Overview
We provide an overview of our Privacy Policy here. You can find more information through the link “Details” for each item. For your comprehensive understanding of our practices with respect to your information, please refer to the details set out in this Privacy Policy. All capitalized terms are as defined in this Privacy Policy.

Who are we?

We are Break Field (Thailand) Co., Ltd., a corporation having its registered office at 952 Ramaland Building 13Fl., Rama 4 Road, Suriyawongse, Bangrak, Bangkok 10500 Thailand. We are acting as a Data Controller for any information collected through our services including our website (“Website”).

What information do we collect about you?

We collect the following type of information about you:

• Information which you choose to provide to us through our service including the Website
• Information collected as you use our service and the Website
• Information provided from third parties

Why do we collect this information?

We collect and use this information to:

• maintain and improve the Website, like tracking system failure and troubleshooting, improving the functions of our service and the Website
• provide personalized services, like providing recommendations, personalized content based on your activity on the Website.
• develop new products or services, like developing a new function of our services or new services based on your usage activity on the Website or inquiry from you.
• provide ads, like showing ads of our or advertisers’ new products or services which you might be interested in.
• measure and analyze performance, like measuring and analyzing your visits to and activity on the Website and optimizing our services and the Website based on such data
• communicate with you, like notifying you of amendments our service or the Website, responding to inquiries from you
• protect Us, our users, and the public, like detecting, preventing, and responding to fraud, abuse, security risks, and technical issues that could harm Us, you, other users, or the public, investigating or addressing claims or disputes relating to our services and the Website
• comply with a law to which we are subject
• prepare historical documents or archives for public interest, or to research or statistics

Some information is necessary to be provided for compliance with laws, or conclusion of contract with us, or performing a contractual obligation with us. If you do not provide such information, we may not be able to provide our services or the Website to you completely.

Who is this information shared with?

Your information is shared with:

• Our Affiliates
• Our Partners
• third-party service providers performing services to help our operations, such as customer support, technical support, or customer management
• third-party IT service providers, such as provider of data storage service or business communication platform service
• third-party advertising service providers

How long will we retain your information?

We will retain your Personal Data until it is no longer necessary to fulfill the purposes of collecting your Personal Data, or until you request us to erase, destroy, or anonymize your Personal Data. We may be required to retain certain information in order to comply with the laws which we are subjected to.

What are your rights with respect to your Personal Data?

Regarding your Personal Data which we collect and retain, you have the rights to:

• request access to and obtain copy of your Personal Data
• receive your Personal Data or request us to send or transfer your Personal Data to other Data Controllers by the automatic means
• object to the collection, use, or disclosure of your Personal Data
• request to erase, destroy, or anonymize your Personal Data
• request to restrict the use of your Personal Data
• request correction or update of your Personal Data
• withdraw the consent which you have given to us
• complain to expert committee with respect to our processing of Personal Data

Contact us

You may contact us through our Data Controller.

1. Introduction

   This Privacy Policy describes how we collect, use, disclose, share, store, and transfer (collectively, “process”) information about you when you use our service including our website https://cashing-field-thailand.com/, (“the Website”). We act as a Data Controller for any information collected through the Website.

   1. Who are we?

      We are Break Field (Thailand) Co., Ltd., a corporation having its registered office at 952 Ramaland Building 13Fl., Rama 4 Road, Suriyawongse, Bangrak, Bangkok 10500 Thailand.

      We have the following affiliate companies (“Our Affiliates”):

      – Break Field Co.,Ltd. a corporation having its registered office at Ichibanchokowa 4Fl., 7-1 Ichibancho, Chiyoda-ku, Tokyo, Japan

      – Break Field (Vietnam) Co.,Ltd., a corporation having its registered office at PhuongTower 4Fl., 31C Ly Tu Trong, Dist.1, HCM City, Vietnam

      During the course of our business, we have made business alliances with several partner companies (“Our Partners”):

      – Promise (Thailand) Co., Ltd, a corporation having its registered office at 87/1 Capital Tower, All Seasons Place, Wireless Road, Lumpini, Phatumwan, Bangkok 10330

      – AIRA & AIFUL Public Company Limited, a corporation having its registered office at No.90 CW Tower, 33rd, 34th Floor, unit B3301-2, B3401-2, Ratchadapisek Road, Huai Khwang Sub-district, Huai Khwang District, Bangkok 10310

      – Interspace (Thailand) Co., Ltd., a corporation having its registered office at 591 UBC II Building, 22nd Floor, Room 2205 Sukhumvit Road, North Klongton, Wattana Bangkok 10110

   2. What is Personal Data?

      In this Policy, “Personal Data” means information relating to a natural person, which is identified or identifiable, whether directly or indirectly, but excluding information of deceased natural persons. Please note that at all times we will adhere to the applicable statutory definition in determining what information is and is not Personal Data for the purposes of this Privacy Policy.

   3. Scope of this Privacy Policy

      This Privacy Policy applies to information, including Personal Data, which we collect in relation to your access or use of our service including the Website only. Regarding any information which you provide to or is collected by any third party other than us, please refer to the privacy policy separately established by such third party.

   4. Changes to this Privacy Policy

      We will amend this Privacy Policy from time to time. We will notify you of the amendment of this Privacy Policy through the Website or other measures determined by us if we make any substantive or material amendments. Any amendment will become effective upon our posting of the amended privacy policy on the Website.

2. What information do we collect about you?

   We collect the following information about you:

   1. Information which you choose to provide to us through the Website
      • Contact Information: such as name, mailing address, phone number, email address, identification information (such as ID number, driver’s license number), date of birth, gender, and photo
      • Financial information: such as income information, expense information, salary, wages, bank account information, cash card information and credit card information.
      • Information of Communication with us: such as information about the communications between you and us, including your inquiry, compliments, and other contacts to us.
      • Sensitive Personal Information: you may choose to provide us through the Website with your information of a sensitive nature such as racial, ethnic origin, political opinions, cult, religious or philosophical beliefs, sexual behavior, criminal records, health data, disability, trade union information, genetic data, biometric data, or any other information of a sensitive nature. We do not collect and use this information without explicit consent from you, except where permitted by applicable laws.
   2. Information collected when you use the Website
      • Usage Information: such as access dates and times, pages viewed, apps and other system activity, and type of browser. In some cases, we collect this information through cookies, beacons, tags, and similar technologies that create and maintain unique identifiers.
      • Device Information: such as information about the devices you use to access the Website, including the hardware models, device IP address, operating systems and versions, software, file names and versions, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion information, and mobile network information.
      • Communication Information: such as information about the communications between you and us or other users or third party through our service and the Website, such as texts, profiles, messages, photographs, graphics, images, icons, voice, video, and other information contents
      • Location Information: such as your precise or approximate location information as determined through data such as GPS, IP address, and WiFi. You may use the Website without enabling us to collect your Location Information.
      • Transaction Information: such as transaction details related to your use of our service and the Website, including the type of services you requested or provided, your order details, delivery information, date and time the service was provided, amount charged, and payment method.
   3. Information provided from third parties
      • We may collect information about you including your Personal Data from third parties with your consent. For example, we may collect and use information about your usage activities on third-party’s services from marketing service providers.
      • In the event that we collect your Personal Data from a third party, we will notify you of the detail of the collected Personal Data and the detail of the third party. Such notification will be made within 30 days from the date of the collection.
3. Why do we process your Personal Data?
   1. We process your Personal Data for the following purposes, to the extent applicable.
      • To provide our service
        We process your Personal Data for providing you with our services. For example, we collect your name, email address, financial information and other information to evaluate and provide you with information regarding the product suitable to you.
      • To maintain and improve our service and the Website
        We process your Personal Data for maintaining or improving our service and the Website. For example, we collect and use the information of trouble informed by you for tracking system failure and troubleshooting, or we collect and use your usage activity on the Website for improving the functions of our service and the Website or develop more convenient for users.
      • To provide personalized services
        We process your Personal Data for providing you with personalized services. For example, we provide recommendations or personalized content based on your activity on the Website.
      • To develop new products or services
        We process your Personal Data for developing new products or services. For example, we collect and utilize information of how you use our service and the Website, inquiry from you, or questionnaire results for developing new products or services.
      • To provide ads
        We process your Personal Data for showing advertisings. We may also show you personalized ads based on your interests. For example, we collect information of your browsing of other website and utilize it for showing advertisements which you might be interested in. You can control what information we use to show you ads in the settings.
        – We don’t show you personalized ads based on Sensitive Personal Information.
        – We don’t share information that personally identifies you with advertisers, such as your name or email, unless you ask us to.
      • To measure and analyze performance
        We process your Personal Data for analyzing and measuring how our service and the Website are used. For example, we measure and analyze your visits to and activity on the Website for optimizing our service and the Website. We also use information of which ads you interact with for helping advertisers understand the performance or effectiveness of their ads.
      • To communicate with you
        We process your Personal Data to communicate with you. For example, we respond to inquiries from you or may send you a notification about our services or the Website by using your contact information, such as your email address. In addition, if you contact us, we will keep a record of your request in order to help solve any issues you might be facing.
      • To protect us, our users, and the public
        We may process your Personal Data to protect us, you or other users, or the public interest. For example, we use your information for detecting and preventing fraud, abuse, or security risks. We may also use your Personal Data to investigate or address claims or disputes relating to our services or the Website.
      • Other Purposes
        We may process User Information for the purposes prescribed in 5. below.
   2. If you do not provide us with your Personal Data which is necessary for complying with laws or performing the contract between you and us or entering into such contract (e.g., the information required to be entered by you on the user registration screen or on the order screen for a transaction through the Website), your application for use of our service may not be accepted, or you may not be allowed to use part of our services or the Website.
4. Disclosure, Share, or Transfer of Personal Data
   1. We may share your Personal Data with the following categories of recipients:
      • Our Affiliates
      • Our Partners
      • third-party service providers performing functions or services on our behalf, such as customer support, technical support, or customer management
      • third-party IT service providers, such as provider of data storage service or business communication platform service
      • third-party advertising service providers
   2. Except for the recipients prescribed above, we will not disclose your Personal Data to any third party without your prior consent, except where we collected your Personal Data based on any of the legal basis prescribed in Article 5 below.
   3. We transfer your Personal Data to any of our Affiliates, our Partner or third-party service providers outside of Thailand. When we transfer it to such entities outside of Thailand, we ensure you that appropriate safeguards and protections are taken in place pursuant to applicable laws. However, please acknowledge that some countries that we transfer your Personal Data might not have appropriate safeguards and protections under the applicable laws of Thailand.
5. The legal basis on which we process Personal Data

   We process your Personal Data based on a different legal basis depending on the nature of Personal Data and the type of processing involved. We rely on the following legal basis (single or multiple) other than or in addition to your consent, insofar as it applies.

   • Performance of a Contract / Entry into a Contract
     Some of Personal Data is processed on the basis that it is necessary for the performance of our agreement with you or for taking steps at your request prior to entering such an agreement. For example, we may request you to provide your email address, phone number or other contact information in order to perform our obligation under service agreement with you.
   • Legitimate Interests
     A second ground relied upon by us is that it is necessary for the purposes of legitimate interests pursued by us or a third party. These legitimate interests include the operation of our service and the Website, our services and our business, maintenance and improvement of our services and the Website, pursuit of the safety of our services and the Website, such as fraud detection and prevention, charging the payment regarding the chargeable services, providing ads of our services or products or ads of third-party’s services or products, provision of our advertising services to our clients as required by our agreements with them. Further examples are shown in Article 3. above. We only rely on such a ground where such interests are not overridden by your interests or fundamental rights and freedoms.
   • Research or Statistics / Preparation of Historical Documents or Archives for Public Interest
     A third ground relied upon by us is that it is necessary for research or statistics, or preparation of historical documents or archives for the public interest. For example, we may create statistics relating to the business area to which our services belong for the purpose of our own or third-party’s marketing. We only rely on such a ground where the suitable measures to safeguard your rights and freedoms are taken in place and in accordance with applicable law.
   • Compliance with the laws
     A fourth ground relied upon by us is that it is necessary for compliance with legal obligations. For example, we are required to retain records for fixed periods of time in order to comply with applicable laws.
   • Prevention of danger / performance of a task for Public Interest
     In some rare cases, it may be necessary to prevent or suppress a danger to your or other persons’ life, body, or health, or we may need to perform a task for the public interest using your Personal Data.
6. What do we do to keep your Personal Data secure?

   We seek to take reasonable security measures to protect your Personal Data against loss, misuse, alteration, and divulgation. Such reasonable security measures include use of adequate security software, restricted access, and assigning a person in charge of managing Personal Data.

   However, please note that although we take appropriate steps to protect your Personal Data, no website, product, device, online application or transmission of information, computer system or wireless connection is completely secured and therefore we cannot guarantee the security of your Personal Data.

7. How long do we retain your Personal Data?

   We retain your Personal Data until it is no longer necessary to fulfill the purposes of processing your Personal Data, or until you request us to erase or destroy your Personal Data. We may be required to retain certain information in order to comply with the laws to which we are subjected to.

   Specific retention periods are determined based on the following considerations: purposes of processing, the nature of Personal Data, and the necessity of retaining Personal Data for legal or business reasons. For example, if you are a visitor of the Website, we will normally erase your Personal Data within [1] months after the date you last visited the Website; however, we may be required to retain the whole of part of your Personal Data for the purpose of establishment, compliance, or exercise of legal claims, defense of legal claims, or the purpose of compliance with the law.

8. What are your rights regarding your Personal Data?

   Regarding your Personal Data which we collect and store, you have the rights to:

   • request access to and obtain a copy of your Personal Data
   • receive your Personal Data or request us to send or transfer your Personal Data to other Data Controllers by the automatic means
   • object to the collection, use, or disclosure of your Personal Data
   • request to erase, destroy, or anonymize your Personal Data
   • request to restrict the use of your Personal Data
   • request correction or update of your Personal Data
   • withdraw the consent which you have given to us, except where there is a restriction by law or the contract which gives benefits to you (provided, your withdrawal of consent will not affect the lawfulness of procession made prior to such withdrawal)
   • complain to the expert committee with respect to our processing of your Personal Data. If you are not satisfied with how we process your Personal Data, you may contact us through the Contact Details below.
9. Contact Details

   If you have any questions regarding this Policy, please contact us through the contacts set out below.

   Break Field (Thailand) Co., Ltd.
   952 Ramaland Building 13Fl., Rama 4 Road, Suriyawongse, Bangrak, Bangkok 10500 Thailand
   phakphoom@breakfield.co.th

   Data Protection Officer
   Sale Representative
   952 Ramaland Building 13Fl., Rama 4 Road, Suriyawongse, Bangrak, Bangkok 10500 Thailand
   phakphoom@breakfield.co.th
   02-235-6323

   Established on 30th May 2022
   Latest Amendment on 31st May 2022