This privacy policy (“Privacy Policy”) explains how Brave group APAC (Thailand) Co., Ltd. (“Brave”, or “we” or “our”) will collect, use, disclose, and process in any manners a Personal Data (as defined herein) relating to users (hereinafter referred to simply as the “Users”) of services provided by Brave (the “Services”) and our business partner (hereinafter referred to simply as the “Partners”, collectively with Users as “you” or “your”) and other Personal Data which we will obtain as specified herein.

 

In addition to this Privacy Policy, Brave may stipulate other rules relating special handling of Personal Data about the Users (the “Individual Rules”) for Braves’ individual services. In such cases, the Individual Rules shall constitute a part of this Privacy Policy, and if there is any conflict between the two, the Individual Rules shall prevail.

 

As Brave may revise all or a part of this Privacy Policy as necessary, so please read all this Privacy Policy before using the Services.

 

1.  Acquired Personal Data

 

The Personal Data that we obtain in order to achieve the purposes of use in Section 4 (the “Acquired Personal Data”) includes the following “Personal Data” as defined in the Personal Data Protection Act B.E. 2562, as amended, as well as any subordinate legislations thereunder (collectively, “PDPA”).

 

(1) Following information:

1. 1.Name, date of birth, gender, occupation (including job title), and other information that may, directly or indirectly, identify any specific individual;
2. 2.Information such as address, telephone number, account information (i.e., e-mail address and password), nickname, etc.
3. 3.Credit card information, payment information such as crypto currency and blockchain wallet addresses;
4. 4.Hobbies, family structure, age, and other personal attribute information that is integrated with Personal Data;
5. 5.Information related to identity verification; and Information about the Users obtained in connection with your use of the Services;

 

(2) Information related to the use and browsing of the Services by the User, such as the content of the Services used by the User, the date, time and number of times used, and the User’s online behavior when using the Services (including information related to the User’s communications, such as cookie information (please see further details on how we process your cookie information via Cookie Policy), access logs and other information related to usage status, device information used, location information, IP address, browser information, browser language, etc.)

 

(3) Information regarding the payment status of the Users and the Partners in relation to the Services or business relationships.

 

(4) When the User has permitted linkage with external services such as social networking services when using the Services, the ID used by the User on such external services and information that the User has permitted to be disclosed to the linked party according to the privacy settings of such external services

 

2. Method of collecting the Acquired Personal Data

 

Brave will collect the Acquired Personal Data through the following methods;

1. 1.Users input on the Services directly;
2. 2.Users provide the Acquired Personal Data to Brave in person, by e-mail, mail, in writing, or by telephone, etc.(When answering the phone with the User, Brave may record such call to improve the quality of the response, etc.);
3. 3.Methods to collect information when the Users use or browse the Services; or
4. 4.Indirect collection from Partners and third parties.

 

3. Management of the Acquired Personal Data

 

Those who are engaged in the management and use of the Acquired Personal Data in Brave will strictly manage the Acquired Personal Data and will take sufficient care in handling the Acquired Personal Data to prevent unauthorized access, loss, leakage, or falsification of Personal Data as well as to ensure that all the activities with respect to the collection, use, disclosure,  or process of Personal Data shall strictly comply with this Privacy Policy and the PDPA..

 

4. Purpose of use of the Acquired Personal Data

 

Brave will use the Acquired Personal Data appropriately to the extent necessary to achieve (i) the purposes notified or announced at the time of acquisition or collection, (ii) the purposes stipulated in the Terms of Use, etc., or (iii) the following purposes. In addition, Brave may change the purpose of use to the extent that it is reasonably deemed to be related to the purpose of use before such change, and Brave will announce such change in a notice when it occurred on the Services or on the website operated by us, or in any other easily understandable manner.
<Personal Data of the Users of the Services>

1. (1) For identity verification;
2. (2) To communicate and provide information on various matters related to the Services;
3. (3) To provide the Services;
4. (4) To simplify the input of information required for the Users registration for the Services;
5. (5) To link information between the Services that the Users has applied for;
6. (6) To confirm applications for e-mail delivery services and to deliver e-mails;
7. (7) To confirm and deliver purchases related to the Services;
8. (8) To confirm billing and payment for the Services;
9. (9) To send you rewards for your cooperation in surveys, etc.;
10. (10) To send prizes for prize competitions, etc. to which you have applied;
11. (11) To survey and analyze the usage of the Services;
12. (12) To improve and enhance the Services to better satisfy our customers or to develop new services;
13. (13) To prevent fraudulent activities that interfere with normal service provision (including detection of the Users violating the Terms of Use, etc. and notification to such users, and investigation, detection, prevention, and response to fraudulent activities such as fraud and unauthorized access that abuse the services, etc.);
14. (14) To customize the contents of the Services to suit the Users;
15. (15) To survey the level of satisfaction with the Services;
16. (16) To aggregate and publish the results of the survey of the information which is statistically processed from the Acquired Information;
17. (17) To send information and notices about the Services, new services, and other various services;
18. (18) To request cooperation for surveys and participation in various events, and to report the results of such surveys and events;
19. (19) To distribute or display advertisements of Brave or third parties;
20. (20) To distribute or display product information within services provided by Brave or third parties; and
21. (21) To resolve problems in the operation of the Services and to comply with laws and regulations.

 

< Personal Data (name, affiliation, contact information, etc.) related to the Partners>

1. (1) To communicate, consult, place and receive orders, settle payments and execute and manage other transactions with Brave;
2. (2) To manage customer information;
3. (3) To prevent fraudulent activities that interfere with normal transactions;
4. (4) To send information and notices regarding the Services, new services, and other various services; and
5. (5) To resolve problems related to transactions and to comply with laws and regulations.

< Personal information regarding applicants who have applied for or participated in our recruitment activities>

1. (1) To provide information on recruitment and job openings, to conduct employment screening, and to confirm application histories.
2. (2) To communicate with applicants and respond to inquiries from applicants
3. (3) To provide information on recruitment-related events and seminars operated by Brave
4. (4) To prepare statistical data for use in the formulation of our future recruitment policy, etc.
5. (5) To resolve problems related to recruitment and to comply with laws and regulations

 

< Personal information concerning our directors, employees, retirees and their family members (hereinafter collectively referred to as the “Employees, etc.”)>

1. (1) To notify and communicate with the Employees, etc.
2. (2) To manage the employment of the Employees, etc. (payment of compensation, etc., performance of personnel and labor management, provision of benefits, etc.)
3. (3) To manage the health of the Employees, etc. and to ensure an appropriate working environment
4. (4) To provide benefit services to the Employees, etc. and to handle various insurance procedures, etc.
5. (5) To submit notifications and reports to government and other public offices concerning the Employees, etc.
6. (6) To resolve problems related to the Employees, etc., and to comply with laws and regulations

 

5. Applicable Legal Bases

 

Your Personal Data shall be collected, used, disclosed, and processed for the aforementioned purposes and by relying on the following legal bases under the PDPA:

 

1. 1.The performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
2. 2.The Processing is necessary for legitimate interests pursued by Brave as a data controller or interests of a third party other than you, except where your fundamental rights and freedoms regarding the protection of his or her Personal Data override these interests;
3. 3.To comply with any legal obligations imposed upon Brave;
4. 4.To prevent or suppress a danger to a person’s life, body, or health;
5. 5.The performance of a task carried out in the public interest or in the exercise of official authority vested in Brave;
6. 6.The achievement of purposes relating to the preparation of historical documents or archives for the public interest or for purposes relating to research or statistics in which suitable measures to safeguard the data subject’s rights and freedoms are taken; and/or
7. 7.Processing based on your consent.

 

6. Joint use

 

Brave may jointly use the Acquired Information as follows;

1. 1.Scope of joint use
2. 2.Our group companies (for details, please click here)
3. 3.Purpose of use
4. 4.To be used by our group companies for the same purposes as described in section4.
5. 5.To communicate and hand over information to company in charge in the event of an inquiry, application for use, or other request regarding the products or services provided by Brave or our group companies.
6. 6.For management and internal administration of our group companies.
7. 7.Items of Personal information to be jointly used
8. 8.Name, date of birth, address, gender, telephone number, account information, nicknames and other information, SNS account information, transaction details (including information on service usage, purchase history, payment information such as credit card information or wallet address, payment status, etc.), etc.
9. 9.Responsible for the management of Personal information used jointly
10. 10.Brave group Inc. (for details, please click here)

 

7. Transfer/Disclosure of the Acquired Personal Data to third parties

 

In certain circumstances, and for the purposes of this Privacy Policy, Brave may transfer or disclose some or all of the Acquired Personal Data to the following third parties, within the scope permitted by law:

1. 1.Our group companies, subsidiaries, affiliates, and any related companies to the extent necessary in providing the Services. For more details of our group companies, please click;
2. 2.Third-party service providers, including but not limited to delivery companies, settlement agents, subcontractors, or other third parties for the purpose of product delivery, payment settlement, response to inquiries from the Users, inquiries from Brave to the Users, provision of related after-sales services, and provision of other services, etc. in order to achieve the performance of Services to the Users;
3. 3.Third-party service providers, including but not limited to warehouse service providers, printing house, IT service provider, auditors, lawyers, tax and legal advisers and any consultants, to the extent necessary of carry out the ordinary course of business;
4. 4.Court, administrative agency, supervisory authority, or other public agency as required by applicable laws and regulations;
5. 5.Third-party marketing agencies, analysts, researchers, and/or advertisement service providers for the purpose of market planning, market research, data and business analysis, advertisement, etc.
6. 6.Other third parties as per your consent or contractual requirements or legal requirements, as the case may be.

 

8. Transfer of Personal Data Outside Thailand

 

Brave may provide the Acquired Personal Data to third parties which are located/resided outside Thailand (e.g., to Japan, etc.), to process and achieve the purposes of collection, use and disclosure specified herein. In such case, Brave shall comply with the requirements under the PDPA for the purpose of the transfer hereunder, including to ensure that the country of destination has an adequate data protection standard. However, please be aware that certain countries may not currently offer the same level of standard on data protection as in Thailand, in that regard, we will put in place any reasonable measures to ensure that your Personal Data is processed securely and in accordance with this Privacy Policy.

 

9. Personally relevant information

 

For the purpose of maintaining and protecting the convenience improvement sessions such as automatic input of e-mail addresses when logging in to the Services, for security protection, and for researching and analyzing the usage of the Services and the effectiveness of advertisements related to the Services, Brave may acquire cookies, device type, device identifier, browser type, referrer, IP address, and other advertising identifiers (collectively, the “Personally Relevant Information”) by incorporating information collection modules selected by us, such as Google Analytics.

These information collection modules collect the Personally relevant information without including personally identifiable information, and the collected information is managed in accordance with the privacy policy and other rules stipulated by each information collection module provider and Brave may use cookies and the Personally relevant information obtained from information collection module providers in conjunction with Personal information that Brave already has.

If you do not want your data to be collected by Google Analytics or other information collection modules, please reject the use of your data in the manner prescribed by Google Inc. or other information collection modules. However, if you prohibit the use of cookies and other personally identifiable information, you may not be able to use the Services properly, or you may not be able to reflect advertising settings that require Personally relevant information.

 

For an explanation of the Google Analytics Terms of Service and Privacy Policy, please visit the following site;

 

Google Analytics Terms of Service
https://www.google.com/analytics/terms/jp.html
Google Privacy Policy
http://www.google.com/intl/ja/policies/privacy/
Google Analytics Opt-out Add-on:
https://tools.google.com/dlpage/gaoptout?hl=ja

 

10.Retention of Personal Information

 

Brave will retain the Acquired Personal Data to the extent necessary for the purposes stated in “Purpose of use of the Acquired Information” in this Privacy Policy and will promptly delete the same in the case that such data is no longer necessary.

 

The criteria for determining the retention period includes but is not limited to: (i) the duration of the contractual relationship between you and Brave; (ii) the legal obligations assumed by Brave; and (iii) a need to perform an agreement to which you are a party.

 

11.Information of minor users

 

If the Users are minor, the Users’ parent(s), guardian(s) or custodian(s) must agree to the contents of the Privacy Policy and Terms of Use, etc., and comprehensively agree to the Users’ use of the Services in accordance with the Privacy Policy and Terms of Use.

 

12.Improvement and update of the Privacy Policy

 

Brave will review the status of our operations regarding the handling of the Users’ Personal Data, etc., as appropriate, and change or amend this Privacy Policy from time to time in response to changes in laws and regulations, business needs, etc. Brave will notify the Users of any changes to this Privacy Policy, so please confirm the latest Privacy Policy before accessing or using the Services.

 

13.Data Subject’s Rights

 

Pursuant to the PDPA, you shall have the following rights towards your Personal Data:

• ・Right to withdraw your consent;
• ・Right to access Personal Data;
• ・Right to correct Personal Data;
• ・Right to erase, destroy, or anonymize Personal Data;
• ・Right to restrict the use of Personal Data;
• ・Right to request a data portability; and
• ・Right to object the Processing of Personal Data.

 

The request for exercising the above mentioned rights or for any general inquiries regarding the processing of your Acquired Personal Data may be submitted to Brave via the contact information as provided in Section 14.

 

Please be informed that, in certain circumstances to the extent applicable under the PDPA, Brave may reserve the rights to refuse your requests. For instance, if Brave deems that there is no legitimate basis for such requests, or if such request is excessive, or the requestor could not verify himself/herself that he/she is the data subject who has those rights toward the Acquired Personal Data retained by us. You may lodge a complaint to the Personal Data Protection Committee of Thailand (PDPC) if you do not agree with Brave’s decision.

 

14.Contact for inquiries

 

If you have any opinions, questions, complaints, request or other inquiries regarding our handling of your Acquired Personal Data, please contact us at the following address.

 

Inquiries to
contact@bravegroupapac.co.th

 

No.65, 42 Tower, 6th Floor, Room 601, Soi Sukhumvit 42 (Kluaynamthai), Sukhumvit Rd.,Phra Khanong, Khlong Toei, Bangkok 10110

 

Brave group APAC (Thailand) Co., Ltd.
Privacy Policy Last Updated and Effective: 7/16/2024