PII being Processed by the Company in the performance of the Service
In order to perform the required Services, the Company would need to collect and process the following PII from the User:
- Directly Identifiable PII such as name, age, nationality and date of birth
- Contact information such as address, phone number, and e-mail address
- Payment information such as the payment transaction information, bank account information and credit card information
- Transactional data, such as username – password and logs, transaction number and history that the User transact and use the Service, including the gathered preference and interest from the transactional behavior
Objectives for PII Process
- The Company would need to collect, restore and use the PII of the User in order to perform any Services as defined under the terms of service, including without limitation to verify the identity and eligibility of the User; to validate the payment conditions for any Service fee (if any); to monitor the transaction executed by the User; and to contact the relevant Use;
- The Company would need to collect and analyze the PII of the User in order to assess the User’s interest with an aim to provide customized and personalized Service that would meet the User’s interest and preference and to improve the User’s experience;
- The Company would need to collect and restore the User’s PII in order to provide other support services after the Service delivery such as in the satisfaction survey or the support and complaint redress mechanism;
- The Company may need to collect and restore the User’s PII as obliged under the applicable laws and regulations, for instance, for the withholding tax payment purpose.
The Company intends to store the PII of each relevant User for throughout the period of time that the User is still the registered User and for 3 (three) years after the User’s termination for the legitimate interest of the Company in the legal proceedings that the Company may have against the relevant User; provided that in case that the relevant laws requires the storage of the PII for the longer period than defined, the Company may need to do so.
Disclosure of the PII
In order to assure the performance of the Service as committed, the Company may need to disclose the User’s PII in the following circumstances:
- To disclose the User’s PII to the outsourced service providers engaged in the performing any direct support service in the Service performance by the Company to the User, including without limitation the advisors as well as the third party service provider (i.e. logistic service provider); provided that the Company shall only disclose the User’s PII strictly on the need to know basis only;
- To disclose the User’s PII in the usage of the storage service on Computer System On-premise;
- To disclose the User’ PII to third party in the legal proceedings to protect the Company’s legitimate rights or to detect and prevent any fraud on the Platform; provided that such disclosure shall be done on the limited and specific purposes as defined only;
- In case that the Company is obliged under the applicable laws, court judgment or administrative order to disclose any PII of any particular users, the Company would need to do so.
What are Cookies that the Company is using in Service Performance?
Cookies are text files stored on the User’s computer browser directory or program data subfolder in order to keep data log of the User’s internet usage and the User’s behavior or interaction when using the Service. For the good performance of the Service, the Company need to use various types of Cookies for various purposes as defined below:
- Functionality Cookies being used to record information about choices the User have made when using the Service such as personal settings, languages, and fonts so this would allows the Company to tailor the Service that would match the User’s preference setting;
- Advertising Cookies being used to record the User’s on-site behavior and history of the Service used and this would allow the Company to provide the User the Services that suit the User’s preferences and to assess the performance of each function of the Service.
- Strictly Necessary Cookies are essential for the User to browse and use the Service and to use its features, such as accessing secure areas of the Service system or interface.
Representation on the Privacy Security
The Company represents and guarantees that the Company shall use the most appropriate security measures to prevent the unauthorized access, amendment or disclosure of the PII in any form or in any circumstance by either internal or external persons and the Company commits to review those measures on the regular basis with the strong commitment to be in strict compliance with the applicable laws.
Data Subject Rights
The Company acknowledges and accepts the User’s rights as the data subject over their PII as defined under the applicable laws that include the following rights:
- Right to access; to request for copy; and to rectify or update their own PII;
- Right to request for data portability of the PII that the Company has processed in the readable forms by the tools or automatic mechanics to other data controller;
- Right to object to the PII process being undertaken;
- Right to request for the erasure or de-identification of any PII that does not have any necessary basis to process, i.e. after the consent withdrawal;
- Right to request to suspend the PII processing in case that request for erasure is being exercised or it is unneccessary to process such PII;
- Right to withdraw consent that has been given.
The User can contact the Company in order to make the request to exercise any defined rights through the defined channel without any charge and the Company will consider and notify the User of the Company’s determination within 30 days after the receipt of the User’s valid request.
Name: The Romoroom Company Limited
Address: 29/18 Moo 8 Ladsavai Lumlukka Pathumthani 12150
Contact detail: 0959895992
Email address: firstname.lastname@example.org