FynnCorp Capital Group Co., Ltd. and its affiliated companies (“FynnCorp” or “the Company”) recognize the importance of protecting and safeguarding the privacy and security of our customers, users, website visitors, and participants in our events (“you”).

This Privacy Policy (“Policy”) explains how we collect, use, and disclose your personal information on our website and through our services. We are committed to complying with the Personal Data Protection Act B.E. 2562 (2019).

By providing your personal information to FynnCorp, you consent to the terms of this Policy.

“Personal data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. However, personal data shall not include data relating to a deceased person or a juristic person.

Website Visits 

The Company may collect non-personally identifiable information, such as web browser type and server computer, in order to improve the Company’s website. This information is collected to better understand how visitors use the Company’s site. The Company may also collect personally identifiable information, such as Internet Protocol (IP) addresses, for login and comment posting purposes on the Company’s blog. The Company will only disclose IP addresses for those who have logged in and posted comments in a manner consistent with its disclosure of other personal information.

Personal Data Collection

When you visit our website, interact with our services, or provide us with your information, we may collect your personal data. The type and amount of data we collect will depend on the nature of your interaction with us. We may collect personal data from the following sources: directly from you (e.g., when you fill out forms or create an account), publicly available sources (e.g., social media), and third-party sources (e.g., our affiliates or business partners). This data may include, but is not limited to, your name, contact information, account details, and information about your use of our products and services.

Types of Personal Data Collected
We may collect, use, and disclose the following types of personal data:

• Identification data: Such as name, date of birth, ID number, passport number, or other government-issued identification.
• Contact information: Including mailing address, workplace, phone number, and email address.
• Social media information: Like Line ID, IP address, cookie ID, browser information, and other device-related data.
• Transaction data: Related to service sign-ups or inquiries.
• Usage data: Including website browsing history, search history, and interactions with our website or advertisements.
• Audiovisual data: Such as voice recordings, images, or videos that may identify you.
• Other data: Displayed on our platform to provide personalized services.
• Sensitive personal data: We may collect sensitive data, such as racial or ethnic origin, health information, or biometric data, with your explicit consent or as permitted by law.
• Automatically collected data: Technical information, such as IP address, cookie ID, and browsing history, is automatically collected when you visit our website.

Purpose of Processing Personal Data
We collect, use, and disclose your personal data in accordance with your requests and/or agreements with us, including but not limited to the following purposes:

• To process your membership, purchase, or service requests, and to communicate with you regarding our products or services.
• To provide customer support and after-sales services.
• To collect feedback on our products and services for statistical analysis, research, evaluation, and improvement.
• To promote our products and services and those of our affiliates.
• To provide you with information about promotions, marketing activities, and invitations to events, and to offer products or services that may interest you through your provided contact channels.
• To manage and optimize our website to better meet your needs by recording and tracking your website usage, generating statistics, and customizing content.
• To comply with laws, regulations, and governmental requirements, or to respond to legal claims.

Data Security and Confidentiality
We are committed to protecting your personal data. We implement appropriate security measures to safeguard your personal data against loss, unauthorized access, destruction, use, modification, or disclosure. These measures include, but are not limited to, administrative, technical, and physical safeguards, as well as access controls. We comply with all applicable data protection laws and regulations.

Minors
If you are under the age of 20 or are legally incapable of consenting to the processing of your personal data, we may require consent from your parent or legal guardian. However, if we become aware that we have collected personal data from a minor without parental or guardian consent, we will delete such data from our servers as soon as reasonably practicable.

Data Retention Period
We will retain your personal data for as long as necessary to fulfill the purposes outlined in this notice. We may be required to retain certain personal data for longer periods as may be required by applicable laws. When the retention period expires or the purpose for which the data was collected has been fulfilled, we will delete, destroy, or anonymize your personal data.

Disclosure of Personal Data
We will keep your personal data confidential and limit its use and access to authorized personnel. However, we may disclose your personal data to third parties with your consent or as permitted by law. Such third parties may include:

• Affiliated companies: We may share your data with our subsidiaries, affiliates, or related companies as necessary to fulfill the purposes outlined in this notice.
• Service providers: We may share your data with our service providers, such as payment processors, IT service providers, social media platforms, and legal advisors, to provide our services. These service providers are bound by confidentiality obligations and are not permitted to use your data except as necessary to perform services on our behalf or to comply with legal requirements.
• Business partners: We may share your data with our business partners to provide you with certain benefits, such as promotional offers.

Legal Requirements

We may disclose your personal data without your specific consent if we are required to do so by law or to comply with a government request.

Business Transfers

We may disclose your information, including personal data, in connection with a corporate reorganization, merger, sale of assets, or other business transfer. We will require the recipient to agree to protect your personal data in a manner consistent with this notice and applicable data protection laws.

Data Storage and Cross-Border Transfers

Your personal data will be stored both electronically and in physical form on our servers located in Thailand and on cloud-based servers (Amazon Web Services) located outside of Thailand. We may transfer your personal data to other countries or jurisdictions. In the event of a cross-border transfer, we will ensure that appropriate safeguards are in place to protect your personal data in accordance with applicable data protection laws.

External Links
Our website may contain links to third-party websites that are not operated by us. If you follow a link to any of these websites, please note that we have no control over the content, privacy policies, or terms and conditions of those websites. We encourage you to review the privacy policy and terms of service of every website you visit.

Remarketing
We use third-party remarketing services (including Google and Facebook) to advertise on their platforms. This involves the use of cookies to serve ads based on your previous visits to our website. These ads may appear on Google search results pages or the Google Display Network. Any data collected will be used in accordance with our Privacy Policy.

You can opt out of Google’s use of cookies by visiting the Google Ads Settings page. You can also set preferences for how Google advertises to you using the Ads Settings, and you can opt out entirely by using a browser plugin.

Disclosure of Personal Data
We may disclose your personal data to our employees, agents, and affiliates on a need-to-know basis to provide services to you or to operate our business. We will not disclose your personal data to any third party who does not have a legitimate need to know. However, we may disclose your personal data in compliance with a court order or governmental request, or when necessary to protect our property or rights.

If you have provided us with your email address, we may use it to send you newsletters, request feedback, or provide you with updates about our products or services. We reserve the right to disclose your inquiries and responses, and we will take reasonable measures to protect your personal data from unauthorized access, use, alteration, or destruction.

Marketing and Communications
We may use your personal data to analyze and improve our website, platform, products or services, and to conduct online marketing through various channels such as Google and Facebook to provide you with relevant products and services. We will only do so with your consent.

We may send you promotional materials or newsletters via email or SMS to offer you interesting activities or news. If you no longer wish to receive communications from us, you may withdraw your consent through the channels specified in this notice.
Our website may display third-party advertisements to facilitate our services. These third parties may have access to your personal data to perform activities on the website and are obligated not to disclose or use it for other purposes.

Your Rights as a Data Subject
Under the Personal Data Protection Act, you have the following rights:

• Withdrawal of Consent: If you have given your consent for us to collect, use, or disclose your personal data, whether before or after the effective date of the Personal Data Protection Act, you have the right to withdraw your consent at any time, unless restricted by law. However, the withdrawal of your consent shall not affect the lawfulness of the processing of personal data based on consent before its withdrawal.  
• Access to Data: You have the right to access your personal data and request that we provide you with a copy of your personal data, as well as request that we disclose how we obtained your personal data that you did not consent to.
• Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and have the right to transmit those data to another controller or to you, unless it is technically impossible.  
• Objection to Processing: You have the right to object, at any time, to the processing of your personal data, unless we have a legitimate reason to refuse your request.
• Erasure: You have the right to request that we erase your personal data if you believe that the collection, use, or disclosure of your personal data is unlawful, or if we no longer need to retain the data, or if you have withdrawn your consent or objected to the processing.
• Restriction of Processing: You have the right to request that we restrict the processing of your personal data pending the verification of your request to rectify or object, or where the organization has no ongoing legitimate reason to process the data but is obliged to retain it by law.  
• Rectification: You have the right to have inaccurate personal data about you rectified.
• Lodging a Complaint: You have the right to lodge a complaint with the relevant supervisory authority if you consider that the processing of your personal data infringes this law.

You may exercise your rights as a data subject by contacting us or our data protection officer as specified below. We will respond to your request within 30 days of receipt.

Cookies and Tracking Technologies
To enhance your online experience, our website uses cookies and similar technologies to provide personalized content, targeted advertising, and to store your preferences on your device.

A cookie is a small file that a website stores on your computer or mobile device. When you visit our website, cookies help us recognize and remember you, allowing us to tailor your experience.

If you prefer not to have cookies stored on your device, you can adjust your browser settings to decline cookies before using our website. Please note that disabling cookies may limit your ability to use certain features of our website. For more information, please refer to our Cookie Policy.

Types of Cookies We Use

• Strictly Necessary Cookies: These cookies are essential for the website to function properly and allow us to provide you with the services you have requested. They help us authenticate users and prevent fraudulent use of accounts. Without these cookies, we cannot provide you with the services on our website.  
• Analytical/Performance Cookies: These cookies help us understand how our website is being used by collecting information such as the number of visitors and how they navigate around the site. This information is anonymous and is used for statistical analysis. Disabling these cookies will prevent us from tracking website traffic and improving our services.
• Functional Cookies: These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies are persistent and remain on your device in order to remember your preferences for future visits. However, you can delete these cookies through your browser settings.  
• Advertising Cookies: These cookies are used to deliver advertisements that are relevant to you and to limit the number of times you see an advertisement. We may also share information from these cookies with third parties, including our business partners, to provide you with targeted advertising.

Data Breach Notification
In the event of a personal data breach that may affect you, we will notify the Personal Data Protection Commission without undue delay and within 72 hours of becoming aware of the breach. If the personal data breach is likely to result in a high risk to your rights and freedoms, we will notify you of the breach, along with the measures taken to mitigate the potential impact, without undue delay via our website, email, telephone, or any other appropriate means.

Changes to Privacy Notice
We may modify this Privacy Notice from time to time, and such modifications are at our sole discretion. We encourage you to review this Privacy Notice periodically to stay informed of any changes. Your continued use of the website following any changes to this Privacy Notice constitutes your acceptance of such changes. 

However, if a change materially affects your rights as a data subject, we will provide you with additional notice as appropriate prior to the change becoming effective.

Contact Information 
Should you have any questions or wish to exercise your rights, please contact us at:

Fynncorp Capital Group Co., Ltd. 

304 Vanich Place Aree Building (Building A), 15th Floor, Room No. 1503-1505, Phaholyothin Road, Samsennai, Phaya Thai, Bangkok 10400, Thailand 

Telephone: +66 (0) 2 636 5556 

Email: partners@fynncorp.com 
Website: https://fynncorp.com/

This Privacy Notice is designed to assure you of the security of your personal data and to demonstrate our commitment to transparency and accountability in protecting your personal information.

This policy was last updated and came into effect on November 13, 2024.