Neo Residence Management Co.,Ltd (the “Company”) hereby gives you the confidence that all the personally identifiable information (the “PII”) that you have provided to us are important and critical information that we commit to assure the protection and we shall only process those information at the best security information standards.

Once you, as the user, visit this website and/or contact the Company via various channels, including the social media channels; visit the Company’s real estate development project and fill in the questionnaire to confirm your interest; or otherwise directly give your PIIs to the Company in any other circumstance, including with the consent granted under the terms and conditions of this Privacy Policy, the Company shall deem that you have agreed and accepted to be bound and comply with this Privacy Policy. It is understood that this Privacy Policy is intended to supplement instead of to supersede or replace any consent that you may have given the Company in relation to the PIIs process prior to this Privacy Policy.

Please kindly study this Privacy Policy in details. If you do not agree to the PIIs process defined hereunder, the Company reserves the right to refuse to provide any service or enter into any transactions with you since the PIIs processing as defined are critical for the performance of the Company’s obligations to you.

This Privacy Policy shall be applicable to this website and/or the service provided by the Company only and shall not be applicable to the application, services or other website of any third party that may connect to the Company’s website that the Company does not have any control over. In such circumstance, you should study the relevant privacy policy declared and announced by those third parties that are separate from this Privacy Policy.

The Company may adjust or amend this Privacy Policy at any time in order to assure the compliance with the relevant laws and regulations and to match with the services provided by the Company; provided that the Company shall notify you of all the amendment and modification made by announcing the amended Privacy Policy on the website.

PII that the Company is processing

The PII that are required to be processed for the performance of the Company’s business include the following information:

• 1. General information relating to you, including name, surname, age, sex and nationality;
• 2. Contact information, including address, contact address, telephone number and email;
• 3. Status information, including marital status, job title, business types and income range;
• 4. Transaction information required in the preparation of the sale and purchase agreement as well as other official documentations needed to effectuate the sale and purchase transaction and the ownership transfer, in particular, for the entry into the power of attorney for the ownership transfer, including your nationality, race as well as the PIIs of your related persons (such as your parents and spouses);
• 5. Your preference and interest information, including the budget; land and space size that you are interested to invest in; the purchase objective; purchase deciding factors; interesting location; development project type that you are interested in; and other additional information about your interest (i.e. hobby, social network activities, sports and tourism);
• 6. Other technical information that can identify or link to your identity, including your GPS collected while you visit the website, IP address, setting and browser connection that you uses to connect to the Company’s website and may include various types of cookies used in order to track your behavior on the website that we will collect and process upon receipt of your consent;
• 7. Other information that you may give for the purpose of marketing and sales promotion; the participation in the event, survey, competition, lucky draw; or any other promotional events and activities, including without limitation the photos taken from the activities and promotion events that have been hosted; and
• 8. Other PII that you may give to the Company during the correspondence and communication for the service performance from the Company to you; or any other PII that you may give the consent to the Company to process.

The Company may collect your PII in the following circumstances:

• 1. When you contact the Company, for instance, when you contact the Company in the development project that you are interested in on-site, via website, social media channel, on phone or via email;
• 2. When you submit your PII for the preparation of the documentation for reservation, sale and purchase and other relevant transactions, including the power of attorney for the transfer of ownership of the real estate as required in the legal template and documentation required by the relevant government authorities for the effectuation of the transaction;
• 3. When you contact the Company for the after-sale maintenance and defect reparation service;
• 4. When you register your interest and when you subscribe to get news, information and other benefits or promotions of the Company as well as other marketing materials;
• 5. When you participate in the survey, competition, lucky draw or other promotional events;
• 6. When you give your feedback and opinion on the Company’s services (i.e. survey gathering on paper or on the website) and/or
• 7. When you submit any PII to the Company for any other purposes.

In addition to the direct submission of the PII from you to the Company (as defined above), the Company may receive your PII from the third party sources that you may contact with and you have given consent to them to disclose your PII to the Company, for instance, the broker, selling agent or other referrer in the reference program. In such circumstance, upon the receipt of the relevant PII, the Company shall deem that the sharing of your PII by those third parties have been given with your consent to disclose your PII to the Company.

Objectives for the PII Process Undertaken by the Company

The PII that you have provided to the Company shall be collected and processed for these particular purposes:

• 1. To contact you back to propose more information about the development project that you are interested in and make a request before the contract entry; to perform the contractual obligations that you, as the contracting party, have with the Company, commencing from the reservation, purchase and sale; the ownership transfer to after-sale support and maintenance during defect and warranty assurance; and to manage the contractual relationship between the Company and you;
• 2. To create and improve the business relationship between the Company and you that may include the case where the Company uses your PII for the employee training or supervisions to assure the service quality (in particular for the customer support staff provided through various channel); for analysis, investigation and complaints resolution; provided that for the PII process for this particular purpose;
• 3. To manage the communication and correspondence that you may contact the Company (i.e., enquiry, complaint management, or other feedback submission);
• 4. To assess and analyze preference in order for the Company to improve the Company’s service to match with your interest to the fullest extent and to create the good relationship between the Company and you and other person who share the similar profile as well as to enhance the relationship between the Company and you that the Company may consider as to protect our legitimate interest;
• 5. To permit your participation in the competition, promotional events or other activities for point collection that you may have agreed to enter into under the relevant defined terms;
• 6. To perform any legal obligations that the Company may have and to comply with the instructions given by the relevant regulatory authorities, for instance, for the tax payment purpose or any other obligations under the Computer Crime Act or the electronic transaction regulations; and
• 7. Upon the receipt of your consent, the Company may use your PII in order to give information relating to the new project and/or the benefits or promotions that the Company and/or the affiliates or business partner may have that may match with your interest or be beneficial to you; provided that the Company will continue to do so until the User has withdrawn the consent given;
• 8. Other purposes that the Company may consider related to the objectives already defined above.

The Company need to process your PII for the purposes defined above throughout the period of time that the Company have the contractual obligations with you or for so long as the period of time as needed to perform the legal obligation; provided that the Company may need to process certain PII after the expiration of the contractual relationship or the legal obligations in order to protect or preserve the Company’s rights against the criminal offences or legal violation against you in the case of the illegal action for the period of time that the Company considers necessary to undertake those actions. Also, for the PII process that is being undertaken on the consent basis, the Company will retain your PII for so long as until you have withdrawn your consent.

Disclosure of the PII

Generally, the Company shall keep your PII in strict confidence; provided that in certain circumstances, the Company may have certain necessity to disclose the PII to these groups of people to fulfill Company’s contractual or legal obligations:

• 1. To the third party service providers and the affiliates or other business partners that have been engaged to provide direct services to the Company in the performance of any obligation to you and other third party who shall subsequently have the direct obligations to perform certain obligations to you, for instance (i) the owner of the real estate project that you are interested in and/or the juristic entities that will manage the real estate after the ownership transfer from the developer to you who will have direct obligations with you under the relevant transactions and agreements; (ii) the service provider engaged by the Company to perform marketing and customer engagement services; (iii) the relevant professional counsel (i.e. legal or accounting counsel) and other counsel engaged by the Company in the service performance to you; and (iv) upon the receipt of the consent for the use of performance cookies, to third party service provider who provide performance assessment of the website; provided always that the Company shall disclose your PII only for the specified objectives and solely on the need-to-know basis and the Company shall assure the information security for the PIIs being transferred and disclosed, in particular the data processing agreement shall be entered into with the recipient of the PIIs;
• 2. To the cloud storage service providers (that may be located in Thailand or abroad); provided that for the utilization of this particular services, the Company assure to set the high confidential configuration and setting to assure the security in your PII at the level that reflects the level of confidentiality and risk exposure;
• 3. To any third party that have been engaged by the Company in the legal proceedings to protect the Company’s legitimate rights or to detect and prevent any fraud or damage in the use of the Company’s services and may affect other person’s rights;
• 4. To any third party or the governmental authorities that the Company may be obliged under the applicable laws, court judgment or administrative order to disclose any PII of any particular users to; and/or
• 5. Other entity whom you may give consent to the Company explicitly to disclose your PII to, including the disclosure of PII to the commercial bank or financial institutions that you have applied for the credit facilities for the acquisition of the project.

Cookies that the Company uses

Cookies are text files stored on your computer browser directory or program data subfolder in order to keep data log of your Internet usage and behavior or interaction on the Website. For the performance of the Website, the Company need to use 4 types of Cookies for various purposes as defined below:

• 1. Strictly Necessary Cookies are the cookies essential for you to browse the Website and use its features, such as accessing secure areas of the Website;
• 2. Functionality Cookies are the cookies used to record information about choices that you have made in the Website such as personal settings, languages, and fonts so this would allow the Company to tailor our Website features that would match your preference setting;
• 3. Performance Cookies are the cookies used to assess the performance in any part of the Website; provided that the assessment may be conducted by the Company and/or the third party service provider whom the Company has engaged to perform that service; and
• 4. Advertising Cookies are the cookies used to record the your on-site behavior and history of the Website visited and this would allow the Company and/or the third party service provider engaged by the Company to provide the you the services and products that suit the your preferences and to assess the success of each function of the Website.

For the use of Strictly Necessary Cookies, the Company needs to use these cookies for the performance of the Website in full capacity and without this type of cookies, the Company shall not be able to provide the designated services to the you.

For other types of Cookies, the Company will only use those cookies upon the receipt of your consent and those Cookies shall be used for a limited purpose.

Even though the use of Cookies would enhance the performance in providing services in any features of the Website to you, you shall be entitled to disable the Cookies setting on your browser at your own will; provided that you shall acknowledge that the Cookies-disabled setting may impact the efficiency and the performance of the Website as defined in detail for each type of Cookies above.

Assurance on the implementation of the Appropriate Information Security of the PII

The Company assures that the Company shall use the most appropriate security measures to prevent the unauthorized access, amendment, or disclosure of the PII in any form or in any circumstance by either internal or external persons and the Company commits to review those measures on the regular basis with the strong commitment to use the best industrial practice and to be in strict compliance with the applicable laws. The Company undertake to update and review the information security measures regularly to assure that your PIIs are kept in strict confidence and reliable manner; provided that the Company reserve the right to make amendment of the information security tools if the Company deem that those tools can enhance and improve the efficiency of the information security.

Data Subject Rights

The Company acknowledges and accepts the User’s rights as the data subject over their PII as defined under the applicable laws that include the following rights:

• 1. Right to access; to request for the copy of all the PII; and to rectify or update their own PII;
• 2. Right to request for the PII that the Company has processed in the readable forms by the tools or automatic mechanics and to request for the data portability to other data controller;
• 3. Right to object to the PII process being undertaken;
• 4. Right to request for the erasure or de-identification of any PII that does not have any necessary basis to process, i.e. after the consent withdrawal;
• 5. Right to request for the PII process suspension in case that request for erasure is being exercised or when such PII is not necessary;
• 6. Right to withdraw consent that has been given for the PII process for specific purpose.

The User can contact the Company to exercise any defined rights through the defined channel and the Company will consider and notify the User of the Company’s determination within 30 days after the receipt of the User’s valid request.

Contact Us:
Data Controller:

Name: Neo Residence Management Co.,Ltd
Address: Neo Residence Management Co.,Ltd
1219/5 Moo.12 Bangna-trad k.m.4.5 rd.,
Bangna Bangkok 10260
Telephone: 086-331-7197
Email: DPO@neothaiproperty.com