80DAYS PHUKET CO., LTD takes issues of privacy and information security very seriously. Protecting users’ personal data is one of our key priorities.
To ensure the protection of users’ rights and freedoms in the field of personal data protection, this Policy has been developed. It explains the legal basis, methods, and purposes of personal data processing.
Introduction1.1. This document defines the policy regarding the protection and processing of users’ personal data (hereinafter referred to as the “Policy”).
1.2. This Policy has been developed in accordance with applicable legislation.
Basic Terms Used in This Policy
Applications — forms for collecting personal data, posted on the website and intended for completion and submission electronically via the website. Applications are presented on the website as questionnaires containing guiding questions related to the personal data subject.
Button — a graphical element of the website, highlighted in color and containing contrasting text that indicates a programmed action to be executed when pressed.
Cookie — text files placed on the computer (or other device) of the personal data subject when visiting the website through a web browser.
Processing of personal data — any action (operation) or set of actions performed with or without the use of automation tools on personal data, including the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
Personal data operator (hereinafter — the “Operator”) — a legal entity that processes personal data and determines the purposes of processing, the composition of personal data subject to processing, and the actions (operations) performed with personal data.
Personal data Operator and Rights Holder — 80DAYS PHUKET CO., LTD, Address:38 Srisoonthorn Rd, Choeng Thale, Thalang District, Phuket 83110, Thailand.
Personal data — any information relating directly or indirectly to an identified or identifiable individual (personal data subject).
Information system user — an employee of the Operator who has been granted access to the personal data of a personal data subject.
Website — a collection of texts, graphic elements, design, images, source code, software, photo and video materials, and other results of intellectual activity available on the Internet.
Personal data subject (also referred to as “User”) — an individual who has accessed the website and filled out an application on any of its pages.
Services — services provided by the Operator, information about which is presented on the website.
Principles of Personal Data Processing3.1. When processing personal data, the Operator adheres to the following principles:
- Personal data processing is carried out with the consent of the personal data subject and continues until it is withdrawn by them. Consent to the processing of personal data is considered received by the Operator at the moment the personal data subject completes registration on the website using the application form available on the website. Registration is deemed complete when the personal data subject, after filling out the application, clicks the button located below (to the right of) the last question in the application form.
- Personal data processing is limited to achieving specific, pre-determined, and lawful purposes. The Operator does not process personal data that are incompatible with the purposes for which they are collected.
- The content and volume of processed personal data correspond to the stated purposes of processing.
- During the processing of personal data, the Operator ensures their accuracy, sufficiency, and, when necessary, relevance to the purposes of processing. The Operator takes necessary measures to delete or correct incomplete or inaccurate data.
- Personal data processed by the Operator shall be destroyed once the purposes of processing are achieved or when they are no longer needed for such purposes.
3.2. The Operator does not verify the accuracy of the personal data provided by the personal data subject when filling out applications on the website, nor does it verify whether the personal data actually belong to the individual who provided them as their own. The Operator assumes that the personal data subject provides their data in their own interest and without intent to violate the rights or legitimate interests of third parties or to cause harm to the Operator.
3.3. The collection, recording, systematization, accumulation, storage, clarification (updating, modification), and retrieval of personal data of personal data subjects are carried out using databases located within the territory of
Thailand.
Information Collected by the Personal Data Operator4.1. The Operator collects, accesses, and uses users’ personal data, as well as technical and other information related to users, for the purposes specified in this Policy.
4.2. Technical information is not personal data; however, the Operator uses cookies that allow the identification of users. Cookies are text files accessible to the Operator for processing information about users’ activity on the Website, Platform, and Personal Account, including data on which pages were visited, the time spent on a page, and the speed of Clients’ engagement with Service Packages. Users can disable the use of cookies in their browser settings.
4.3. Technical information also includes data automatically transmitted to the Operator while using the Website, Platform, and/or Personal Account through the software installed on the user’s device, namely:
4.3.1. Information about the user’s online activity, in particular, visited pages, date and time of URL transitions, etc.;
4.3.2. Information about the device and browser used to access the Internet: IP address and (if accessed from a mobile device) the type of device and its unique identifier;
4.3.3. Data on interactions with the Operator’s advertising materials displayed outside the resource, including their quantity, frequency, and depth of viewing.
4.4. “User’s personal data” refers to information that the user provides to the Operator when accessing the Website, Platform, or Personal Account, during registration and/or authorization, and when using the Website, Platform, Personal Account, Service Packages, or filling out the Application-Questionnaire, including:
4.4.1. Surname, name, patronymic;
4.4.2. Email address;
4.4.3. Contact phone number;
4.4.4. Messaging account identifiers;
4.4.5. Links to profiles (pages) in social networks;
4.4.6. User’s image (photo);
4.4.7. Other information provided by the User to the Operator via the Website, Platform, Application-Questionnaire, Personal Account, and during the provision of Services within Service Packages;
4.4.8. Data transmitted automatically, depending on the software settings of the User, in anonymized form;
4.4.9. The User acknowledges and accepts that third-party software used on the Website, Platform, and/or Personal Account may receive and transmit anonymized data specified in clause 4.4.8.
4.5. The third-party software mentioned includes:
• user geolocation system (city and country) — maxmind.com;
• web analytics system — Google Analytics;
• end-to-end business analytics system — Roistat.
4.6. The composition and conditions for collecting anonymized data using third-party software are determined directly by their rights holders.
4.7. The Operator processes personal data, technical information, and other Client information for the entire duration of the agreement concluded between the Client and the Operator. For other users who are not Clients, the processing of personal data is carried out for the entire period of their use of the Website and other resources of the Operator.
Personal Data5.
1. The processing of the User’s personal data means recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of the User’s personal data that do not fall into special categories requiring the User’s written consent for processing by the Operator, in accordance with applicable legislation.
5.2. The User gives consent to the Operator for the processing of their personal data provided during registration and/or authorization and when using the Website, Platform, or Personal Account, including when filling out the Application-Questionnaire. This also includes consent to transfer such personal data to third parties for the execution of an agreement between the Operator and the Client, as well as for the implementation of partnership programs with such third parties, even when such transfer is carried out outside of Thailand (cross-border transfer).
5.3. The processing of personal data is carried out both with and without the use of automation tools.
5.4. The User’s personal data are processed by the Operator within the territory of Thailand.
5.5. The Operator processes personal data within its information systems relating to the following categories of subjects:
- employees of the Operator;
- Clients (Customers) of the Operator;
- contractors, subcontractors, and other third parties providing services and/or performing work on behalf of the Operator;
- participants in events organized by the Operator;
- subscribers to the Operator’s informational newsletters;
- information partners of the Operator, invited guests, and presenters at events organized by the Operator.
All of the above subjects are hereinafter collectively referred to as “Users.” The term “Clients (Customers)” is used when referring exclusively to clients and not to all Users.
5.6. This Policy applies to all processes related to the collection, recording, systematization, accumulation, storage, clarification, retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data, whether automated or not.
5.7. The use of the Website, Bitrix24 Platforms, Service Packages, or other resources of the Operator signifies the User’s unconditional consent to this Policy and the specified conditions of personal data processing. The User may also express consent to this Policy by subscribing to the Operator’s newsletters or by providing written consent for processing to the Operator.
Purposes of Personal Data Processing6.1. The information provided by the User is used by the Operator solely for the following purposes:
6.1.1. Fulfilling the Operator’s obligations to the Client under the Agreement regarding the use of the Website, Platform, Personal Account, Materials, or other intellectual property within the provision of Services;
6.1.2. Establishing and maintaining communication with the User;
6.1.3. Sending informational or other types of messages to the User’s email address;
6.1.4. Improving service quality and modernizing the Website, Platform, and Personal Account;
6.1.5. Registering the User on the Website, Platform, or Personal Account and managing the User’s account;
6.1.6. Administration of justice in cases where the Operator receives a corresponding request from authorized bodies;
6.1.7. Implementation of partnership programs with third parties;
6.1.8. Compliance with the laws in force in the territory of Thailand.
6.2. The Operator does not verify the accuracy or legal capacity of the personal data provided by Users.
6.3. The personal data of a personal data subject are processed for the following purposes:
- to make a phone call or send an email to clarify the subject’s intention to purchase the Operator’s services, as described on the website;
- to conclude an agreement with the subject for the provision of services by the Operator, including issuing invoices, sending notifications, and information related to the provision of services;
- to process requests and applications received by the Operator;
- to send informational newsletters to the subject on topics related to recruitment and personnel selection;
- to develop and adjust the Operator’s marketing strategy based on the preferences of personal data subjects, depending on their location and professional position.
Composition of Processed Personal Data7.1. The composition of personal data processed by the Operator (which may vary depending on the application) includes:
- Surname, first name, patronymic;
- Email address;
- Contact phone number;
- Messaging account identifiers;
- Links to social media profiles (pages);
- User’s image (photograph);
- Other information provided by the User to the Operator via the Website, Platform, Application-Questionnaire, or Personal Account, and during the provision of Services under Service Packages.
Rights of the Personal Data Operator8.1. The Operator has the right to conduct statistical and other research based on anonymized personal data provided by the User. The Operator has the right to grant access to such research to third parties for advertising targeting purposes. The User gives their consent to such research and the receipt of targeted advertising by accepting this Policy. The User may withdraw this consent at any time by contacting the Operator at the address specified on the relevant page of the Website.
8.2. The Operator has the right to provide information about Users to law enforcement or other government authorities within judicial proceedings, investigations, or based on a court order, compulsory request, or in other cases provided for by the laws applicable in the territory of Thailand.
8.3. The Operator has the right to provide information about Users to third parties for the purpose of detecting and preventing fraudulent activities, resolving technical issues, or addressing security problems.
8.4. The Operator has the right to grant access to Users’ personal data to third parties, including other Users of the Website and Platform, as well as participants of webinars, online, and offline events held by the Operator, if such transfer is necessary for the Operator to fulfill its obligations under agreements concluded with the Client.
8.5. The Operator has the right to determine the scope of personal information required from the User for the use of the Website, Platform, and/or Personal Account. If certain information is not marked as mandatory by the Operator, its provision or disclosure is at the User’s discretion.
8.6. The Operator stores personal data no longer than necessary to achieve the purposes of processing. The storage period may be established by law or specified in the consent given by the data subject. After the storage period expires, personal data are subject to destruction or anonymization.
8.7. In accordance with predefined purposes and legal requirements, the Operator may transfer personal data to the following categories of third parties:
- subsidiaries and companies within the Operator’s corporate group;
- external contractors;
- governmental or other authorities for the purpose of fulfilling legal obligations.
8.8. Cross-border transfer of personal data to foreign countries that do not provide an adequate level of protection for the rights of personal data subjects is carried out strictly with the subject’s consent and/or for the execution of a contract and/or for compliance with legal obligations.
8.9. For the transfer of personal data obtained from the EU to third parties located in countries that do not ensure an adequate level of personal data protection as defined by the GDPR, the Operator concludes agreements containing “Standard Contractual Clauses” (SCC) adopted by the European Commission or a supervisory authority and approved by the European Commission, which guarantee the protection of data subjects’ rights and freedoms.
User Rights (Data Subject Rights)9.1. Every data subject whose personal data are processed by the Operator has the following rights:
9.2. By posting information about themselves on the Website, Platform, in the Application-Questionnaire, or in the Personal Account, the User may make this information publicly available. The User understands that such information may be indexed by search engines and accepts the related risks of disclosing information pertaining to personal, family, or other private matters.
9.3. The User may delete or modify the information they have provided at any time by taking the necessary actions on the Website, Platform, or in the Personal Account, or, if such functionality is unavailable, by contacting the Operator at the following email address:
quicknclear.media@gmail.com.
The User understands that the Operator may continue to use such personal data in cases permitted by the legislation of Thailand.
Consent to receive informational newsletters and marketing materials may be withdrawn by the User at any time by notifying the Operator in the same manner.
9.4. The data subject has the right to request confirmation of the fact that their personal data are being processed. In the case of such processing, the data subject has the right to access the personal data being processed, as well as information about the purposes of processing, categories of processed data, actions performed on the data, recipients of the data, guarantees applied when transferring the data to third parties, duration of processing, data sources, and the existence of fully automated decision-making processes. The data subject also has the right to obtain a list of the personal data being processed.
9.5. In situations where the Operator relies on the data subject’s consent as the legal basis for processing, the data subject has the right to withdraw their consent at any time. Each consent to personal data processing granted by the data subject to the Operator includes a procedure for withdrawal — if the data subject wishes to withdraw any consent previously granted, they may do so in accordance with the procedure outlined in that consent.
9.6. The data subject has the right to request the correction of their personal data in the event of inaccuracies in the data being processed by the Operator. Considering the purposes of processing, the data subject also has the right to supplement their personal data, including by submitting an additional statement.
9.7. The data subject has the right to request the restriction of processing of all or part of their personal data if one of the following conditions applies:
- the accuracy of personal data is contested by the data subject (restriction applies for the period necessary for the Operator to verify the accuracy of the personal data);
- unlawful processing of personal data has been identified, and the data subject objects to deletion, instead requesting a restriction on their use;
- the Operator no longer requires the personal data for processing purposes, but the data subject needs them for the establishment or exercise of legal claims or in the course of judicial proceedings;
- the data subject objects to the processing of their personal data (restriction applies for the period necessary for the Operator to determine whether the Operator’s legitimate grounds for processing override those of the data subject).
9.8. The data subject has the right to request the deletion of their personal data from the Operator’s systems and/or other material sources if one of the following conditions applies:
- the personal data are no longer necessary for the purposes for which they were collected;
- the data subject withdraws their consent on which the processing was based, and there is no other legal basis for processing;
- the data subject objects to the processing of their personal data, and there are no overriding legitimate grounds for such processing;
- the personal data are being processed unlawfully;
- the personal data must be destroyed to comply with a legal obligation in accordance with applicable law;
- at the time of data collection, the data subject was a minor under the age of 16, and the personal data were not obtained based on the consent of a legal representative for the provision of services via remote access channels (information society services).
9.9. The data subject has the right to request a list of their personal data provided to the Operator for processing in a structured, commonly used, and machine-readable format, and to instruct the Operator to transfer their personal data to a third party, provided that the Operator has the corresponding technical capability. In this case, the Operator shall not be responsible for the actions of the third party with respect to such personal data after the transfer.
9.10. The data subject has the right to object to the processing of part or all of their personal data for the purposes stated at the time the personal data were provided to the Operator, except in cases where the Operator’s legitimate grounds for processing override the interests, rights, and freedoms of the data subject, or where processing is necessary for the establishment, exercise, or defense of legal claims.
9.11. The data subject has the right to request a restriction on the processing of their personal data for the Operator’s marketing activities.
9.12. The data subject has the right to lodge a complaint with a supervisory authority if the Operator in any way violates their rights in the field of personal data processing.