Data Privacy Policy and Notice
of
Siam Wellness Group Public Company Limited and
the Subsidiary Companies

1. Introduction

Siam Wellness Group Public Company Limited and the Subsidiary Companies (hereinafter referred to in this policy as The “Group”) recognizes the importance of protecting the personal information the Group receives from the data subject. According to the Personal Data Protection Act B.E. 2019, therefore, this policy has been prepared to announce and clarify the collection, use, transfer or disclosure of personal information to the data subject and related agencies to know and understand, Rights and duties of the Group and of the Personal Data Subject as required by law

2. Definition

“Group” means Siam Wellness Group Public Company Limited and the Subsidiary Companies incorporated in Thailand such as Siam Wellness Lab Co., Ltd., Siam Wellness Resort Co., Ltd., Siam Wellness Education Co., Ltd. and Tiger Eyes Trading (Thailand) Co., Ltd.

“Personal Data Protection Law” means the Personal Data Protection Act B.E. 2019, including the relevant ministerial regulations, announcements and regulations (secondary laws) and which will be amended in the future.

“Personal Information” means any information about an individual that enables that person to be identified either directly or indirectly, but does not include the information of the deceased, especially in accordance with the law on protection of personal data and does not include information of legal entities.

“Sensitive Data” means personal data about race, ethnicity, political opinions, cult religion or philosophy, sexual behavior, criminal records, health information, disability, trade union information, genetic data, biological data, or any other information similarly affecting the subject of personal data as the personal data protection law stipulates.

“Data Subject” means the subject of personal data that the Group perform personal data processing including but not limited to customers who come to use the service, customers who purchase products and products, partners, contract parties, employees, consultants, directors, teachers, personnel of the Group, service partner, Students who come to study in a massage school, Shareholder of the group of companies, Visitors, agents and any person involved in the operations of the Group.

“Processing” means any processing of personal data whether it is collected, used, transferred or disclosed; including recording, organizing, modifying or altering, etc.

“Personal Data Controller” means a person or a juristic person who has the authority to make decisions about the collection, use or disclosure of personal data.

“Personal Data Processor” means a person or a juristic person who performs the collection, use or disclosure of personal data on the order or on behalf of the Personal Data Controller.

3. Personal data to be collected

3.1 The subject of personal data that the Group will collect, use, transfer or disclose is the following information subject:

3.2 The Group will collect your personal data or information obtained from you as follows; Such collection depends on the relationship between the Group, Data and the context and type of information.

3.3. Methods for collecting and obtaining your personal data

4. Legal bases and consent for collection, use, processing and disclosure of personal data

The Group will collect, aggregate, use, process and disclose your personal data within the framework required by law. or where the Group has your consent. which is based on the following base

5. Purpose of collection Use and disclose personal information under the law or with your consent.

The Group will process your personal data. For the following purposes, details are as follows:

Purposes and legal bases used for processing Details

5.1 For providing services to the group's customers

Legal bases used for processing pursuant to Section 4.1 - 4.4 and/or Consent Bases.

Health massage service, Massage for beauty, other spa services, onsen

  • Receiving reservations, calling to confirm or postpone access to the service, Screening for diseases or prohibited characteristics before using the service as required by law, Providing massage services for some people who report aches or symptoms in the area to be massaged, Receiving payments that are not paid in cash, Refunds, Refunds to you in case of necessity or force majeure, Collection of user data for customer satisfaction, such as delivery of goods and gifts, etc., To listen to any feedback or assess satisfaction and for the legitimate interests of the Group.
  • The exercise of the Group's rights, including the action required by law, Exercise of rights under the insurance policy of the group or your necessary litigation of the Group.
  • For use in invoicing, Receipts, Tax Invoices and/or other financial documents as well as complying with the accounting standards.
  • Hotel Service, Hotel reservations, Meeting rooms, Banquet rooms, Restaurants, Registration of stays, Validation providing services in hotels such as Table Reservations, Swimming pools, Fitness Centers, etc. Use for the Group's Lawful Interest

  • The exercise of the Group's rights, including taking action as required by law, The exercise of rights under the insurance policy of the Group or your necessary litigation by the Group.
  • For use in invoicing, Pay service fees, Deposits, Issue receipts, Tax Invoices and/or other financial documents as well as complying with the accounting standards.
  • 5.2 For selling products and products to customers of the company

    Legal bases used for processing pursuant to Section 4.1-4.3 and/or Consent Bases.
  • Reservation, Quote, Promotion Offering, Buy, Sell, Deliver of goods and products, Providing you with information about the products and how to use the products and products of the Group including contacting for details for such purposes and using information to satisfy you such as sending various gift vouchers. and for the legitimate interests of the Group.
  • Entering into the contract, performance of the contract and any actions in accordance with the contract and the law Monitoring and Enforcement of Contracts and Laws Exercise of the Group's rights and any necessary litigation.
  • for use in invoicing Receipts, Tax Invoices, and/or other financial documents as well as complying with the accounting standards.
  • 5.3 For treatment and providing services to visitors to use services in a physical therapy clinic.

    The legal bases used for processing are subject to Section 4.1-4.4 and/or Consent Base.
  • Accepting appointments to come to use the service and receive treatment including the next appointment to register the patient's history, Making a medical registration, treatment, recording a registration of treatment as required by law. Issuing a medical certificate for your follow-up treatment and taking action for the legitimate interests of the Group.
  • The exercise of the Group's rights, including taking action as required by law, Exercise of rights under the insurance policy of the Group or your Necessary litigation of the Group.
  • For use in invoicing Receipts, Tax Invoices, and/or other financial documents as well as complying with the accounting standards.
  • 5.4 For entering into a contract and complying with contract with partners of Group companies

    Legal bases used for processing pursuant to Section 4.1-4.4 and/or Consent Bases.
  • For the purpose of recruiting, inspecting, selecting and recording you as a contracting party with the Group, Entering into the contract, performance of the contract and any actions in accordance with the contract and the law. Applying for various licenses necessary for doing business, Monitoring and Enforcement of Contracts and Laws including the case of termination of the contract for the legitimate interests of the Group, Exercise of the Group's rights and any necessary litigation.
  • For use in making payments Payment of goods, wages, compensation, invoicing Receipts, Tax invoices, withholding documents and/or other financial documents as well as complying with the accounting standards.
  • 5.5 For managing the personnel of The Group including employees, consultants, trainers and directors of the Group.

    Legal bases used for processing pursuant to Section 4.1-4.4 and/or Consent Bases.

    Employees, Consultants, Trainers and Directors in the Group of Companies

  • For entering into an employment contract, performance of the employment contract with you, employment, termination of employment, management of foreign workers, disabled workers, Personnel Management Execution as commissioned. This includes compliance with the rules, regulations, discipline, announcements, orders and work regulations of the Group. Management of safety, occupational health, welfare and working environment, Skill development, inspection, investigation, compliance with contracts, rules, regulations, discipline, announcements, orders and regulations of the Group including as required by law. Performance evaluation, photo recording, Record audio and video, Voice recording of conversations, termination of employment, post-contract actions including litigation in accordance with the rights and duties of the parties. Execution of subpoenas or to comply with the law.
  • To comply with the law such as labor protection laws, Labor Relations Act, Social Security Act, Act on the Promotion and Development of Labor Skills Acts in accordance with the law relating to the request and employment of foreigners, Applying for a work permit for an alien or other relevant laws, Compliance with any rules and regulations of relevant agencies such as the Department of Labor, Protection and Welfare, Department of Skill Development, Department of Employment, Social Security Office, municipality, etc.
  • To apply for a license necessary for the business of a Group of Companies as required by law, such as a license for a spa establishment and health massage, Clinic license, hotel license etc.
  • For any administration related to the Social Security Fund, Provident fund, Compensation fund, Fund for Promotion and Development of the Quality of Life of Persons with Disabilities and Other Funds of the Group.
  • To manage welfare such as Group health insurance, medical expense reimbursement, Insurance money in case of injury or death, including keeping a history of illness, Welfare management; such as borrowing money from financial institutions or employers, etc. Training of group companies or government and private agencies, equipment supply, Facilities upon employment and welfare provided by the Group.
  • To administer the payment of salaries, taxes, compensation or other benefits to you upon employment; This includes keeping and recording records in accounting and taxation, withholding taxes, issuing payrolls. Salary slip including other tax and financial documents

    Director

  • In order to comply with the Civil and Commercial Code Company Partnership Act, Public Company Act, Securities and Exchange Act and other relevant laws, including rules, regulations, orders, announcements issued by relevant agencies such as the Stock Exchange of Thailand and the Securities and Exchange Commission.
  • Registration and applying for various licenses of the group of companies.

    Teacher, Trainer

  • For compliance to Private School Act or other relevant laws, including rules, regulations, orders, announcements issued by relevant agencies such as the Ministry of Education, Ministry of Public Health, Department of Skill Development, etc.
  • Requesting for teaching courses, including asking for permission to modify, Change the course of teaching, Teaching evaluation, history making, recording of teacher registration information, Appointment withdrawn report preparation, Conclusion of the test results and any action required by law.
  • 5.6 For the selection, entering into contracts, management, training and performance of contracts and laws relating to health massage partners.

    Legal bases used for processing pursuant to Section 4.1-4.3 and/or Consent Bases.
  • For the recruitment and selection as a service partner with the Group of Companies, disease examination and history, Entering into service contracts and training contracts, Management and compliance with service and/or training contracts, borrowing massage equipment, Massage evaluation including massage skills, allowing customers to make reservations for the next service, Entering and exiting establishments and providing services in health establishments in each branch of the Group. Adjustment of your posture at the Group massage school, Termination of a service or training contract and actions after the termination of a service and/or training contract.
  • For receiving the power of attorney to register as a service provider, Applying for a health establishment license to relevant agencies, Compliance with the Health Establishment Act and other relevant laws.
  • For the payment of compensation and any other benefits including the exercise of rights under your insurance policy, Entering into a contract of rights between the Group and you.
  • To be used to issue evidence of compensation for joining the service including withholding documents and other financial documents to you.
  • 5.7 For use in recruiting and training courses teaching Students attending and training in a health massage course

    Legal bases used for processing pursuant to Section 4.1-4.3 and/or Consent Bases.
  • For enrollment, apply for training, entering into a training contract, teaching registration and training, compliance with a training contract, actions related to teaching and learning, organizing exams, issuing scores, collecting and delivering documents for exams to enhance your labor skills as required by law, evaluation, testing, announcement of exam results issuing certificates, diplomas, certificates, and substitutes, Record audio and video Registration and student accounts, report preparation, test summary, Termination of the training contract, Actions after the end of the training contract including litigation in accordance with the rights and duties of the parties or to comply with the law.
  • For the purpose of compliance to Private School Act or other relevant laws, including rules, regulations, orders, announcements issued by relevant agencies such as the Ministry of Education, Ministry of Public Health, Department of Skill Development, etc.
  • For use in invoicing Receipts, Tax Invoices, and/or other financial documents as well as keeping and recording for the purpose of accounting data.
  • 5.8 For use in the performance of the rights and duties of The group of companies to the shareholders

    Legal bases used for processing pursuant to Section 4.1-4.3 and/or Consent Bases.
  • In order to comply with the Civil and Commercial Code Company Partnership Act, Public Company Act, Securities and Exchange Act or other relevant laws, including rules, regulations, orders, announcements issued by relevant agencies such as the Stock Exchange of Thailand and the Securities and Exchange Commission. Examination of the right to attend the shareholders' meeting, shareholder meeting voting, receiving dividends, Notification of the list of shareholders of the group of companies to relevant agencies request for replacement of share certificates and the request to exercise the right as a shareholder including any action required by law.
  • 5.9 For recruiting personnel of the group of companies

    Legal bases used for processing pursuant to Section 4.1-4.3 and/or Consent Bases.
  • For application, nomination, consideration of qualifications and your selection, photo recording, Record audio and video Record, your conversations including disease and history checks to recruit, appoint or hire you as an employee, employee, student intern or personnel within the organization and for other administrative purposes that may be beneficial to you, such as contacting you to work, Sending job information, Apply for an internship including in the event that you are not selected. The Company may retain your information for calling you back for a new interview or for a job in the same position or other position that the Group deems suitable for you within the period. enough time.
  • To improve and develop the applicant selection system, Consideration of the manpower rate of the Group of Companies, public relations and for the legitimate interests of the Group.
  • 5.10 Subscription or benefits with group of companies

    Legal bases used for processing pursuant to Section 4.1-4.3 and/or Consent Bases.
  • Apply for membership applications such as WellnessMe or other group benefits such as cash card issuance or the purchase of massage vouchers, Applying an onsen membership card, etc. For the Group to send you information about the Group including receiving benefits, Examination of the use of various benefits that have been made with the Group, Verification of identity to claim any rights with the Group, The information about your use of the service will be collected in order to create satisfaction for the next service to you. and for the legitimate interests of the Group.
  • For use in invoicing Receipts, Tax Invoices, and/or other financial documents as well as keeping and recording for the purpose of accounting data.
  • 5.11 Providing information and answering questions to you

    Legal bases used for processing pursuant to Section 4.1-4.3 and/or Consent Bases.
    If you come to the Company or a branch of a Group of Companies, call to visit the website of the Group of Companies or come to inquire, press follow news or make a reservation for goods and services through the information systems of the Group such as Line, Facebook, Wechat, etc., the Company will process your personal information for providing information. Answer questions or take action as you wish. The Company may record your browsing data using cookies. However, the company will ask for your consent in such matters first.

    5.12 For security

    The legal base used for processing in accordance with Sections 4.2-4.4 and/or the Consent Base.
  • For the development of safety standards in the service and use of the service, Management and protection of information, technology infrastructures such as the provision of Wi-Fi services in the Group's workplaces. In this section, the group of companies Encryption may be performed for security and verification purposes.
  • To control access to the building, parking lot and to ensure that each building establishment and the area of ​​the Group is safe for you and visitors and their property, as well as, for the security of any information located or stored in the premises of the Group whether in document or electronic form. To monitor and observe the entrance and exit of the building, the place, the parking lot that is secured, protected room, Warehouse premises, server rooms and other areas (collectively, “Buildings and Premises”) to prevent entry and exit of the Group's buildings and premises. and to prevent, detect and investigate security-related incidents such as theft, assault fire or other disaster.
  • For recording photographs, video and/or audio via CCTV (CCTV), video and audio recording of you and all persons including their property, such as vehicles, which enter the area under surveillance within or around the buildings, premises and facilities of the Group in order to protect life and assets to be safe including protection. Protect the premises facilities and the assets of the Group to be safe as well as to provide support and assistance to law enforcement agencies in the investigation, investigation, prevention, suppression and prosecution of both civil and criminal cases and actions to prevent potential crimes and/or to assist in the resolution of disputes arising in disciplinary proceedings or grievances including labor litigation. However, the Group will have a CCTV warning sign indicating that the CCTV camera is being used in the area as well.
  • 5.13 For other purposes that the Group notify you at the time personal data is collected

    Legal bases for processing Consent base

    The Group will notify you of any other purposes that cause the Group to want to use your personal data in addition to the purposes stated above or when the Group wishes to have a change to the original purpose set or when the Group is necessary to obtain your consent for the specific processing of personal data. By contacting you through the contact information you have provided to the Group.

    In the event that the Group of Companies will use your personal data for purposes not listed above The Group will provide additional Privacy Policy Notices to explain the use of information for such purposes. You should read the additional Privacy Notice in conjunction with this Privacy Policy.

    6. The necessity of entering into a juristic act and possible consequences of not providing information

    Due to your personal information at the Group of Companies, Processing will be carried out for the purposes stipulated in Article 5 above, which are necessary for entering into a contract, providing services, complying with the law or is acting according to your wishes where your personal information is necessary for the achievement of that purpose. If you do not provide such personal information to the Group, Failure to provide such information may prevent the Group from performing its obligations to you or fulfilling its obligations to achieve such objectives. or may not be able to enter into a contract with you or even may affect the law If this is the case, the Company Group may be obliged to refuse or cancel the service. entering into a contract or any obligations to you whether in whole or in part

    7. External entities or personal data to which your personal data may be transmitted.

    7.1 The Group may disclose your personal information under the objectives set out above and in accordance with the rules prescribed by law to the following agencies and persons:

    7.2 Disclosure of your personal information to other parties will operate under the specified objectives or other purposes as required by law to do so only In addition, if the law requires your consent for the transmission of information. The Group will obtain your express consent.

    7.3 In the event that the Group disclosing your personal information to other parties, the Group will take appropriate measures to protect the personal information disclosed and to comply with personal data protection standards and duties as required by the law on personal data protection

    8. Transferring your information abroad

    In the event that the Group will send or transfer your personal data abroad, The Group will monitor and take steps to ensure that the destination country or international organization that will receive your personal data has adequate personal data protection measures or the transfer of your personal data is a case that is exempt from personal data protection laws, including that you have given your consent to the transfer of your personal data abroad.

    9. Period of retention of personal information

    The Group will retain your personal data for the period necessary to fulfill the stated purpose of processing that personal data. The retention period of personal data will vary depending on the purpose for which it was collected. and process that personal data.

    In addition, the Group will keep your personal information in order to comply with applicable laws, rules and regulations. taking into account the business practices for each type of personal data such as accounting information Customer relationship management Processing of legal claims or relevant authorities that have been requested, etc.

    10. Personal Information of Minors

    Minors are not the Group's main target audience. However, in certain activities, minors may be involved, and from time to time the Group may have to collect and process personal data relating to individuals under the age of 20. Therefore, the Group will comply with the personal data protection laws in relation to the processing of personal data of minors. This includes seeking consent from a legitimate representative or an authorized person as required by the law on personal data protection.

    11. Rights of the Personal Data Subject

    Under the provisions of the Personal Data Protection Law You should acknowledge that you have legal rights regarding the collection, use, disclosure and/or transfer of your personal data in the following ways:

    12. Security in keeping personal information

    The Group has established and/or chooses to store personal data with appropriate mechanisms and techniques. and have security measures in accordance with the law on personal data protection and related laws including limiting access to your personal data that can only be accessed by those involved. To prevent your personal information from being used, disclosed, destroyed or accessed without permission. In addition, the Group also has a policy for internal and external parties concerned to be aware and aware of data retention and to take care of personal data to have security standards for personal data protection.

    13. Links to the Website Third Party Products and Services

    Group services; There may be links to websites, applications, products, products. and third party services. Such third parties may collect certain information in connection with your use of the Service. This Privacy Policy applies solely to the processing of personal data for the purposes established by the Group Companies. The security or privacy of any of your information collected by such third party websites, applications, products or services. Even if you click on the links displayed on the Group's services, you should exercise caution and check the privacy policy. Privacy policies or notices of those third party websites, applications, products and services.

    14. REVIEW AND CHANGES TO THIS PERSONAL DATA PROTECTION POLICY

    The Group may from time to time make changes to this Privacy Policy. To comply with any changes related to the processing of your personal data and to comply with the changes in accordance with the provisions of the Personal Data Protection Law or other relevant laws. The group of companies will notify you of any material revisions by means of appropriate and feasible communication channels. However, the Group recommends that you review this Privacy Policy from time to time.

    15. Governing Law

    This Privacy Policy It is subject to the enforcement and interpretation of Thai law. and the Thai courts have the authority to decide any disputes that may arise or in connection with this Privacy Statement.

    16. How to contact

    If you have any questions about this Privacy Policy, or wish to exercise your rights as set forth in Section 11 of this Policy. Please use the contact form on the website at www.siamwellnessgroup.com. You can also contact the group of companies. through the Data Protection Officer of the Group by using the following contact details:


    Email : [email protected] Telephone : 02-641-6619 ext. 113
    or
    send mail to
    Data Protection Officer, Siam Wellness Group PCL,
    BU Place, 22nd Floor, No. 567 Soi Sutthiphorn, Pracha Songkhro Road, Din Daeng, Bangkok 10400

    This announcement of Personal Data Protection Policy will be effective on June 1, 2022 orwhen the Personal Data Protection Law comes into force.