-up registration for goods and/or services and other channels where we collect your personal data. However, please read this Privacy Policy in conjunction with the terms and conditions of particular service that you use. For the purpose of this Privacy Policy, “Personal Data” means “any information relating to an identified or identifiable natural person” and "Sensitive Data" means Personal Data classified by law as sensitive data.

We reserve the right to modify this Privacy Policy from time to time, so please review it periodically. Any changes to this Privacy Policy will immediately become effective when we post the revised Privacy Policy on our website or application.

Types of Personal Data we collect

We may collect or obtain the following types of information which may include your Personal Data directly or indirectly from you or other sources or through our affiliates and subsidiaries within EVLOMO group ("EVLOMO GROUP"), other companies or business partners depending on the context of your interactions with us and the services or products you need or want from us and from EVLOMO GROUP. The Personal Data we may collect, use, disclose and/or cross-border transfer may include, but are not limited to, the following:

  • Personal details: such as your title, full name, age, occupation, date of birth, company’s title, position, salary, working history, working information (e.g. type of working organization, workplace, position, period of work, department, occupation, company which you are working or holding shares), political status, gender, nationality, marital status, educational history, educational degree, photograph, image, voice and telephone recording, signature, CCTV records, shareholding percentage, including complaints, your comment on our product, goods, and services, and inquiries via social media.

  • Contact details: such as registered address, present address, business address, postal address, telephone number, business number, mobile number, fax number, email address, postal number, social media account (e.g. LINE ID, Facebook account, and available date for contact), and other contact details via electronic channels.

  • Information for identity verification from official identification documents: such as national identification number, passport number, tax identification number, social security number, including information from driving license, house registration, company’s affidavit (which includes director names) or any similar identifiers.

  • Demographic information: such as number and age of children, number of family members, education level, and family’s salary.

  • Behavior details: such as information about customer’s purchasing behavior and data supplied through the use of our products and services;

  • Financial details: such as sale price, fees, payment method (e.g. in cash or through credit cards), number and information of cash card, debit card, credit card, and bank account numbers and types, banking history, withdrawal/deposit, current assets, source of income, payment information, credit rating and monthly income, products and services registration information (via application);

  • Transaction details: such as purchasing history, purchasing amount, behavior on the purchase and/or use of our product, goods, and services, including favor, preferences, interest and your search history.

  • Technical Information: such as Internet Protocol (IP) address, web beacon, log, device ID, GPS location, device model and type, network, connection details, access details, Single Sign On (SSO) access information, access time, time spent on our page, cookies, login data, search history, browsing details, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on devices you use to access the platform;

  • Loyalty program and other card information: including information on service, use and purchase of products and goods account through a loyalty program, and other cards, behavior related to the use of loyalty program

  • Marketing and communications channel details: such as your preferences in receiving marketing information from us, EVLOMO GROUP, and business partners including your preferences on communication channel or format for our product, goods and services information, information of your interaction with us, other communication channel preferences, contact details, and marketing data (e.g., information supplied through surveys, polls, comment request forms, or researching activities);

  • Profile details: such as account identifiers, username and password, PIN ID code for sale of our products, goods, and services.

  • Usage details: such as information on how you browse or use our internet, platform, products, goods and services, methods you use or interact with our advertisement (including content viewed, link clicked, and other usage details);

  • Customer relation management information: such as customer account opening, managing, operating, paying, dispute resolving, processing, and reporting on customer’s behalf, this Personal Data may include your signature, and your communication records with us; and/or

  • Other data: such as relationship history including your details as interacted with us e.g., information you provided to us as specified in the contract, registration data, application information, poll, research, or information collected during your participation of our business activities, seminar, training, or social activities.

If you provide Personal Data (e.g. their full name, address, and contact details) of any third party (e.g., your emergency contact person, spouse, parent, descendant, relative, child, employer, agent, beneficiary, or reference person (in case of individual customers) or employer, shareholders, directors or relevant person to your organization (in case of corporate customer), you must ensure that you have rights and/or authority to provide such persons Personal Data and authorize us to use such Personal Data in accordance with this Privacy Policy. Also, you must be responsible to notify each person of this Privacy Policy and/or obtain consent from each person (if necessary) and/or rely on other legal bases.

We will not collect the Personal Data of minors (who have not yet become sui juris, i.e., under 20 years of age or has not reached legal age through marriage as applicable by laws), quasi-incompetent persons, and incompetent persons, and do not allow such persons to register for the use/purchase our products, goods, and services without obtaining consent or without relying on any other legal bases. In the event we learn that we have unintentionally collected Personal Data from such persons without consent, or without relying on other legal bases, we will delete it immediately, and may need to cease providing service to such persons, unless we may rely on other legal bases apart from consent.

Purposes and legal bases on which we rely on to collect, use, or disclose your Personal Data

  • The purposes on which we rely on the legal basis of your explicit consent to collect, use, or disclose your Personal Data

    • Marketing and Communications: To provide marketing, communications, sales, special offers, promotions, notices, news, and information about the products and services from us, our affiliates and subsidiaries, and/or business partners which we cannot rely on other legal bases.

    • The purposes on which we rely on other legal bases to collect, use and disclose your Personal Data We may collect, use, and/or disclose your Personal Data on the legal basis of (1) contractual basis, for starting or entering into a contract or for performance of a contract with you; (2) legal obligation, for fulfilment of our legal obligations; (3) legitimate interest, for the purpose of our legitimate interests and the legitimate interests of third parties; (4) vital interest, for the prevention or suppression of danger to a person’s life, body, or health; and/or (5) public interest, for the performance of tasks carried out in the public interest or for exercising official authorities duties, as the case may be, for processing purposes applicable to you as listed below:

      • Sensitive Data from official identification documents (e. g. religion on national identification card or race on passport): for authentication and verification purposes during membership registration, to prepare products and service, and to retain as evidence for identity verification where we cannot rely on other legal bases.

      • Health data (e.g., congenital disease)

      • Criminal records: for authentication and verification purposes and assess qualification of the relevant person such as customer's driver.

      • Biometric data, (e. g. facial recognition and fingerprints) for identity verification

  • We will only collect, use, and/or disclose your Sensitive Data if we have received your explicit consent or as permitted by law.

  • The purposes on which we rely on other legal bases to collect, use and disclose your Personal Data We may collect, use, and/or disclose your Personal Data on the legal basis of (1) contractual basis, for starting or entering into a contract or for performance of a contract with you; (2) legal obligation, for fulfilment of our legal obligations; (3) legitimate interest, for

    • Providing the products, goods and services to you: such as to respond to your requests before entering into an agreement and to manage the contractual relationship between us, to issue quotations as you request, to provide, preserve, protect, check services and to improve services, to provide convenience, to assist and conduct activities related to our products, goods and services, to manage your account and to conduct financial transactions related to payment, refund, issuance of bills, receipts, invoices for proceeding and monitoring delivery, receipt, return or exchange of our products, goods, and services, including validating and verifying transactions to process your purchase order;

    • Registration and Authentication: such as to register, verify, identify and authenticate your identity.

    • Customer selection: such as, verifying your customer status and/or conducting background checks on you, including risk identification on you and customer, examining and screening blacklist, evaluating suitability and qualifications of you and customer, issuance of request for quotation and bidding, execution of contract with you or customer.

    • Communications and contacting you: such as to contact, coordinate, provide services, to publicize, offer marketing details, sales, special offers, promotions, notices, news, information and any information about the products, goods and services from us, to process and update your Personal Data as our member, including to handle customer service-related queries, request, feedback, complaints, claims, disputes or indemnity; to provide technical assistance and deal with technical issues, to notify you of issue solving, to conduct opinion and satisfaction survey to our service and activities, including to update your Personal Data (e.g. name list/customer name list) and to store relevant documents referring to you;

    • Marketing and Communications: such as to provide marketing and communications, sales, promotions, special offers, discounts, privileges, including, notices, news, information about the products goods and services from us, EVLOMO GROUP, and/or business partners in accordance with your preference/your uses of services including; information about products, goods, and services similar to your interest and products, goods and services receiving history of you, whether direct or indirect, to enable you to participate sales, offers, privileges, campaigns, activities, seminars, competitions, sweepstakes, prize draws, booths, and events collaborating with branch stores to meet you, and other relevant promotional offers and advertising services to facilitate your participation of our activities, including collaboration with OR and/or Non-OR brands and to process and administrate registration of your user account, to provide loyalty card services and to collect, add, redeem, obtain, pay and/or transfer points balance to provide the highest benefits to the card holder;

    • Profiling and data analytics: such as to learn more about the products, goods and services you receive and other products, goods, and services you may be interested in receiving, for instance by looking at the types of products, goods and services that you use from us and/or EVLOMO GROUP, how you like to be contacted; to conduct service satisfaction survey for us and/or EVLOMO GROUP, to collect information from your use of our or EVLOMO GROUP goods or services, to undertake statistics, behaviour analysis, customer segmentation based on group of products, time span, customer’ s location, market trends, for promotional purposes, new campaigns, to know better about you, to resolve issues with our and/or EVLOMO GROUP existing products, goods and services; and to improve our and/ or EVLOMO GROUP business operation;

    • To improve business operations, products, and services: to evaluate, develop, manage, and improve, research and develop the products, goods and services provided to you, including system and business operations, to develop and adjust marketing strategies, products, goods and services, to manage, examine, report, control or manage risks, to conduct statistic reports, trends and plans, or any other activities in a similar manner, including to comply with the organizational retention policy, to analyze and manage our business, to conduct market research, surveys, assessments, behaviour, statistics and segmentation, consumption trends and patterns for the processing of our data, for research, assessment, resolving, purposes, to improve quality, safety, and security of our products, goods, and services, and to develop new products, goods, and services;

    • Loyalty program and other card information: including information on service, use and purchase of products and goods account through a loyalty program, and other cards, behavior related to the use of loyalty program and other cards (e.g., points earned, added, used, redeemed, obtained, paid, and/or transferred).

    • Training management: such as to conduct training activities both in physical and in e-learning formats and/or to issue certificate of training participation to you;

    • Information technology management: such as for the purpose of our business management, to communicate internally within our organization, including to manage IT operations, communication systems, and IT security systems of the organization, including system access control and records, monitoring of system, equipment and internet system;

    • Functioning of the websites, mobile application, and platform: such as to administer, operate, track, monitor, and manage the websites and platform to facilitate and ensure that they function properly, efficiently, and securely; to facilitate your experience on the sites and platform; improve layout, and content of the sites and platform;

    • Personalization: such as to identify your preferences and personalize our products, goods, and services to your experience;

    • Complying with applicable legal and regulatory obligations: such as to comply with legal obligations, legal proceedings, or government authorities’ orders which can include orders from government authorities outside Thailand and/ or to cooperate with courts, regulators, government authorities, and law enforcement bodies when we reasonably believe we are legally required to do so. We may need to disclose your Personal Data to strictly comply with said legal obligations, legal proceedings, or government authorities’ orders, including to comply with internal investigations procedures, complaints or claims, interrogation, crimes or fraud prevention, and/or to establish legal claims;

    • Conduct sales or acquisitions of business: such as, in the event of business reorganization, merger, sale, purchase, joint venture, assignment, transfer or other disposition of our business, assets, or stock, or rehabilitation, capital venture or any similar transaction, whether in whole or in part, we may disclose your Personal Data to our assignee(s) of rights and/or obligations as part of such transactions;

    • Protecting our interests and related persons: such as protecting the security and integrity of our business, affiliates, or other related persons; exercising our rights or protecting our interest, affiliates, or other related persons, where it is necessary and lawfully to do so, for example to detect, prevent, and proceed against any fraud claims, intellectual property infringement claims, or violations of law; managing and preventing loss of our property; securing the compliance of our terms and conditions; detecting and preventing misconduct within our premises which includes the use of CCTV; following up on incidents; preventing and reporting crimes and protecting the security and integrity of our business; managing and preparing reports, internal policy under our scope of operation;

    • Fraud detection: such as to verify your identity, and to conduct legal and other regulatory compliance checks (for example, to comply with anti-money laundering regulations, and prevent fraud). This includes to perform sanction list checking, internal audits and records, asset management, system, and other business controls; and

    • For the prevention or suppression of danger to a person’s life, body, or health. Failure to provide Personal Data to us may affect you and we may be unable to respond to your request or to perform a contract. As a result, we may not be able to offer or provide you our products, goods, and services, whether partially or in whole. We may not be able to facilitate or may not be able to comply with our obligations under your contract and you may be suffered from damages or miss out on opportunities in certain circumstances. In some instances, this may affect responsibility for legal obligations that we or you are required to comply with, this may lead to relevant penalties as applicable.

Who might we disclose or transfer your Personal Data with?

We may disclose or transfer your Personal Data to the following third parties who collect, use, and disclose Personal Data in accordance with the purposes under this Privacy Policy. We recommend you visit their privacy policies to learn more details on how they collect, use, and disclose your Personal Data as you may also be subject to their privacy policies.

  • EVLOMO GROUP
    We may need to disclose or transfer your Personal Data to EVLOMO GROUP, or otherwise allow access to such Personal Data by EVLOMO GROUP for the purposes set out in this Privacy Policy.

  • Our service providers We may use other companies, agents, or contractors to perform services on behalf of or to assist with 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) infrastructure, internet, website developer and IT service providers; (2) logistic and courier service providers; (3) analytics service providers; (4) marketing, market survey, advertising media, and communications agencies; (5) data storage and cloud service providers; (6) training seminars agencies; (7) travel agencies;(8) oil service providers(9) payment and payment system service providers; (10) physical document storage and/or shredding service providers; (11) 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 Personal Data for any other purposes.

  • Our business partners We may disclose and/or transfer your Personal Data to companies that we have partnered with to offer or enhance products and services, for example, banking and financial institution partners, ewallet partners, insurance partners, royalty program partners, including service providers, and suppliers who offer you products, goods and services. However, the Personal Data disclosed or transferred in this manner will be subject to these business partners’ privacy policies, not this Privacy Policy.

  • Third parties required by law In certain circumstances, we may be required to disclose and/ or transfer your Personal Data to government agencies, courts, officers, government authorities, law enforcement bodies or other third parties where we reasonably believe it is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals’ personal safety, or to detect, prevent, or otherwise address fraud, security, or safety issues.

  • Assignee of rights and/or obligations 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 all or any portion of our business, assets or stock or similar transaction; the assignee of our right and/or obligations will comply with this Privacy Policy to respect your Personal Data.

    Cookies and how they are used

    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 is unable to function properly. Other cookies allow us to enhance your browsing experience, tailor content to your preferences, and make your interactions with the site more convenient: 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 cookies it can affect your user experience and without cookies, your ability to use some or all of the features or areas of our websites may be limited.

    Some third parties may issue cookies through our websites to serve ads 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 visit when you leave our websites. Information gathered through these automated means may be associated with the Personal Data you previously submitted on our website. You may also be subject to these third parties’ own cookies and privacy policies. Therefore, we recommend you should refer to such third parties’ own cookies and privacy policies for information about how they collect, use or disclose your Personal Data

    International transfer of your Personal Data

    Some of the recipients we may share your Personal Data with may be located outside Thailand. The destination countries may or may not have the same equivalent level of protection for Personal Data protection standards. In such case, we ensure appropriate safeguards in place, and oblige the recipients to protect your Personal Data in accordance with this Privacy Policy and as allowed by applicable laws using appropriate security measures. We will request your consent where consent to cross-border transfer is required by law.

    Retention of your Personal Data

    Subject to applicable data laws, we will retain your Personal Data for as long as necessary to fulfill the purposes for which it was collected or to comply with legal, regulatory, and internal requirements. However, we may have to retain your Personal Data for a longer duration, as required by applicable laws.

    Your rights as a data subject

    Subject to applicable laws and exceptions thereof, you may have the following rights to:

    • Request access to your Personal Data. You may have the right to access or obtain a copy of your Personal Data we collect, use or disclose about you;

    • Request to rectify. You may ask us to have any inaccurate, outdated, incomplete, and misleading Personal Data that we collect, use or disclose about you rectified;

    • Request to port. You may have the right to obtain Personal Data we hold about you, in a structured, electronic format, and to send or transfer such data to another data controller, where this is (a) Personal Data which you have provided to us, and (b) if we are collecting, using, or disclosing your Personal Data on the basis of your consent or to perform our contract with you. However, if exercise of your rights violates the rights and freedoms of others or we must use your Personal Data to perform a task carried out in the public interest, or for compliance with law, we have the discretion to reject your request;

    • Request to object. You may have the right to object to the collection, use and disclosure of your Personal Data for certain cases as required by the applicable laws;

    • Request to restrict. You may have the right to suspend use of your Personal Data in certain cases;

    • Request to withdraw your consent. You can withdraw your consent at any time where we collect, use and disclose your Personal Data based on your consent in certain cases;

    • Request to delete. You may have the right to ask us to delete, destroy or anonymize your Personal Data that we collect, use, or disclose except where the retention of such Personal Data is for compliance with a legal obligation or to establish, exercise, or defend legal claims; and

    • Lodge a complaint. You may have the right to lodge a complaint to the competent authority where you believe that we do not comply with applicable data protection laws.

    Security Measures

    We maintain appropriate security measures for Personal Data, which cover administrative, technical and physical safeguards in relation to access control to protect the confidentiality, integrity, and availability of Personal Data against any accidental or unlawful or unauthorized loss, access, use, alteration, correction or disclosure of Personal Data, in compliance with the applicable laws. We have implemented access control measures which are secured and suitable for our collection, use and disclosure of Personal Data. We restrict access to Personal Data as well as storage and processing equipment by imposing access rights or permission, user access management to permit access to authorized personnel, and user responsibilities to prevent unauthorized access, disclosure, perception or unlawful duplication of Personal Data, or theft of device used to store and process Personal Data. This includes methods enabling the reexamination in relation to access, alteration, erasure, or transfer of Personal Data which are in accordance with methods and channels to collect, use or disclose Personal Data.

    Contact details for concerns/questions

    If you have any questions, or would like to exercise your rights regarding your Personal Data, please contact us or our data protection officer at:
    EVLOMO TECHNOLOGIES CO., LTD
    Raintree Office Garden 280 B2, Fl. 1ABC
    Soi Soonvijai 4,
    Rama 9 Road, Huaykwang
    Bangkok 10310
    Thailand
    Data Protection Officer: Email: dpo@evlomo.co.th