Smart Easy Solution values your privacy. This Privacy Policy informs you of your choices and our practices regarding personal data you provide to us.

The use of our services may involve collecting, using and disclosing your Information (as defined in the “The Information We Collect and How We Collect It” section below) on our services (including our websites and mobile applications). It is important for you to understand how this happens and how you may control it, so please read this Privacy Policy carefully.

How to Contact Us

If you wish to contact us regarding this Privacy Policy or any privacy-related matters, please contact our Privacy Officer via email at dev.sesolution@gmail.com (Privacy Team) or tel. +668 1494 0329 or via postal mail at 37/26, Moo 4, Klongsam sub-district, Klongluang district, Pathum Thani province, 12120 (attention: Privacy Team, Corporate Affairs Department).

Update to this Policy

This Statement may be subject to updates. Any material future changes or additions to the processing of personal information as described in this Statement affecting you will be communicated to you through an appropriate channel. For example, we may place a prominent notice on a product site or email you to let you know of an updated Statement.

1. THE INFORMATION WE COLLECT AND HOW WE COLLECT IT

In providing our services, we collect, store and use the following Information relating to you:

“Information” is Personal Information and Non-Personal Information;

"Personal Information" is any information or combination of information that relates to you, and can be used to identify you. Personal Information may include the following:

• information you make available to us when you open an account or use our services, such as your name, telephone number, email address and credit card details;
• information which you make available to our services as you use them, including Shared Information you make available to others through our services and information you store using our services;
• shared Information that others using our services make available about you, such as information contained in posts they make and communications they make to you or others using our services;
• online identifier which may be collected with unique identifiers tied to the browser, application, or device you are using. This helps us do things like maintain your language preferences across browsing session; and
• Information we collect as you use our services, such as certain Location Data, Log Data and public information.

““Location Data” is information that we collect regarding your location (when you use a location-enabled service), including:

• the location of your device when you use our services, such as from the GPS, WiFi, compass, accelerometer or other sensors in your device;
• the IP address of the device or internet service you use to access our services,
• other information made available by you or others that gives an indication as to where you are or have been located, such as account information that indicates where you are located and Shared Information you or others post indicating your location, such as any geotag information that is embedded in any photos you make available to us; and
• if you have provided us with your location data previously and would like us to delete such existing location data, you may be able to do so via our services.

"Log Data" is technical information that is automatically collected by us when you use our services, whether through the use of cookies (as explained in more detail in the Cookies Policy ) or otherwise, including:

• technical information such as your mobile carrier, configuration information made available by your web browser or other programs you use to access our services, your IP address as well as your device’s version and serial number.
• information about what you have searched for and looked at while using our services, such as web search terms used, social media profiles visited and details of other information and content accessed or requested by you in using our services;
• information about application and other software you have used and how you have used them;
• information about communications you have made using our services, such as the people you’ve communicated with and the time, data and duration of your communications; and
• metadata, which means information related to items you have made available through our services, such as the date, time or location that a shared photograph or video was taken or posted.

“Non-Personal Information” is any information that relates to you but from which it is not practicable to directly or indirectly identify you, including Personal Information in aggregated, anonymised or pseudonymised form.

“Shared Information” is information about you or relating to you that is voluntarily shared on our services, including postings that you make on our services (including your public profile, the lists you create), any postings from others that you re-post and including Location Data and Log Data associated with these postings. Shared Information also includes information about you (including Location Data and Log Data) that others who are using our services share about you.

2. HOW WE USE YOUR INFORMATION

We may use your Information for any of the following purposes:

• to provide our services to you;
• for customer service, security, fraud-detection, archival and backup purposes in connection with the provision of our services;
• to provide you with advertising (as discussed in more detail under the “Advertising” section below);
• to better understand how you access and use our services, for the purposes of trying to improve our services and to respond to customer desires and preferences, including language and location customisation, personalised help and instructions, or other responses to your and other customers’ usage of our services;
• to help us develop our new services and improve our existing services;
• to assess the effectiveness of and improve advertising and other marketing and promotional activities on or in connection with our services;
• for the purposes of software verification or administering software upgrades; and
• to allow you to participate in surveys and other activities about our products and services.

Please note that for the purposes of seeking to provide our users with a better experience, to improve our services or otherwise where you have consented, Personal Information collected through one of our services may, subject to user privacy controls (where available), be used by our other services (including in an aggregated or individualised manner).

For example, Personal Information collected during your use of one of our services may be used to suggest particular content that can be made available to you on another service or be used to try to present more relevant advertising to you in another service. You may also from time to time ask us to migrate or export your Personal Information contained in one of our services to another of our services, where such migration option is available.

3. YOUR RIGHTS

You may have rights under Thai and other laws to have access to your personal information and to ask us to rectify, erase and restrict use of, your personal information. You may also have rights to object to your personal information being used, to ask for the transfer of personal information you have made available to us and to withdraw consent to the use of your personal information. Further information on how to exercise your rights is set out below.

We will honor your rights under applicable data protection laws. You have the following rights under Thai laws, and may have similar rights under the laws of other countries.

• Right of subject access: The right to make a written request for details of your personal information and a copy of that personal information
• Right to rectification: The right to have inaccurate information about you corrected or removed
• Right to erasure ('right to be forgotten'): The right to have certain personal information about you erased
• Right to restriction of processing: The right to request that your personal information is only used for restricted purposes
• Right to opt out of marketing: You can manage your marketing preferences by unsubscribe links found in the communications you received from us or by visiting the preference setting
• Right to object: The right to object to processing of your personal information in cases where our processing is based on the performance of a task carried out in the public interest or we have let you know the processing is necessary for our or a third party’s legitimate interests. In these circumstances the right to object is not absolute.
• Right to data portability: The right to ask for the personal information you have made available to us to be transferred to you or a third party in machine-readable format
• Right to withdraw consent: The right to withdraw any consent you have previously given us to handle your personal information. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information prior to the withdrawal of your consent

These rights are not absolute and they do not always apply in all cases. In response to a request, we will ask you to verify your identity if we need to, and to provide information that helps us to understand your request better. If we do not comply with your request, whether in whole or in part, we will explain why.

In order to exercise your rights please contact us via contact information as mentioned above.

4. COOKIES

Please review our Cookies Instructions for more information regarding how we use cookies.

5. ADVERTISING AND MARKETING

We deliver marketing and event communications to you across various platforms such as email, telephone, text messaging, direct mail and online. Where required by law, we will ask you to explicitly opt in to receive marketing from us. If we send you a marketing communication it will include instructions on how to opt out of receiving these communications in the future.

Honoring your marketing preferences is important to us. You have the right to opt out of receiving direct marketing and targeted online advertising.

How to Opt Out of Email Marketing

Where we send marketing emails, we provide unsubscribe options for your use within our emails. To update your email marketing preferences, please visit the applicable preference setting, a link to which will normally be included in emails you receive from us. In addition, you can also use the “Contact Us” feature of a particular Service to discuss with us

Even if you opt out of receiving marketing communications by email, we may still send you service communications or important transactional information related to your accounts and subscriptions (for purposes such as providing customer support).

Interest-based advertising (IBA)

Interest-based advertising (IBA) allows us to deliver targeted advertising to users of our Services. IBA works by showing you advertisements, or sending you marketing emails, that are based on the type of content you access or read. For example, as you browse our Services, one of the cookies placed on your device will be an advertising cookie so we can better understand what sort of pages or content you are interested in. The information collected about your device enables us to group you with other devices that have shown similar interests. We can then display advertising to categories of users that is based on common interests. For more information about IBA, please visit: http://www.iab.net/public_policy/behavioral-advertisingprinciples.

Opting out of IBA
If you want to opt out of receiving interest-based advertising, it does not mean that you will no longer receive advertising when you are using our Services. It just means that we will not use your personal information for IBA and that any advertising you see will not be customized to you. You can exercise your online advertising choices at http://optout.aboutads.info or by clicking the AdChoices icon in an ad and following the instructions.  You may also opt out of receiving interest-based ads from many sites through the Network Advertising Initiative's (NAI) Opt Out Tool (http://www.networkadvertising.org/choices) and in the EU at http://www.youronlinechoices.com/ If you delete cookies, use a different device, or change web browsers, you may need to opt out again.

Advertising on mobile devices
Mobile devices have an identifier that gives companies the ability to serve targeted ads to a specific mobile device. In many cases, you can turn off mobile device ad tracking or you can reset the advertising identifier at any time within your mobile device privacy settings. Another tool you can use to control advertising on your mobile device is the AppChoices App: http://youradchoices.com/appchoices

You may also choose to turn off location tracking on your mobile device. If you turn off ad tracking or location tracking, we will no longer use information collected from your device’s advertising identifier for the purposes of advertising. You may still see the same number of ads but they may be less relevant because they will not be based on your interests.  Where we need your consent to gather information about your location we will obtain this from you. 

6. YOUR AD CHOICES

Advertising enables us to provide the rich content for which Services on the Tencent (Thailand) are known, and to provide much of this content free of cost to our Users. Thus, we strive to provide you with ads that are relevant to you and for products you may want.

The tools provided on the AdChoices page, as well as the DAA opt-out page and the NAI opt-out page are provided by third parties, not Tencent (Thailand). Tencent (Thailand) does not control or operate these tools or the choices that advertisers and others provide through these tools.

When using a mobile application you may receive tailored in-application advertisements. Depending on your device, you may be able to reset your mobile device's advertising identifier at any time by accessing the privacy settings on your mobile device. In addition, each operating system, iOS for Apple phones, Android for Android devices and Windows for Microsoft devices, provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt-out of tailored in-application advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact (or review the applicable privacy web page of) the applicable platform operator.

7. SHARING OF YOUR PERSONAL INFORMATION

Other than as permitted under this Privacy Policy or as otherwise consented to by you, we will not transfer your Personal Information to any other third parties for their processing for any purposes. We and our affiliate companies may share your Personal Information within our group of companies and with joint venture partners and third party service providers, contractors and agents (such as communication service providers who send emails or push notifications on our behalf, mapping services providers who assists us and you with location data, analytics partners who assist our business, and advertising partners on our services). In addition, we may allow such third parties to collect your Personal Information across our services. In each case, we permit such sharing and/or collection for the purposes of: (i) providing our services to you; (ii) assisting us in carrying out the purposes set out under the “How We Use Your Information” section above; (iii) carrying out our obligations and enforcing our rights under the Terms of Service or this Privacy Policy; and/or (iv) our business, including helping us better understand and improve our services. These third parties may be accessed, and use and store your Personal Information, outside of your jurisdiction for these purposes.

Where we permit any third parties to collect and use your Personal Information in accordance with the above paragraph, we will use reasonable efforts to ensure that such third parties only use your Personal Information: (i) in compliance with this Privacy Policy; and (ii) subject to any other instructions we give them, including any appropriate confidentiality and security measures that we implement. You consent to the third party use, sharing and transfer of your Personal Information (both inside and outside of your jurisdiction) as described in this "Sharing of your Personal Information" section

As we continue to develop our business, we or our affiliate companies may be acquired by a third party or re-organise our group structure. In these circumstances, it may be the case that your Information is transferred within our group and/or transferred to a third party who will continue to operate our services or similar services under either this Privacy Policy or a different privacy policy which will be notified to you. The party to which your Personal Information is transferred may be located, and use your Information, outside of your jurisdiction.

You agree that we or our affiliate companies may be required to retain, preserve or disclose your Personal Information: (i) in order to comply with applicable laws or regulations; (ii) in order to comply with a court order, subpoena or other legal process; (iii) in response to a request by a government authority, law enforcement agency or similar body (whether situated in your jurisdiction or elsewhere); or (iv) where we believe it is reasonably necessary to comply with applicable laws or regulations. You also agree that we or our affiliate companies may need to disclose your Personal Information in order to enforce the Terms of Service or this Privacy Policy protect our rights, property or safety, or the rights, property or safety of our affiliate companies or other users of our services.

A WORD ABOUT SHARED INFORMATION

A number of our services enable Shared Information to be shared publicly with all users of that service and not just your contacts. Our social media services in particular are primarily designed to help you share Shared Information with the world, so Shared Information can be broadly and instantly transmitted and will remain public for as long as you do not delete it (and even after you delete Shared Information, it may still be separately cached, copied, or stored by, or remain public through, other users or third parties who are not affiliated with and not controlled by us).

Please consider carefully what you post and communicate through our services.

8. COMMUNICATIONS FROM US

Newsletters and other types of communications

When you use our services, we may use your Information to send you emails, newsletters or push notifications to your device. If you no longer wish to receive these communications, you can do so by following the unsubscribe instructions in the emails we send to you, opting out of notifications at the device level (if available) or contacting our Privacy Officer.

Service-related announcements

We may from time to time send you service-related announcements when we consider it necessary to do so (such as when we temporarily suspend one of our services for maintenance). You may not opt-out of these service-related announcements, which are not promotional in nature.

9. A WORD ABOUT SENSITIVE PERSONAL INFORMATION

In some jurisdictions, certain Personal Information, such as information about your race or ethnic origin, religious or philosophical views or personal health, is characterised as “sensitive” and is subject to stricter regulation than other personal information. Please note that content and information that you input to our services, such as photographs or information about your school or social activities, may reveal your sensitive Personal Information to others.

Please note that we do not use your sensitive Personal Information for the purpose of serving advertising to you.

We urge you to consider whether it is appropriate to communicate sensitive Personal within our services.

10. THIRD PARTY SERVICES ON OUR SERVICES

Our services may include, or they may link you to, social media or other services (including websites) provided by a third party. For example:

• you may be able to share content on our services using services provided by third parties. The third parties who provide such services may be able to collect your Information and Personal Information (including your Log Data), and may set cookies on your computer to enable such third party services to function properly; and
• We may (whether in advertisements or otherwise within our services) provide you with links that allow you to access third party services or websites.

These third party social media or other services may be hosted by the relevant third party or us. Your use of any such third party services (whether social media services or otherwise), including any Personal Information you provide to such third parties, are subject to the relevant third party’s own Terms of Services and privacy policies and not the Terms of Service or this Privacy Policy, so please review their terms carefully.

This Privacy Policy only applies to any Information collected by us, does not apply to any services offered by or information practices of any third parties, and we bear no liability for any third party use of any Information provided by you to them.

11. AGE RESTRICTIONS

We do not generally aim our service at any children per local legislationbecause our service needs attentiveness. We do aim our service at people who reach their legal age. In the limited circumstances where we may collect and use personal information about children or any person who are still not the majority, please contact our Privacy Officer and we will promptly investigate (and remove, if we have any) such Personal Information.

12. INTERNATIONAL TRANSFER

This Service is governed by and operated in accordance with Thai law. If you are located outside of Thailand, you use this Service at your own risk. Tencent (Thailand) may be required to transfer your Information internationally. In particular, your Information will be transferred to and processed in the Thailand where many of our central databases operate. By using this Service, you acknowledge that the data protection and other laws of other countries, such as Thailand, may provide a less comprehensive or protective standard of protection than those in your country, and consent to your Information being collected, processed and transferred as set forth in this Privacy Policy and Thai law. We take appropriate steps to ensure that personal information is processed, secured and transferred according to applicable law. In some cases, we may need to disclose or transfer your personal information to headquarter or to third parties in areas outside of your home country.

13. HOW WE SECURE PERSONAL INFORMATION

We have put in place physical, electronic, and managerial procedures designed to help prevent unauthorized access, to maintain data security, and to use correctly the Information we collect online. These safeguards vary based on the sensitivity of the Information that we collect and store.

In some cases, we will use encryption technology (such as SSL) to protect certain sensitive Information provided by you to us.Please be aware that despite our efforts, no data security measures can guarantee 100% security at all times. Our systems and the communications networks through which you access our services may be subject to security breaches and failures which are due to circumstances beyond our reasonable control.

14. RETENTION PERIOD OF PERSONAL INFORMATION

Subject to applicable laws and regulations (including as set out under the “Sharing of your Personal Information” section above), we will only retain your Personal Information for so long as is necessary to fulfill the purposes as set out under the “How We Use Your Information” section above.

We retain your information in accordance with our enterprise records retention schedule. You can find more information on the criteria used to calculate the retention periods set out below.

Tencent (Thailand) has a Records and Information Governance team that works in conjunction with our Privacy Team to implement policies and rules relating to the retention of personal information. We have an enterprise records retention schedule that is based upon a classification scheme consisting of business functions, record classes, and record types.

We calculate retention periods for your personal information in accordance with the following criteria:

1. the length of time necessary to fulfill the purposes we collected it for
2. when you or your employer (or other subscriber providing for your access to our Services) cease to use our Services
3. the length of time it is reasonable to keep records to demonstrate that we have fulfilled our duties and obligations
4. any limitation periods within which claims might be made
5. any retention periods prescribed by law or recommended by regulators, professional bodies or associations
6. the existence of any relevant proceedings

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