Data Protection Notice for Customers
CIRCULAR INDUSTRY CO.,LTD
This website www.circular-club.com is owned and run by CIRCULAR INDUSTRY CO.,LTD (“CIRCULAR” or “We”). At CIRCULAR, we are committed to protecting and respecting our users’ privacy (“You” or “User(s)”). This Privacy Policy explains the types of personal information we collect, how we use that information, who we share it with, and how we protect that information.
This policy (together with our terms and conditions and any other documents referred to on it) sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal information, and how we will treat it. By continuing to use this website, www.circular-club.com, you are accepting and consenting to the practices described in this policy.
Information Covered by This Policy
This policy covers all personal information collected and used by CIRCULAR. In this policy, “personal information” means information or pieces of information that could identify you. This includes information such as your name, address, username, profile pictures, or email address, but could also include information such as your IP address, or information about your preferences and shopping habits.
Personally Identifiable Information (PII) being processed by the Company for the performance of the Platform
In order to perform the required services and features defined on the website, CIRCULAR would need to collect and process the following PII from the User:
1. Directly Identifiable PII, including without limitation name, age, nationality, and date of birth
2. Contact information, including without limitation, address, phone number, and e-mail address
3. Platform transactional data, including without limitation username, password, transaction number, and history that the User transact on the Platform, including the gathered preference and interest from the Platform transactional behavior
4. Technical PII, including without limitation the IP address number, the Platform usage, setting, and web browser connection that has been connected to the Platform.
Access to Personal Data
We access users’ personal data through 2 main channels:
1. We access personal data directly from the users via the collection during the provision of service including:
User’s account registration, and the submission of application for any services
User’s subscription of any marketing and sales information including advertisement and promotion
User’s consensual agreement when filling out the survey
User’s cookies when accessing the platform
Mutual contact between users and service providers both offline and online such as email inquiries and phone calls
User’s purchase of any particular service or product
User’s log-in on both the service provider’s platform and associated sites such as Facebook and Google
2. We collect personal data of the users indirectly from the third-parties in the following cases: Facebook Login and Google Login
Data Collection Objectives
We may collect and use users’ personal data for any or all of the following purposes:
1. To perform obligations in the course of or in connection with our provision of the goods and/or services requested by the user
2. For post-sale customer services such as promotions and feedback inquiries
3. To verify the user’s identity
4. For marketing research and customer relationship optimization
5. To comply with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority
6. To transfer data to any unaffiliated third parties including our third-party service providers and agents, relevant governmental and/or regulatory authorities, for the aforementioned purposes
Sharing Personal Data
We may share and disclose your personal data to third parties in the following circumstances:
1. To third-party service providers who require access to personal data in order to assist in the provision of the website, products and services, and other business-related functions such as website analytics providers or our third-party advertisement partners. These third-party service providers are limited to only accessing or using this data to provide services to us and must provide reasonable assurances they will appropriately safeguard the data.
2. We may also disclose visits information to third-parties
3. Where required by law or regulatory requirement, court order or other judicial authorization
4. In response to lawful requested by public authorities including for the purposes of meeting national security and law enforcement requirements
5. In connection with the sale, transfer, merger, bankruptcy, restructuring or other reorganization of a business
6. To protect or defend our rights interests or property, or that of third parties
7. To investigate any wrongdoing in connection with the website or service
8. To protect the vital interests of an individual
9. We may also share Personal Information collected through the Website with third party companies so that they may offer products and services that we believe will be of interest to visitors, as well as third party advertising serving companies to better target the adverts and other content displayed on the website and to provide offers we think may be interests of visitors. The unsubscription of marketing is stated in the “Personal Data and Marketing Activities” section.
Personal Data Processing
After the collection of users’ personal data, we may store the data regarding the following processes:
1. Computer System including On-premise
2. We may use the collected personal data with the purposes mentioned in “Data Collection Objectives”
3. We may disclose users personal data:
To staff members under CIRCULAR INDUSTRY CO.,LTD, in order to perform obligations in the course of or in connection with our provision of the goods and services requested by users; or
To third-party service providers, agents, and other organizations we have engaged to perform any of the functions with reference to the above-mentioned objectives and for safety purposes.
Data Storage and Data Retention
We may store users’ personal data using the following systems:
1. Users’ personal data will be saved as soft copy data stored in our computer systems.
2. Users’ personal data will be saved in the service provider’s devices, such as computers, phones, and tablets. This includes the mentioned Computer System (On-premise).
3. Data retention period will be illustrated in the “Data Retention” section below.
Data Retention Period
1.Directly Identifiable PII, including without limitation name, age, nationality, and date of birth
Period: 10 years from the contract termination date
2. Contact information, including without limitation, address, phone number, and e-mail address
Period: 10 years from the contract termination date
4. Platform transactional data, including without limitation username, password, transaction number, and history that the User transact on the Platform, including the gathered preference and interest from the Platform transactional behavior
Period: 5 years from the contract termination date
5. Technical PII, including without limitation the IP address number, the Platform usage, setting, and web browser connection that has been connected to the Platform.
Period: 5 years from the contract termination date
6. Pictures Photos voice records Medical History and Medical records
Period: 5 years from the contract termination date
Data Subject Rights
Data subjects have the following rights:
1. Right to withdraw consent: Users can withdraw their consent and request the processors to stop collecting their personal data.
2. Right of Access: Users can submit data access requests, which oblige processors to provide a copy of any personal data they hold regarding data subjects. This includes a request for a disclosure of platforms and methods from which the processors collected the data.
3. Right of Rectification: Users can request an update on inaccurate or incomplete personal data.
4. Right to Erasure: Users can request that the service provider erase their data in certain circumstances, such as when the data is no longer necessary, the data was unlawfully processed, or is no longer meeting the lawful ground for which it was collected. This includes the instance where the individual withdraws consent.
5. Right to Restriction of Processing: Users can request the service provider to limit the way their personal data is used.
6. Right to Data Portability: Users are permitted to obtain and reuse their personal data for their own purposes across different services.
7. Right to be informed: Users have the right to be notified about the collection of their personal data such as storage periods and purposes.
8. Right to Object: Users can object to the processing of personal data that is collected on the grounds of legitimate interests or the performance of a task in the interest/exercise of official authority.
You may contact our Data Protection Officer if you have any inquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner
For full guidelines, please visit Thailand Data Protection Guideline 2.0, Ministry of Digital Economy and Society website http://www.mdes.go.th, GDPR Guideline https://gdpr.eu/, European Commission https://ec.europa.eu/.
Personal Information Request Form
In the case that you would like to manage your personal data, including:
1. Data access request
2. Data correction request
3. General Consent Withdrawal request
4. Complaint submission
Please contact our Data Protection Officer through the following details in the "Contact Us" section down below.
Personal Data and Marketing Activities
To optimize users’ satisfaction, we may distribute information regarding our marketing activities such as promotion, discount, and news. This also includes information related to your preferences. Users can withdraw their consents after the subscription by contacting sales@sc-grand.com.
What are Cookies?
Cookies are text files stored on your computer's browser directory or program data subfolders. Cookies are created when you use your browser to visit a website that uses cookies to keep track of your movements within the site. If you wish to learn more about cookies, visit https://www.allaboutcookies.org/.
How Do We Use Cookies?
1. To increase the efficiency and safety of the user’s log-in process
2. To collect user’s platform usage, content adjustments, and personal settings
3. To research an individual user’s behavior on the platform for satisfaction optimization purposes
4. To research the behavioral trend of all users in order to increase the efficiency of the platform
Types of Cookies
1. Functionality Cookies: Functionality cookies record information about choices you have made in the platform such as personal settings, languages, and fonts. This allows us to tailor our platform to you.
2. Advertising Cookies: Advertising cookies record your on-site behavior and history of sites visited. This allows us to provide you with the services, products, and advertisements that suit your preferences.
3. Strictly Necessary Cookies: These cookies are essential for you to browse the website and use its features, such as accessing secure areas of the site.
4. Performance Cookies: These are cookies used for gathering site visitors’ data anonymously, including the page that is visited most frequently on the website. This allows us to efficiently improve our platform regarding users’ preferences.
5. Third-party Cookies: These cookies will be determined by third parties such as Google Analytics
Cookies Setting
Users can disable cookies on their browsers.
Effect of Notice and Changes to Notice
This Notice applies in conjunction with any other notices, contractual clauses, and consensual clauses that apply in relation to the collection, usage, and disclosure of your personal data by us.
We may revise this notice from time to time without any prior notification. You may determine if any such revision has taken place by referring to the date on which this notice was last updated. Your continual use of our services constitutes your acknowledgment and acceptance of such changes.
Effective date:
10/09/2021
Last updated:
10/09/2021
Contact Us
Data Processor
Name: CIRCULAR INDUSTRY CO.,LTD
Address:
CIRCULAR INDUSTRY CO.,LTD
212 Moo 2 Soi Prachauthit 90, Prachauthit Road., Ban Klongsuan, Prasamut Jadee, Samutphakarn 10290 Thailand
Email address: sales@sc-grand.com
This privacy policy of CIRCULAR INDUSTRY CO.,LTD (“CIRCULAR”) applies to the operations of CIRCULAR that CIRCULAR offers through the website www.circular-club.com (hereinafter collectively referred to as “Services”). It provides the policies and procedures for collecting, using, and disclosing the information of each visitor or user of the Services (“User”). The User shall also include users who subscribed to the Services and those who did not subscribe to the Services. This Privacy Policy (the “Policy”), describes what information CIRCULAR collects and what it's used for. Please read this Policy carefully as it describes how CIRCULAR collects, uses, discloses, and/or transfers User personal information.
What Information CIRCULAR Collects
1. Information About User
CIRCULAR may collect information about User, for example, name, surname, phone number, gender, date of birth, E-mail, profile picture, contact information and the data, pictures, sounds, logos or contents that the User uploaded or disseminated onto the Services. This information allows CIRCULAR to improve our services and provide additional features and functionality.
If you purchase our products or services through our Services, for example, if you purchase clothing or other services, CIRCULAR may collect information about User, contact information, payment information, and service information, for example, name, surname, telephone number, address, and congenital disease.
If you are a business owner, CIRCULAR may collect information about User business. For example business name, business owner’s name, juristic registration number or identification number, address, telephone number, E-mail, contact information, and financial information (e.g. name of bank account, account number, bank name).
In addition, CIRCULAR may collect User additional information from other websites, organizations, or other sources to improve our services and provide additional features and benefits.
You shall notify CIRCULAR of any changes in User personal information so that CIRCULAR may adjust the information to be as accurate, as up-to-date, and as complete as possible. If you fail to notify the change to us, User personal information under our control shall be deemed to be accurate, up-to-date, and complete. You acknowledge and agree to waive and forfeit any right to contest or take any legal action against CIRCULAR for the inaccuracy or incompleteness of the said personal information.
In the event that you provide personal information of other person, you are responsible for informing that person about the Services and the associated data collection, use, disclosure and/or transfer to overseas prior to submission of those persons' personal information to us, obtaining their consents or relying on other applicable legal bases as an exception to consent, and advising them of this Policy.
2. Information CIRCULAR Collects Automatically
CIRCULAR may automatically collect information about User use of the Services such as access time, User activities within the Services, the length of time that you are logged in, device ID or other unique identifiers, IP address, mac address, language information, device name and model, location and timezone, geo-location data.
How CIRCULAR Use Information
CIRCULAR uses the information from and about User for your benefits in using the CIRCULAR’s Services that meet User’s purposes and for other purposes necessary under laws:
To provide and operate the Services and to fulfill our contractual obligation with you.
To respond to User requests, communicate with you, to provide customer service and technical support.
To verify User identity and prevent spam or other unauthorized or illegal activity.
To prevent, detect, mitigate, and investigate fraud, security breaches, or other potentially prohibited or illegal activities
As necessary to meet responsibilities CIRCULAR has to our regulators, tax officials, law enforcement, or otherwise meet our legal obligations.
As necessary for our legitimate interests or legitimate interests of any other person or legal person.
For preventing or suppressing a danger to a person’s life, body or health.
As necessary for the performance of a task CIRCULAR carried out in the public interest, or it is necessary for the exercising of official authority vested in us.
For the achievement of the purpose relating to the preparation of the historical documents or the archives for a public interest, or for the purpose relating to research or statistics with appropriate security measures.
Moreover, CIRCULAR uses the information to enable User to receive benefits from using Services according to User’s given consent:
To better understand how users access and use our Services, in order to improve our Services and respond to user desires and preferences, and/or for other research and analytical purposes.
To offer you the promotions from CIRCULAR and/or from our affiliates and business partners.
To analyze, deliver targeted marketing, targeted advertising, service updates, and promotional offers based on User communication preferences and to improve and keep our product up to date with the latest technology.
If you do not provide User information to us, CIRCULAR may not be able to facilitate, communicate or provide some or all of our Services to you.
How CIRCULAR Share Information
CIRCULAR may disclose and/or transfer User information to the following parties within Thailand and/or to overseas, which such destination countries may or may not have an adequate data protection standard similar to Thailand.
1. Our Affiliates and Subsidiaries
CIRCULAR may disclose the information CIRCULAR collects to our affiliates and subsidiaries for the purposes under this Policy.
2. Service Providers
CIRCULAR may disclose the information CIRCULAR collects to third party vendors, service providers, contractors or agents who perform functions on our behalf.
3. Business Transfers or Mergers
CIRCULAR may transfer the information CIRCULAR has collected to another company in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business.
4. Third Parties and Partners
CIRCULAR may share the information with our third-party partners, including advertisers and researchers.
5. In Response to Legal Process
CIRCULAR also may disclose the information in order to comply with the law, a judicial proceeding, court order, subpoena, or other legal process.
6. To Protect CIRCULAR and Others
CIRCULAR also may disclose the information if CIRCULAR believes it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which CIRCULAR is involved.
7. Aggregate and De-Identified Information
CIRCULAR may also share aggregated or de-identified information about users with third parties for marketing, advertising, research or similar purposes.
8. Other Users
As part of the Services, CIRCULAR may make User personal data available to other users.
How Long Do CIRCULAR Keep User Information
CIRCULAR generally only keeps User information to the extent necessary for the performance of our Services and/or obligations and for as long as is reasonably required for the purposes explained in this Policy or as required by applicable data protection laws. CIRCULAR will also retain information if CIRCULAR reasonably believes there is a prospect of dispute/litigation to the extent permitted by applicable laws. CIRCULAR will use its best effort to arrange for the security procedure for User personal information to prevent the loss, or the unauthorized access, usage, amendment, modification, or disclosure of User personal information.
Cookies
A cookie is a small text file that is stored on User computer when visiting a website. This text file stores information that can be read by the website when visiting it again at a later date. Some of these cookies are necessary because otherwise the site is unable to function properly. Other cookies are convenient for the visitor: they remember User username in a secure way as well as User language preferences, for example. Cookies mean that you do not need to fill out the same information each time you visit a website.
CIRCULAR will store User activities within the Website through cookies and similar local storage technologies and CIRCULAR uses cookies to improve the efficiency of accessing and using our service through the internet. CIRCULAR use cookies:
To help CIRCULAR maintain User sessions when you use Services and/or any additional services.
To enhance security of our systems.
To store User preferences and provide customized services to you.
To help CIRCULAR understand how people use Services and to improve them.
The types of cookies CIRCULAR use and why CIRCULAR use them includes but is not limited to the following:
Strictly necessary cookies: These are cookies that are required for the operation of the website, and include, for example, cookies that enable you to log into secure areas of the website;
Functionality cookies: These are used to recognize you when you return to the website. This enables CIRCULAR to personalize our content for you, tailor the website for User needs and remember User preferences, for example, User choice of language;
Analytical/Performance cookies: These cookies allow CIRCULAR to recognize and count the number of visitors and to see how visitors move around and use our website. These cookies are used for website enhancement and optimization purposes and to aggregate statistics on how our visitors reach and browse our websites. This helps CIRCULAR to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily and to help CIRCULAR understand what interests our users, and measure how effective our advertising is;
Advertising cookies: These cookies will remember User preferences, and in general, that User used the website, to tailor advertising to you that are as relevant to you as possible, e.g. by selecting interest-based advertisements for you, or preventing or limiting the number of times you see the same advertisement to help measure the effectiveness of advertisements.
Most Internet browsers allow you to control whether or not to accept cookies. If, however, you deactivate cookies or limit the ability to set cookies, you may not be able to obtain the full benefit of the website or access all of its functions, which may limit User overall user experience.
Push Notifications/Alerts
CIRCULAR may send push notifications or alerts to User device. You can deactivate these messages at any time by changing the notification settings on User device or by changing User Services settings.
User Rights
Subject to applicable laws, you may have the following rights with respect to User personal information:
You have a right to withdraw consent for the collection, use, or disclosure of User information that is based on User consent at any time. However, if you withdraw User consent, CIRCULAR may not be able to facilitate, communicate or provide some or all of our Services to you;
You can request access to, obtain a copy, of User information that CIRCULAR hold about you;
You can request CIRCULAR to rectify User information to be accurate, up-to-date, complete;
You have a right to request CIRCULAR to erase or destroy or anonymize User information in certain circumstances as applicable with law;
You have a right to request CIRCULAR to provide User information or transmit that information to another organization;
You have a right to object to CIRCULAR or restrict CIRCULAR from collecting, using, or disclosing User information in certain circumstances;
You have a right to lodge a complaint with the competent public authority if you believe that CIRCULAR has not complied with law.
You can exercise these rights by contacting CIRCULAR per the Contact Us section below.
Third-Party Websites
This Policy only governs the use of our services through our Website. Any access to and use of such links to third-party websites is not governed by this Policy (even if you have access to third-party websites through our Website), but instead is governed by the privacy policies of those third party websites.
Amendment of this Policy
CIRCULAR will review the privacy policy to comply with the guidelines and the regulations. CIRCULAR may change this Policy from time to time and will notify you of such change. Where applicable and required, CIRCULAR will ask for User consent for any change that User consent is needed.
Contact Us
If you want to exercise any of the rights as permitted by applicable laws set out above, have any questions about the Privacy Policy of our services, comments, concerns or would like to make a complaint about this Policy, please contact our company.
CIRCULAR INDUSTRY CO.,LTD
212 Moo 2 Soi Prachauthit 90, Prachauthit Road., Ban Klongsuan, Prasamut Jadee, Samutphakarn 10290 Thailand
