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Skyfrog Co., Ltd.

Privacy Policy

Privacy Policy / Privacy Notice for the website

of

Skyfrog Co., Ltd. (“Skyfrog”)

Revision 4

Updated: 28 March 2023

Skyfrog Co., Ltd. (“Skyfrog”) respects the privacy of its users' personal data and applies the strictest standards of security and confidentiality, particularly in relation to all personal data that users provide to Skyfrog through the website https://www.skyfrog.net (the “Skyfrog website” or the “website”). Skyfrog wishes to advise users that this Privacy Notice (the “Notice”) is of the greatest importance, and asks that users, as data subjects, read it carefully in order to understand Skyfrog's policy and practice — as data controller — in collecting, using and disclosing (“processing”) users' personal data, along with the rights that data subjects hold in their personal data. This Notice applies to users of the website and to other online activities carried out through the Skyfrog website.

  1. Definitions

In this Privacy Notice, the following terms have the meanings given in this clause unless the context requires otherwise.

“Personal data” means information relating to a person that enables that person to be identified, whether directly or indirectly, but does not include the information of a deceased person in particular.

“Sensitive personal data” means personal data as defined in section 26 of the Personal Data Protection Act B.E. 2562, including personal data concerning racial or ethnic origin, political opinions, cult, religious or philosophical beliefs, sexual behaviour, criminal records, health data, disability, trade union information, genetic data, biometric data, or any other data which affects the data subject in a similar manner as prescribed by the Personal Data Protection Committee.

“Website” means the website https://www.skyfrog.net.

“PDPA” means the Personal Data Protection Act B.E. 2562, together with the rules, regulations and other subordinate legislation issued under the authority of that Act.

“Personal data law” means the PDPA and any other applicable law relating to the protection of personal data that is in force.

“The Committee” means the Personal Data Protection Committee, together with the officers and regulatory bodies concerned with the protection of personal data in Thailand.

  1. Collection of personal data

In providing the website, Skyfrog collects your personal data as follows.

  • Information about your access to and visits to the website, the pages you have viewed and the searches you have made on the site, together with “cookies”, IP address, browser type and version, referring/exit pages, operating system, date/time stamp and clickstream data recorded in log files (“personal data collected automatically”).
  • Where you provide contact information, exercise your rights as a data subject, or take part in other online activities through the website, Skyfrog collects, in addition to the personal data described in clause 2.1 above, personal data that identifies you, including your first name, surname and email address.
  1. Cookies and log files
  • Most web browsers accept cookies automatically. You may, however, choose to accept or refuse cookies by changing your browser settings. Disabling cookies, or refusing them in whole or in part, may prevent you from reaching or using services on our website effectively, or may limit your use of the site.
  • The website https://www.skyfrog.net uses only cookies that are necessary and essential to the operation of the site, and cookies that remember settings in order to tailor content to the intended audience. It does not collect users' personal data, analytics or performance data, or data for advertising or for presenting products and services.
  • Skyfrog does not link the personal data collected automatically as described above with any other personal data of yours, and will not disclose that data.

The Skyfrog website collects and uses strictly necessary cookies on the lawful bases of performance of a contract and legitimate interest, retaining them for no more than 1 day. It also collects and uses functionality cookies on the lawful basis of consent, retaining them for 5 months. For details of the cookies used on the website and their retention periods, please see the Cookie Policy for this website.

  1. Purposes of processing and lawful bases for processing personal data

Skyfrog's purposes in processing data on the website, including personal data, and the lawful bases relied on for that processing, are as follows.

  • Skyfrog relies on performance of a contract and on legitimate interest in collecting and using cookie data for the purposes of providing the website and keeping it secure.
  • Skyfrog relies on consent in collecting and using cookie data that remembers settings in order to tailor content to the intended audience.
  • Skyfrog relies on consent and on performance of a contract in collecting and using personal data provided for contact purposes and in requests by data subjects to exercise their rights.
  1. Disclosure and transfer of personal data

It is not Skyfrog's policy to disclose or transfer website users' personal data for business or marketing purposes. Skyfrog may, however, disclose and/or transfer such data to third parties in the following circumstances.

  • Third parties providing services to Skyfrog, including but not limited to providers of data analysis and data storage, cloud providers, IT maintenance providers, auditors, accounting and audit providers, legal advisers, marketing providers, event organisers, other service and product providers used by Skyfrog, and electronic payment providers — for the processing purposes set out above.
  • Government agencies, or officers of government agencies, empowered by law to order the disclosure of personal data, including in compliance with judicial proceedings, a court order or other legal process.
  1. Security
  • The security of users' personal data matters to Skyfrog. Skyfrog applies appropriate measures, no lower than the standards set by the PDPA — including electronic measures and personal data management measures — to protect users' personal data against loss and against unauthorised or unlawful access, use, alteration, amendment or disclosure.
  • All personal data you enter into Skyfrog's systems is accessible only to Skyfrog personnel with a relevant duty who have been authorised to access it, or to third parties authorised by Skyfrog to do so, and solely for the purposes set out in this policy. Skyfrog takes steps to ensure that those persons comply with the requirements of this Notice, with Skyfrog's privacy policy and with applicable personal data protection law.
  • Skyfrog follows certified industry standards for protecting personal data, both while data is in transit and once Skyfrog has received it. No method of transmitting data over the internet or storing it electronically is, however, perfectly secure. Accordingly, although Skyfrog makes every effort to protect users' personal data against unauthorised or unlawful access, it cannot guarantee perfect security.
  1. Retention of personal data and retention periods
  • Skyfrog retains your personal data securely within its systems only for as long as is necessary to fulfil the purposes of processing and storing that data, as set out under “Purposes of processing and lawful bases for processing personal data” above.
  • Skyfrog may retain users' personal data where doing so is necessary for compliance with the law or for Skyfrog's legitimate interests — for example, to resolve disputes between users, or to prevent fraud and abuse.
  1. Rights in personal data

As a data subject, you have the following rights.

  • Right of access. You have the right to request access to your personal data, to obtain a copy of the personal data Skyfrog holds about you, or to request disclosure of how your personal data was obtained where you did not give consent. Where Skyfrog cannot refuse your request, it will act on it without delay and within 30 (thirty) days of receiving it.
  • Right to data portability. You have the right to receive your personal data from Skyfrog in a format that is commonly readable or usable by automated means, and to ask Skyfrog to send or transfer your personal data in that format to another data controller. This applies only to personal data collected on the basis of consent or performance of a contract, or as otherwise prescribed by law.
  • Right to object. You have the right to object to the processing of your personal data at any time in the cases prescribed by law, and in particular where your personal data is processed for direct marketing purposes.
  • Right to erasure, destruction or anonymisation. You have the right to ask Skyfrog to erase or destroy your personal data, or render it anonymous, where: (i) the personal data is no longer necessary for the purposes of processing; (ii) you have withdrawn your consent to the processing and Skyfrog has no legal authority to continue processing it; (iii) you have objected to the processing; or (iv) the processing of your personal data is unlawful.
  • Right to restrict processing. You have the right to ask Skyfrog to suspend the processing of your personal data where: (1) a request by you to have your personal data made accurate, up to date, complete and not misleading is under examination; (2) the data ought to be erased or destroyed but you ask for its use to be restricted instead; (3) the personal data is no longer necessary for the purposes of processing but you need it retained for the establishment, compliance, exercise or defence of legal claims; or (4) a request to exercise your right to object to processing is under examination.
  • Right to rectification. You have the right to have your personal data made accurate, up to date, complete and not misleading. Skyfrog may ask you for documentary evidence to confirm and verify the accuracy of the data you have provided, or of the correction, update or change you are requesting.
  • Right to withdraw consent. Where Skyfrog processes your personal data on the basis of consent, you have the right to withdraw that consent at any time, unless the law provides otherwise. Withdrawal does not affect the processing of personal data to which you lawfully consented before the withdrawal.
  • Right to lodge a complaint. You have the right to lodge a complaint with the Committee or with the authority that regulates personal data protection.

As a data subject, you may exercise your rights in your personal data through the data subject rights request form.

  1. Amendments and updates to this Privacy Notice

Skyfrog reserves the right to add to, amend, change or update this Privacy Notice whenever it considers it necessary, or as required by personal data law or other applicable law. Skyfrog therefore recommends that users review this Privacy Notice from time to time. Where Skyfrog does add to, amend, change or update this Notice, it will do so as personal data law requires, and may notify users, as data subjects, of the addition, amendment, change or update on the website and/or through any other contact channel the user has given to Skyfrog.

  1. How to contact Skyfrog

If you, as a data subject, wish to exercise any of your rights or have any question about this Privacy Notice, please contact Skyfrog's Data Protection Officer by email at dpo@skyfrog.net, by telephone on (662) 692-8731-4, or at the address below. | Personal data breach notification form for external parties

Skyfrog Co., Ltd.

230 CS Tower, 9th Floor, Ratchadaphisek Road

Huai Khwang, Huai Khwang, Bangkok 10310