Privacy Policy

Last updated: 27 December 2022

Privacy Policy

GoWabi (Thailand) Company Limited (“Company” or “We”) gives highest importance in protecting Personal Data; consequently, the Company publishes this Privacy Notice (the "Privacy Notice") in order to fulfill our obligations as the data controller under the Personal Data Protection Act B.E.2562 (“PDPA”). This Privacy Notice will define how the Company will collect, compile, process and use the Personal Data (as defined hereunder) of any visitors to the Company’s platform, any users who register for user accounts, and/or any person who use the Company's services ("User" or “You”) for the performance of our services, which include the service of providing a platform for booking beauty and salon services (the "Services").

The Scope of Privacy Notice This Privacy Notice shall only be applicable to the Personal Data processing undertaken directly by the Company in the provision of Services by us to You through website https://www.gowabi.com, mobile application, GoWabi App and GoWabi Partner App ( all website and application collectively referred to as the “Platform” ) or through other communication channels. This Privacy Notice shall not be applicable to the process of the Personal Data by any other third-parties, even those third-party services are connecting from the Platform or relates to the Service (including, but not limited to, the processing of Personal Data by our merchant partner that registers to offer beauty, salon and massage service to You through our Platform ( the Partner ) .It should be noted that the Company does not have any ability to control the Personal Data processing undertaken by those third-party; therefore, it is highly recommended that the User should study the relevant privacy notices of those third parties that are separate from this Privacy Notice.

Acceptance and Amendment of the Privacy Notice. When the User access the Platform, signing for a user account, contact and/or use our Services, the Company shall deem that the User accept and acknowledge this Privacy Notice. The Company reserve our right to make any amendment to this Privacy Notice from time to time in order to ensure the compliance with the relevant laws and the change in the Services that We are providing to You; provided that the Company will inform the User of those changes by announcing the amended Privacy Notice via the communication channels that the Company may have.

Personal Data means any data that can be used to identify any single individual, either directly or indirectly, excluding the data of the deceased.

Method that the Company Collect Your Personal Data
The Company may obtain and collect the User’s Personal Data from various method as follows
1. The Company may automatically collect User’s Personal Data by the system upon your visit to the Platform;
2. The Company may directly receive or collect the Personal Data from User through various channels, including (a) the contact made through various channels which the Company may have; (b) the user registration on the Platform; or (c) the participation in the Company’s promotional activities;
3. The Company may collect your Personal Data indirectly from: (a) social media where the User has opted to share your profile information and enabe the social media service provider to transfer Your Personal Data to the Company; (b) an external service provider engaged by the Company to provide relevant services to the Company in performing the Service, including without limitation to the payment gateway or our Partner; (c) any other third party who may refer You to use the Platform and/or Services; or (d) other third party to whom the User may give consent to disclose your Personal Data to the Company; provided that the Company will inform You of the relevant sources of information in case where the Company obtain Your Personal Data indirectly from third party.

Types of Personal Data being processed
The Company shall collect, compile and process Your Personal Data to the extent necessary to provide You with the Service and to operate the business in a manner that You would sensibly anticipate. Specifically, for the aforementioned purposes, the Company shall collect, use, or disclose Your Personal Data which is classified as follows:

General information		refers to full name, sex, profile picture, date of birth and any other Personal Data provided for the user account registration, including username and password;
Contact information		refers to e-mail, phone number, User’s social media account (i.e., LINE ID, Facebook Account / Google Account / Apple ID); and in case where the User use delivery Services, this contact information shall include the delivery address;
Technical information		refers to IP address, the log-in information, browser type and version of program which You use to access the Platform, time setting, location, operating system and platform, device’s universal code, serial number, device’s unique number and cookies (if any) and any other technology or tools used by You to access the Platform as well as other technical information collected automatically by our system when You using our Services to identify Your device and other technical analytic information;
Payment Information		refers to bank account information, credit card information, payment slip or other proof of payment of any Services fees, either made through the Platform or paid at salon to the Partner;
Transaction Information through Platform		refers to details of the order and payment made as well as other information relating to the Services used by the User; purchasing detail and purchasing history; cashback history; Your preference and interest; satisfaction feedback; the use of discount and promotional code log through Platform;
Usage Information		refers to information about User's purchasing habits,the search and query made by the User on the Platform; the visit of any Services or any content; items in the shopping cart, a list of Services that the User is interested in, notification logs and other transaction information.
Communication Information		refers to communication / interaction details and logs Information collected across various channels used by the Company for communication, including phone, email, website, and other social media channels
Other Personal Data		include but not limited to (1) other information that the User may give for the purpose of participation in the lucky draw or any other promotional events and activities (which may include the selfie photo of the User participating in the event); and (2) other information that You may provide to a Company via any form for Platform use; as well as the satisfaction review of the services performed by the Partner.

Objective of the Personal Data Processing and the Retention Period
The Company shall collect, use, process, retain User’s Personal Data for the lawful purposes without causing excessive impact on the User’s right as the data subject. Thus, the Company shall process the defined Personal Data for the following purposes:
1. For the Performance of any Contractual Rights and Obligations the Company may have to perform for You under the Terms of Services which include but not limited to:
  1. To verify the User’s suitability and qualifications for registering for user account and to manage a User account;
  2. To provide Services in response to User’s orders or reservations made on the Platform, including particular to verify booking orders; to confirm the use of Service with the relevant Partner; to verify Services fee payments; and to coordinate with the User before, during, and after the use of Services;
  3. To collect the User’s satisfaction feedback; and to display the rating results on the Platform for other users to study before making decision to use the services of such Partner;
  4. To respond to inquiries, comments, and complaints regarding the use of the Service on the Platform, as well as to contact and coordinate in the inspections process; to facilitate and effectuate cashback transaction; or to provide Users other adds-on Services;
  5. To verify the User’s eligibility to participate in various activities that the Company may arrange and in which the User may be interested;
  For the processing of Personal Data for performance of any rights and obligations the Company may have with You under the relevant contractual arrangement, the Company would need to collect, process and retain the Personal Data for as long as the Company still owes the User a Service, in particular if the User still has a Platform user account on the Platform.
2. For the Performance of the Legal Obligations that the Company may be subject to which include but not limited to obligations for accounting and tax payments, including VAT refund, tax invoices issuance and tax filing.
  
  For the processing of Personal Data for the performance of legal obligation, the Company need to process User’s Personal Data in accordance with the timeframe specified by relevant laws.
3. For the Protection of the Company’s or third party’s Legitimate Interests, without excessively cause impact on the User’s right as the data subject, the Company would need to process the Personal Data for the following purposes:
  1. To build and improve the business relationship between the Company and You, in particular, the Company may process the Personal Data to conduct analysis, investigation, complaint management, conducting internal audit reports on the Services provided by Company employees to Users; and to assess and manage the enterprise risk; provided that the Company reserve the right to process those Personal Data for so long as it is necessary and may retain the statistic information continuously thereafter;
  2. To analyze User interests in order to enhance the Service to better fulfill the needs and preferences of each User and Company’s overall users; to identify usage trends; to measure the effectiveness of promotional activities carried out by the Company; to analyze the use of Personal Data analysis for Platform development and experience improvement; to analyze User Service usage for marketing planning purposes, in particular, for the lookalike marketing purpose, excluding direct marketing to the User;
  3. To defend legal proceedings to be initiated between the Company and User;
  4. To process and transfer Personal Data to third parties that involves in the Company restructuring, including sales, transfers, mergers, reorganizations, or other events of a similar nature.
  For the processing of Personal Data to establish and enhance business relationships and/or improve the Service, the Company reserve the right to retain those Personal Data to the extent necessary to fulfill those business purpose without causing excessive impact on the User’s right as the data subject. For the processing of Personal Data for the purpose of protecting and preserving the Company’s legal rights, the Company will retain those Personal Data for the time period prescribed under the applicable law.
4. In case the User gives consent to the Company: The Company shall process the Personal Data for the purpose that the User give those consents to, including without limitation:
  1. To use other cookies, if necessary, (besides the Strictly Necessary Cookies which are the cookies that are required for the Platform to function and required for the provision of Services to the User in the most secure and feasible way), including the following cookies:
  2. To use the Personal Data for the promotional, direct marketing, or direct contacting You to inform the special privileges and promotions, discounts, special offers, advertisements, notifications, news, information regarding our Services from the Company and/or Partner through various communication channels that the User has notified the Company, including e-mail, phone, SMS or other equivalent forms of electronic communication such as In-App Notification
  The User may withdraw the consent at any time; provided that the withdrawal shall not affect the collection, use, disclose or process of the Personal Data undertaken with the User’s prior consent.
Disclosure of Personal Data
Generally, the Company will not disclose Your Personal Data, without Your consent or without any legal basis permitted under PDPA, to any third party. Yet, for the provisions of Services by the Company to You, the Company may need to share, transfer and/or disclose Your Personal Data to the following third party:
1. Partner whom the Company needs to transfer Your Personal Data to for the provision of the relevant beauty, salon or massage services by those Partner to You in response to the reservation made by You on the Platform; provided that the Company shall disclose and transfer Your Personal Data only to the extent necessary to performance of the relevant Service by us and/or the Partner to the User.
2. External Service provider (i) whom being engaged to provide support service to the Company in the performance of the Company’s contractual rights and obligations to You, including the information technology service provider, payment gateway, analytic, advertise and marketing service provider; (ii) whom being engaged in the business operation of the Company, including but not limited to: the consultants or legal advisor engaged in the protection of the Company’s legitimate rights; the consultant being engaged to assist in detect and prevent any fraud on the User’s transaction. For the disclosure of the Personal Data to these service providers, the Company shall only disclose and share the Personal Data on the necessary basis to serve the defined purposes and shall implement appropriate security measures in sharing and disclosing those Personal Data in particular the measures defined under the data processing agreement entered into with those Service providers
3. Other User when Users shares their Personal Data, in particular Services use feedback, or interacts with other users on the Platform;
4. Government authorities and/or regulator which the Company may be obliged under the relevant laws and regulations, court judgement, the government order to disclose and share the User’s Personal Data to those government agencies; provided that the Company will only share the Personal Data on the need-to-know basis to serve such particular purpose;
5. Other third party whom You may give consent to the Company explicitly to disclose Your Personal Data to.

Information Security measures to Protect Personal Data
Information security of the User’s Personal Data is critical for the Company; hence the Company has established the appropriate security measures to prevent the loss; unauthorized access, use, amendment, or disclosure of the User’s Personal Data. The Company will inspect and monitor the Personal Data collection method, the Personal Data storage area and implement processing practices, including physical safety measures, to be accordance with the Company's information security policy and guideline. In addition, the Company shall review the relevant information security measures as necessary and in response to any change in the technology to ensure the efficiency of the information security measures; provided in case the Company detect or receive any complaint of the breach in the Personal Data, the Company shall solve such breach urgently; seek the measures to prevent the effect which may occur consequently; and report such breach to the relevant regulatory authorities and affected data subject as prescribed under the applicable laws.

Data Subject Right
Subject to the provisions and exclusions of applicable law, the Company acknowledges and respects the User's statutory rights under the PDPA with regard to their Personal Data as follow
(1) the right to withdraw consent;
(2) the right to request access or a copy of your Personal Data under our possession;
(3) the right to request for data portability in case We restore the Personal Data in a form that can be read or commonly used by automatic tools or devices and the right to request for the automatic port of those Personal Data to other data controllers, except such transferal cannot be operated due to technical reasons;
(4) the right to object to any processing of your Personal Data which been processed on the Company’s or other’s legitimate interest ground or processed on the public interest ground ; provided that in case of the right to object, the Company will only continue processing the Personal Data to the extent that there is sufficient legal justification that overrides the User’s right as the data subject or processed as specifically required for the legal compliance or the legal defense purposes;
(5) the right to request for the deletion or de-identification of your Personal Data if it is believed that those data are unlawfully processed; there is no longer necessary for the Company to proceed as defined under this Notice; or upon the withdrawal of consent or the exercise of the right to object; provided that it should be noted that as a result of this process, the Company may not be able to identify you, which may limit the User's access to some Services for which the Personal Data is required and limit you from receiving Service benefits or Company news;
(6) the right to request for the temporary suspension of Personal Data processing during the time that the Company is still considers the data subject's request for rectification or objection, or in any other situation where there is no need for the processing and the Company is required by law to delete or destroy Personal Data, but the data subject requests the restriction of the use of such Personal Data instead;
(7) the right to request for the rectification of their Personal Data to be accurate, current, complete and not misleading.
Processing of Minor’s Personal Data
The Company has no intention of collecting Personal Data from Users under the age of 13. If any legal guardian is aware that your minor have given the Company their Personal Data, please contact the Company to give your consent for the use and access of Personal Data in accordance with this Privacy Notice. If the Company detects that we have collected Personal Data from persons under the age of 13 without the consent of their legal guardian, (if required) the Company will immediately remove such Users' Personal Data from the Company’s system.
Contact Information
If You would like to request to exercise any of those defined rights or if You have any queries, suggestion, or complaint regarding this Privacy Notice, please feel free to fill in the Data Subject Access Request form or contact our Personal Data protection unit.

Please contact us at:

GoWabi (Thailand) Company Limited

Major Tower Thonglor 7 FL Room 12, 141 Sukhumwit 63 (Ekkamai) ,Khlong Tan Nuea, Watthana, Bangkok

E-mail: [email protected]

Phone: 02-821-5950, working hours are 9:00 a.m. to 6:00 p.m. of everyday