Personal Data means any information relating to a person, which enables the identification of such person, whether personally directly or indirectly.
Data Controller means a juristic person having the power and duties to make decisions regarding the collection, use, or disclosure of the Personal Data.
Data Processor means a juristic person who operates in relation to the collection, use, or disclosure of the Personal Data.
If you do not consent to the processing of your Personal Data as described in this Privacy Policy, we request you to cease the use of our Service and access to our Website. If we change our Privacy Policy, we will post those changes or the amended Privacy Policy on the Website. We reserve the right to amend this Privacy Policy at any time.
We will/may collect your Personal Data as follows:
In the event where we receive or collect your Personal Data provided by sources other than you directly, we will inform you of such collection within thirty (30) days from the day on which we have collected the mentioned Personal Data. We will make sure that we have received your consent to collect, use and process your Personal Data, unless we are able to rely on any relevant legal basis to justify an absence of the consent.
The Personal Data that we collect from you is information which enables the identification of your identity whether directly or indirectly which includes as follows:
We will collect, use, disclose your Personal Data only if necessary. This includes circumstances where we are obliged to perform in accordance with our regulatory obligations, agreement concluded between you and us and the legitimate interest of Translucia including an implementation according to your given consent and/or under legitimate ground of other applicable law(s) depending on case by case basis. The detail of how we will use your Personal Data for each purpose is described below:
Purpose / Activity | Type of information | Legitimate power for processing the information and legitimate interest |
o To confirm your identity or identify you when you use our platform o To perform our duty to provide you with information, content, products and services. o To identify you and distinguish you from other platform users o To track or record your usage on the platform as well as to prepare relevant reports o To implement the request(s) you made before you enter into an agreement or a contract with us o To consider and approve the provision of service including delivering our products and/ or services to you | o Personal information o Other Information | o For legitimate interest o (For the security of our network and the prevention of fraudulent act) o For our legal compliance o For the performance under the agreement or contract you have made with us |
o To improve our Service | o Personal information o Other Information | o For legitimate interest o For our Service development |
o To communicate our obligations and policies o We may use your information to inform you about your obligations towards us and any changes of our terms, conditions or Policies. o To manage the relationship between us and you (such as, customer care, assessing satisfaction and handling of complaints) | o Technical information o Other Information | o For legitimate interest o For informing you about your obligation towards us and changes of policies) o For our legal compliance |
o Conversation regarding problem solving o To notify you or fix problems that may arise in our Service. o To manage Interactive function of the platform | o Personal information o Other Information | o For legitimate interest (Helping you fix problems on the platform) |
o To protect business and platform o To manage and protect our business and platform including investigation of any violations of the terms and conditions of using our platform and solving problems regarding analysis of information from testing report-supporting maintenance system and hosting data | o Personal information o Technical information o Other Information | o For legitimate interest (Providing our Service, administrative and IT services, network security and preventing fraudulent act.) o For our legal compliance |
Since there are certain purposes for which we will/may collect, use, disclose or process your Personal Data subject to situation at that time, hence; such purposes may not be specified above. However, we will notify you and ask for your consent again when there is a purpose which a law specifies that a consent is needed to be obtained from you.
We implement a variety of security measures and strive to ensure the security of your Personal Data on our systems. User’s Personal Data is contained behind secured networks and is only accessible by a limited number of employees who have special access rights to such systems. However, we cannot guarantee of an absolute security of your Personal Data.
In the event that we or you have set a password for you to engage the Service provided on our platform, it is your responsibility to keep the password confidential to prevent other people from unlawfully accessing your Personal Data.
We would like to inform you that the transfer of information though the internet is not 100% risk free. However, we will use its utmost reasonable efforts to protect the Personal Data.
In conducting Translucia’s business, Translucia may need to disclose the Personal Data to Translucia’s third party service providers, agents and/or our affiliates or related corporations, and/or other third parties, whether sited in the Kingdom of Thailand or outside of the Kingdom of Thailand for one or more of the above-stated purposes. Such third-party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing the Personal data either on Translucia behalf or otherwise, for one or more of the above-stated purposes.
We will retain your Personal Data for the duration you remain a user of our platform in order to achieve the purposes set out in this Policy. In addition, we may have to store your Personal Data according to prescription or period specified by a relevant law. The details of the period we will store your Personal Data for each type of information are as follows:
No. | Type/List of Personal Data | Processing period |
1 | Personal information | 5 years form the date you cease the usage of our platform |
2 | Details of your requirements and comments towards our platform | 5 years form the date you cease the usage of our platform |
3 | Technical information | 5 years form the date you cease the usage of our platform |
We will erase, destroy or anonymize your Personal Data when it is no longer necessary or when the period specified above lapses. If we plan to destroy or delete any of your Personal Data, we will inform you in advance.
Your Personal Data and/or information may be transferred to be stored in Server outside Thailand, provided that there will be no other person who can access such information other than us. In most cases, your Personal Data will be processed in the Kingdom of Thailand, where our servers are located and our central database is operated. We will only transfer your information overseas in accordance with Personal Data Protection law.
The exercise of rights listed above may be restricted under relevant laws and it may by necessary for us to deny or not be able to carry out your requests, e.g. to comply with laws or court orders, public tasks, your request in breach of rights or freedom of other persons, etc. If we deny the request, we will inform you of the reason.
Any request made pursuant to the right as described above must be made in writing according to the format we have set. We will use our best effort to take action and clarify within 30 days or not exceeding the period specified by law.
The provisions in this Section only apply if you are a user who is located in the European Union (“EU”). These provisions take precedence over any inconsistent provisions in the remainder of this Privacy Policy.
Portability
You have the right to obtain from us the Personal Data that you have previously provided to us, and which we process based on your consent in a structured, commonly used and machine-readable format and a right to request that we transfer such Personal Data to another party. If you wish for us to transfer the Personal Data to another party, please ensure you detail that party and note that we can only do so where it is technically feasible. We are not responsible for the security of the Personal Data or its processing once received by the third party. We also may not provide you with certain Personal Data if providing it would interfere with another’s rights (e.g. where providing the Personal Data we hold about you would reveal information about another person).
Erasure
You may request that we erase the Personal Data we hold about you in the following circumstances:
Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. However, we may retain the Personal Data if there are valid grounds under law for us to do so (e.g., for the defense of legal claims or freedom of expression) but we will let you know if that is the case. Please note that after deleting the Personal Data, we may not be able to provide the same level of servicing to you as we will not be aware of your preferences.
Retention of Personal Data
We retain your Personal Data as long as needed to provide services or products to you, or as required or permitted by applicable laws, such as tax and accounting laws. If you make a request for erasure of your Personal Data and we determine that there is a valid basis for your request, we will endeavor to erase the Personal Data within 30 days of your request, or inform you if it will take longer.
You have a right to request that we restrict the processing of the Personal Data we hold about you to storage purposes only, where:
Transfer of Personal Data outside the EU
Your Personal Data may be transferred outside of the EU. We take appropriate steps to ensure that recipients of your Personal Data are bound to duties of confidentiality and we implement measures such as appropriate contractual clauses to ensure that the recipients of such transfer protect and treat your Personal Data in accordance with all applicable personal data protection laws.
Information on children
The Services are not intended for children under the age of 16 who are located in the EU. We do not knowingly collect or maintain any personal data or non-personally-identifiable information from anyone under the age of 16 who is located in the EU, nor is any part of our Website, Games or other services directed to children under the age of 16 who are located in the EU. We will close any accounts used exclusively by such children and will remove and/or delete any Personal Data we believe was submitted by any child under the age of 16 who is located in the EU.
We and our business partners may send marketing, advertising and promotional information through website notification, post, phone call, email and/or other messaging applications (“Marketing Media”) to you and/or your parents, guardians or legal representatives. In the event that you agree to subscribe in a contract list and/or accept to receive marketing and promotional media from us, you may opt-out of sending of such media in accordance with the format and channels that we set at any time. We would like to inform you that if you choose not to receive such media, we will still be able to send messages that are not marketing and promotional related to you.
In case Translucia have done any amendments/ changes to its Privacy Policy, Translucia will announce the changes on this page. Please occasionally revisit and read content on this page for an update of changes to our Privacy Policy. In case of material changes, we will notify you of the changes as soon as possible.
If you have any inquiries about our Privacy Policy or wish to exercise your rights under this Privacy Policy or send any complaint regarding processing of your Personal Data by us, please contact us at [email] or Tel […] or our head office address: [No.101, True Digital Park Building, 4th Floor, Room No. 408, Sukhumvit Road, Bang Chak Sub-district, Phra Khanong District, Bangkok].