1.   Introduction

This Privacy Policy describes how we collect, use, disclose, share, store, and transfer (collectively, “process”) information about you when you use “D-Live”, the services operated and provided by us (“Services”).   We act as a Data Controller for any information collected through the Service.

​

1.1.   Who are we?

We are DAIDO KOGYO CO., LTD., a corporation having its registered office at I-197, Kumasaka-machi, Kaga-shi, Ishikawa, 922-8686, Japan

We have the group companies showing here  (“Group Companies”):

1.2.   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.

1.3.   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 the Services 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.

1.4.   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 Services, or other measures determined by us in case we make any substantive or material amendments.  Any amendment will become effective upon our posting of the amended privacy policy on the[H2]  Services.

​

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 Services

• Profile Information: such as name, mailing address, phone number, email address, login ID, login passwords, identification information (such as ID number, driver’s license number), birth date, gender, photo, and mobility 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 Services 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 such information without explicit consent from you, except where permitted by applicable laws.

​

2)   Information collected as you use the Services

• Usage Information: such as access dates and times, pages screen viewed, activity data on apps. 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 Services, 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

• 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 Services without enabling us to collect your Location Information.  However, this might affect the functionality available on your use of the Services

​

3)   Information provided from third parties

• We may collect information about you to be provided from third parties due to your consent.  For example, we may collect your account information of third-party’s services when you log in to the Services through such account.

 

3.   Why do we process your Personal Data?

3.1.   We process your Personal Data for the following purposes, to the extent applicable.

• To provide the Services

We process your Personal Data to provide you with the Services.  For example, we collect your name, email address, and other information to create your account of the Services, and we use your user ID and password to verify you as a user of the Services.

• To maintain and improve The Services

We process your Personal Data for maintaining or improving the Services.  For example, we collect and use information of trouble informed by you for tracking system failure and troubleshooting, or we collect and use your usage activity on the Services for improving the functions of the Services or develop more convenient for users.

• 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 the Services, inquiry from you, or questionnaire result for developing new products or services.

• To provide ads

We may process your Personal Data for showing advertising.  We may also show you personalized ads based on your interests.

・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 the Services are used.  For example, we measure and analyze your visits to and activity on the Services to optimize them.  We also use information of which ads you interact with to help 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 the Services by using your contact information provided such as 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 account ID and password for detecting, preventing unauthorized use of your account, fraud, abuse, or security risks.   We may also use your Personal Data to investigate or address claims or disputes relating to the[H7]  Services.

​

• Other Purposes

We may process Personal Data for the purposes prescribed in 5. below.

​

3.2.   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), your application for use of the Services may not be accepted, or you may not be allowed to use part of the Services.

​

4.   Disclosure, Share, or Transfer of Personal Data

4.1.   We may share your Personal Data with the following categories of recipients:[L O8]

• service providers who provide vouchers in the Service for the exchange of points your acquires [L O9]

• our Group Companies

• 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 licensors of white-label applications, providers of data storage services or business communication platform services[L O10]

• third-party advertising service providers

4.2.   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 5 below.

4.3.   As we are a Japanese company, we transfer your Personal Data to Japan. In addition, we may transfer your Personal Data to any of our Group Companies or third-party service providers located outside of Thailand such as our data center specified in 6.2.  When we transfer it to such entities outside of Thailand, we ensure that appropriate safeguards and protections are taken in place in accordance with the Binding Corporate Rules (BCRs) or other information transfer agreements pursuant to the applicable laws.

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 bases (single or multiple) other than or in addition to your consent, insofar as it applies.

• Performance of a Contract / Entry into a Contract

Some 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 need to request you to provide your email address, login name, login passwords to create your account for using the Services 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 the Services and our business, maintenance and improvement of the Services, pursuit of the safety of the Services, such as fraud detection and prevention, charging the payment regarding the chargeable services, providing ads of the Services or products or ads of third-party’s services or products.  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 the Services belong for the purpose of our own or third-party’s marketing. We only rely on such a ground where suitable measures to safeguard your rights and freedoms are taken in place and in accordance with applicable law.

• Compliance with a Law

A fourth ground relied upon by us is that it is necessary for compliance with a legal obligation.  For example, we are required to retain records for fixed periods of time in order to comply with applicable laws.

• Prevention of a Danger / Performance of a Task for Public Interest

In some rare cases, there may be necessary for preventing or suppressing a danger to your or other persons’ life, body, or health, or we may need to perform a task for the public interest.

​

6.   What do we do to keep your Personal Data secure?

6.1.   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 secure and therefore we cannot guarantee the security of your Personal Data.

6.2.   We store your Personal Data not only in Thailand but also in our data centers located in Japan and  Singapore.

​

7.   How long do we store 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 subject.

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 user of the Services, we will normally erase your Personal Data within 12 months from the date on which you become no longer a user of the Services; however, we may be necessary to retain the whole of a 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.   Cookies

During any use of the Company's website Information relating to your access to this website will be saved in the form of a cookie.  Cookies are text files that are stored on a user's computer and/or communication devices that you use, such as tablets and smartphones, via a web browser while you enter our website.  Cookies will not cause harm to your computer equipment and/or communication devices.  They are used to store detailed log data, internet usage or your website visit behavior.  You can learn more about cookies here.

We will collect website information from all visitors through cookies or similar technologies and will use cookies for the purpose of improving the efficiency of accessing and using the Services.  The company collects cookies for the following purposes:

• to study the behavior of your website usage and to develop our websites to be able to use easily, quickly and more efficient;

• to enable you to sign in to your account on the Service;

• to protect you from fraud and improve security;

• to analyze products and services, and offers of our products that may be relevant to you;

• to improve the marketing that you see on social media, applications and other websites.

You can refuse the collection of information via cookies through your browser settings, which may reduce the optimum performance of the website and application.

​

9.   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 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.

Especially, if you want to exercise the right to withdraw consent, you can contact us here.  However, the withdrawal of your consent related to and required for the Service may prevent you from complying with the contract or providing services to you or may cause the transaction or any other related activities to be suspended or temporarily discontinued.

​

10.Contact Details

If you have any questions regarding this Policy, please contact us here;[L O16]  or you may also contact us through the following contacts set out below.

DAIDO KOGYO CO., LTD.

I-197, Kumasaka-machi, Kaga-shi, Ishikawa, 922-8686, Japan [Contact]

Established on 22,Dec.2022