PRIVACY POLICY - lugentcorporation

1. Purpose of Information Collected

The use of this information is for the following primary purposes:

1.1 Enter into relevant sale and purchase agreement.

1.2 Communication of services, sale and purchase transactions.

1.3 Payment transaction processing.

1.4 Settlement of fund, Refund or Cancellation, Dispute and/or Chargeback of the payment transaction.

1.5 Recurring payment service and/or tokenization.

1.6 General administration.

1.7 Manage and maintain your account(s) and facility(ies) with us.

1.8 Respond to your enquiries and complaints and to generally resolve disputes.

1.9 Update, consolidate and improve the accuracy of our records.

1.10 Produce data, reports and statistics which have been aggregated in a manner that does not identify you as an individual.

1.11 Conduct research and survey, which solely for analytical purposes including but not limited to data mining and analysis of your transactions with us.

1.12 Meet the disclosure requirements of any law binding on us.

1.13 For audit, compliance and risk management purposes.

1.14 Any other purpose that we deem necessary and/or as required or permitted by any law, regulations, guidelines and/or relevant regulatory authorities.

2. User’s Information to be Collected and Method of Collection

For purposes of this Policy, “User’s Information” means information that identifies users, history of actions on communication services and other information created or accumulated in relation to user or users’ devices, which shall be collected by the Company pursuant to this Policy. Depending on the method of collection, the User’s Information that we may collect for a user to use the Services includes:

2.1 information provided by the user, including Personal Data that we may collect:

2.1.1 Name, Age, Race, Gender, Nationality, ID Number, Passport Number, Date of Birth

2.1.2 Contact Details such as House Number, Mobile Number; Email Address; Home Town Address; Correspondence Address; Delivery Address

2.1.3 Credit Card information

2.1.4 Bank Account number

2.1.5 Photographs

2.1.6 Other information entered by the user into such form as specified by the Company

2.2 information provided from services outside the Services to the extent that the user permits for use with the Services.
2.3 The Company may collect the following information from services outside the Services, including but not limited to social network services, to the extent the user permits for use with the Services at that time. The Company may collect information upon access to or use of the Services, including ID used by the user for such outside service, Authorized, terminal information, log information, cookies and anonymous ID; and location information.

3. Purpose of Use

Purpose of Use

3.1 The User’s Information may be used not only for provision of the Services as provided in Section but for other purposes as provided in Section 3.3

3.2 Specific purposes of the User’s Information for the provision of the Services shall include the following:

3.2.1 provision, maintenance, protection, and improvement of the Services, including but not limited to acceptance of registration for the Services, identification of individuals and computation of use fees;

3.2.2 guidance or response to inquiries relating to the Services;

3.2.3 addressing a violation of rules, regulations or policies relating to the Services (the “Rules”);

3.2.4 notice of any modification to the Rules; and

3.2.5 other purposes incidental to the foregoing.

3.3 Purposes other than those specified in Section 3.2 above shall be as indicated below:

4. Method of Notice, Publication and Permission; Method of Discontinuance of the Use

4.1 The user’s permission must be obtained before collecting the following User’s Information:

4.1.1 terminal information: and

4.1.2 location information.

4.2 If the user specifies a certain setting, the user is entitled to require the Company to, and the Company shall immediately, discontinue the use of any or all of the User’s Information, in accordance with such rules as may be from time to time prescribed by the Company. Depending on the item of the User’s Information, if such collection or use is required for the Services, the Company may not be able to discontinue such collection unless the user withdraws from the Services pursuant to the procedures as determined by the Company.

5. Outside Transmissions; Provision to Third Parties:

advertisements using the Users Information, the following information collection module is incorporated into the Services. Thus, the Company provides the User’s Information to the provider of such information collection module in accordance with the following:

• Name of Information Collection Module:

• Provider of Information Collection Module:

• Items of User’s Information to be Provided:

• Means and the Methods of Provision

• Purposes of Use by Provider:

• Whether or not Provider Intends to Provide Information to Third Parties:

• URL of Providers Privacy Policy

6. Provision of Personal Information to Third Parties

Unless required by the related Personal Information Protection Act or other applicable laws and regulations, the Company shall not provide to any third-party personal information contained in the User’s Information without the prior consent of the user, unless:

• The Company authorizes such third party to handle the personal information in whole or in part to the extent necessary to accomplish the purpose of the use.

• The personal information is provided through a business transfer by way of merger or other similar transactions.

• The personal information is provided to a provider of an information collection module pursuant to Section 4 hereof.

• The Company is required to cooperate with state or local governmental organizations or their agents to perform their duties or obligations pursuant to applicable laws and regulations, and such performance is likely to be precluded if the consent of the user must be obtained.

• In addition to the foregoing, the Company is entitled to disclose information pursuant to the Personal Information Protection Act or other applicable laws and regulations.

7. Joint Use

The Company may jointly use personal information as follows:

7.1 Items of Personal Information to be Jointly Used

7.2 Party to Jointly Use Personal Information

7.3 Purposes of Joint Use

7.4 Name of Party Responsible for User’s Information

8. Disclosure of Personal Information

Upon request from the user to disclose its personal information under the Personal Information Protection Act, the Company shall, without delay, disclose to the user such information after confirming its identity (or notify it of the nonexistence of such personal information), to the extent required to do so pursuant to the Personal Information Protection Act and other applicable laws and regulations.

9. Disclosure your personal data will be kept confidential, but you consent and authorize us to provide or share your Personal Data to the following class of users:

9.1 Persons/Organizations required under law or in response to government requests.

9.2 Related, subsidiaries, holdings of the Company, including future entities under the Company.

9.3 Government agencies, statutory authorities, enforcement agencies under law.

9.4 Auditors, accountants, lawyers under the Company.

9.5 Contractors, sub-contractors, affiliates of the Company.

9.6 Third party service /product providers that is deem necessary or appropriate for the purposes stated above (including those located out of Malaysia, under conditions of confidentiality and similar levels of security).

9.7 Persons under a duty of confidentiality to the Company.

9.8 Any other purpose that we deem necessary and/or as required or permitted by any law, regulations, guidelines and/or relevant regulatory authorities.

Data shared will be for the purpose as stated in this notice, or purposes not stated but directly related to the primary purpose of collection. We may also share your Personal Data where required by law or where disclosure is necessary to comply with applicable laws, legal processes or queries from the relevant authorities.

10. Data Security

We shall take necessary steps to store and process your personal data securely. We will undertake the following security steps:
10.1 Implementation of a formal information security policy and necessary technology controls such as firewall, password controls, physical security, logging and monitoring, etc.

10.2 Process controls such as segregation of duties, defined roles and responsibilities and need to know basis for staff;
10.3 Third party providers and contractors storing or processing personal data has implemented similar acceptable standards of security.

11. Retention of Personal Data

Your personal data will be stored for only the period as necessary to fulfill the purposes stated above after which we proceed to ensure that your personal data is destroyed, anonymized or permanently deleted if it is no longer necessary to store. Reasons to further store your information even after the fulfillment of the purposes includes:

11.1 to satisfy legal, regulatory or accounting requirements;

11.2 to protect the interest of the Company.

12. Direct Marketing

We may use your personal data to provide you with information about our and third-party services and/or products, which may be related to your interests, unless requested otherwise by you. We may, in some circumstances, disclose your personal data to preferred merchants and strategic partners. Such disclosure will only occur where you have subscribed for particular Services or Products which require such disclosure, and/or where your consent has been obtained, subject at all times to any laws (including regulations, guidelines and/or obligations) applicable to the Company.

We take reasonable steps to ensure that the 3rd parties we are sharing your personal data with also have appropriate privacy and confidentiality obligations.

If you do not wish your personal data to be utilized for the purposes of marketing and promotion, please contact us at the contact details below. Your latest written instructions to us will prevail.

13. Rights of Access and Correction

Under PDPA, you reserve the right to access your personal data and request for correction of the personal data that might be inaccurate, obsolete, incomplete or misleading. In respect to this, you may:

13.1 Request to check and access your personal data in our records;

13.2 Request that we correct any of your inaccurate, obsolete, incomplete or misleading personal data;

13.3 Request copies of the data from us.

Once we receive a request, we will acknowledge the receipt of such request. For data amendment and correction, we will consider if the information requires amendment. If there is any disagreement, then we specify the reason in clearly stated terms such as where rights of others will be violated, or regulatory functions will be affected.

In accordance with the PDPA, and to the extent not limited by any other applicable law, we may:

I. Charge an administration fee for processing your request for access or correction to the Personal Data, in compliance to the fees stated in PDPA sub-regulation; and

II. Refuse to comply with your request for access or correction to the Personal Information and give you a written reason for such an action.

14. Transfer of Your Personal Information Outside Thailand

It may be necessary for us to transfer your personal data outside Thailand if any of our service providers or strategic partners who are involved in providing part of a services are located in countries outside Thailand. You consent to us transferring your personal information outside Thailand in the instances whereby it is necessary to fulfil the execution of the service/products that you signed up for.

We shall take necessary steps to ensure that any such partners are contractually bound not to use your personal information for any reason other than to provide the Products and/or Services they are contracted by us, to safeguard your personal information.

15. Inquiries

Any suggestions, questions, complaints, or other inquiries on the handling of the User’s Information must be submitted to:
LUGENT (THAILAND) COMPANY LIMITED
23/74 Royal City Avenue Building, 1st Floor Zone G, Soi Soonvijai, Rama 9 Road, Bangkapi, Huai Khwang, Bangkok 10310, Thailand

The Company reserves its right to amend this Policy in the future, from times to times, any amendment to be done by the Company shall bind all user in all respect, and whether the Company has sent the prior notice to them regarding the amendment or not.