Sukhothai Management and Services Company Limited (the "Company", we or us), operator of s.management and sms-exec.com, (the “Website“) is committed to protecting and respecting your privacy.
This Policy describes how we collect, use, process, and disclose your information, including personal information, in conjunction with your access to the Website. Please read it carefully. This Policy may, at any time, be altered by us and periodically visit on this Website and Policy is recommended.
Proceeding to use this Website indicates that you accept terms set out in this Policy.
1. Information We Collected
1.1 You may provide us with information in several ways, including by filling in forms on the Website or correspondences with us. This includes information you provide when you register for an account or subscribe, contact estate agents or developers using forms or phone numbers available on the Website.
1.2 We may combine this information with other information you have provided to us or which we have received from other sources.
Information provided by you to us
Your access to and use of the Service is conditioned upon your acceptance of and compliance with these Terms. These Terms apply to all visitors, users and others who wish to access or use the Service.
1.3 We ask for and collect the following personal information about you when you use the Website. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.
(a) Account Information. When you sign up for an account on the Website, we require certain information such as your first name, last name, email address, and date of birth;
(b) Profile and Listing Information. To use certain features of the Website (such as creating a listing or searching for property), we may ask you to provide additional information, which may include your address, phone number, and a profile picture;
(c) Credentials. We collect passwords, password hints, and similar security information used for authentication and account access;
(d) Identity Verification. We may collect identity verification information (such as images of your government issued ID, passport, national ID card, or driving license, as permitted by applicable laws) or other authentication information for the purpose verification of identity; and
(e) Communications with the Website and other users. When you communicate with us or use the the platform in the Website to communicate with other users, we collect information about your communication and any information you choose to provide.
1.4 This information may include any information you add to your profile (for example, your name, address, email address, phone number, profile picture and user name), including without limitation to the followings:
(a)information relating to any transactions carried out by you on or in relation to the Website;
(b) information that you provide to us for the purpose of subscribing to the Website, the Service, email notifications and/or newsletters.
(c) any other information that you choose to send to us.
Information provided by you to us
1.5 When you use the Website, we automatically collect information, including personal information, about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Website.
1.6 The above information may include, without limitation, information about your computer and about your visits to and use of the Website, including without limitation IP address, geographical location, browser type, referral source, length of visit and number of page views.
Information provided by you to us
1.7 We may collect information, including personal information, that others provide about you when they use the Website, or obtain information from other sources and combine that with information we collect through the Website. We do not control, supervise or respond for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.
2. Usage of Information
2.1 We use personal information collected for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests in order to enter into or perform a contract with you (“Contractual”), with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below:
We use the information we collect or receive:
Providing our Services and development of the Website
(a) Providing you with the information and the Service;
(b) Administering promotions or marketing campaign;
(c) Allowing you to participate in our interactive features;
(d) Operate, protect, improve, and optimize the Website and experience, such as by performing analytics and conducting research;
(e) Provide customer service; and
(f) Send you service or support messages, updates, security alerts, and account notifications.
(g) Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Website.
Marketing and Advertising
(h) Providing you and others with information about goods and services that we and selected third parties offer that may be of your interests interest you or them, which may be based on inferences and your activity on the Website;
(i) Customising or enhancing your experience of the Service, which may use inferences about your likely interests based on your activity on the Website;
(j) Delivering relevant advertising to you on websites the Website or third parties or in direct communications from us;
(k) Measuring and understanding the effectiveness of advertising served;
(l) Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about the Website or partner campaigns and services) and social media advertising through social media platforms.
Service improvement and account management
(m) Ensure the most efficient and efficient presentation of our content;
(n) Administering our Website (including without limitation, troubleshooting, data analysis, testing, research, statistical and survey purposes);
(o) Protecting our interests and those of third parties and as part of our efforts to keep our services safe and secure;
(p) Managing and operating your account;
(q) Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity;
(r) Conduct security investigations and risk assessments;
(s) Conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent where required;
(t) Comply with our legal obligations;
(u) Enforce our terms and conditions of Service and other policies.
3. Sharing and Disclosure of Information
3.1 We share your information, including personal information, pursuant to consent given by you, such as when you authorize a third-party application or websites to access your account in the Website or when you participate in promotional activities conducted by us, our partners or third parties.
3.2 We may also share your personal information with third parties in the following circumstances:
(b) Our service providers We may provide your personal information to our business partners, suppliers and subcontractors who provide services to us or where necessary to perform the Service;
(c) Advertising We may provide your personal information to our partner advertisers and advertising networks that require that information to select and serve relevant adverts to you and others; and
(d) Analytics and Search Engines We may provide information about your visit to analytics and search engine providers to help us improve and optimize the Service.
3.4 Aggregated Data. We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
3.5 Professional Advice and Legal Obligation. We may disclose your personal information to as to seeking professional advices in respect of our business/services (for example, from legal advisors or financial advisors). We may also disclose your personal information under our obligations pursuant to relevant legislations, regulations or order of competent authority under the applicable jurisdictions. We may disclose your personal information to enforce our agreements with you or to protect the rights, property or safety of the Website, its users or others. This includes sharing personal information with other organisations for fraud prevention purposes.
4.2 You may refuse to accept cookies by altering the settings on your internet browser. Please note that if you adjust your internet browser settings to refuse the setting of cookies, you may not be able to access or use fully certain parts or functionality of the Website.
5. Opting Out of Collection of Information by Third Parties
6. Transfer of your Information Internationally
Our servers are located in Singapore. If you are accessing our Website from Singapore, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see "Sharing and Disclosure of Information" above), Singapore and other countries.
European Commission's Standard Contractual Clauses: Such measures implementing the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers, which require all such recipients to protect personal information that they process from the EEA in accordance with European data protection laws. We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request
7. Our Disclaimer on Third-party Websites
We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our Website.
8. Information Retention Period
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible
9. Information Safety
We aim to protect your personal information through a system of organizational and technical security measures.
10. Your Rights
10.1 You may exercise any of the rights described in this section before an applicable data controller by updating your preferences in your account. If you cannot fulfil your request using these tools, please email [email@example.com] or contact us using the address below.
10.2 In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure, (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please contact us using the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
Managing Your Information
10.3 We will handle your request in accordance with the law. This means there may be legal reasons why we cannot fulfil all requests.
10.4 You may access and update some of your information through your Account settings. If you have chosen to connect your Account to a third-party application, like Facebook or Google, you can change your settings and remove permission for the Websites by changing your Account settings. You are responsible for keeping your personal information up-to-date.
10.5 You have the right to ask us to correct inaccurate or incomplete personal information concerning you.
10.6 You may at any time review or change the information in your account by:
(a) Logging into your account settings and updating your account
(b) Contacting us using the contact information provided below
10.7 You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. You can also opt-out by:
(a) Noting your preferences at the time you register your account with the Website.
(b) Logging into your account settings and updating your preferences.
(c) Contacting us using the contact information provided below
10.8 We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide the Website to you, you can request that we erase your personal information and close your account (see “Information Retention Period” above).
Please note that if you request the erasure of your personal information:
(a) We may retain some of your personal information as necessary for our legitimate business interests, e.g. fraud prevention and safety; and
(b) We may retain and use your personal information to the extent necessary to comply with legal obligations under competent legislative regimes.
Withdrawing Consent and Restrictions
10.9 You may withdraw your consent at any time by changing your account settings or by sending a communication to the Company specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the legality and activities process of information provided by you during the period prior to withdrawal of consent.
10.10 Where your personal information is processed for direct marketing purposes, you may, at any time ask the Company to cease processing your data for these direct marketing purposes by sending an e-mail to firstname.lastname@example.org
California Do Not Track Disclosure
11. Updates to the Policy
12. Contact us
Post: Data Protection Manager, Sukhothai Management and Services Company Limited