PERSONAL DATA PRIVACY NOTICE FOR PROCESSES RELATED TO CUSTOMERS OF M2 PLUS CO.,LTD

1. General Provisions For the purpose of complying with the Personal Data Protection Act B.E. 2562 (2019) and subordinate laws issued thereunder, including any amendment which may be made thereto, (“Laws on Personal Data Protection”), M2 PLUS CO.,LTD and its subsidiaries (“M2 PLUS”, “M2 PLUS PHUKET”, “us”, “we” or “our”) have prepared this personal data privacy notice for processes related to customers of M2 PLUS (“Privacy Notice”) to inform you regarding how M2 PLUS handles information which can or may identify you, whether directly or indirectly, according to the Laws on Personal Data Protection (“Personal Data”), for instance, the methods by which Personal Data is collected, used, disclosed or dealt with, whether by manual or automated means, such as recording, organization, storage, adaptation or alteration, retrieval, sending, transfer, disclosure or making available by any means, sorting, combination, restriction on or prohibition of access, erasure or destruction (“Processing”, “Process”, “Processes” or “Processed”), as well as to notify you of the purposes for such Processing, the retention period of Personal Data and your rights as the data subject. In this regard, M2 PLUS recommends that you read and understand the following terms under the Privacy Notice

2. About M2 PLUS At M2 Plus, our architects, interior designers, 3D artists, furniture makers, and project managers all work in harmony to deliver quality solutions that will save you time, money, and hassle. The M2 Plus team is renowned for its commitment to design excellence and innovation. Our aim is always to deliver on your project in a way that exceeds your expectations. We promise that we will be your most approachable and committed design and build partner.

For more information, please visit: www.m2.plus If you have any questions or would like to exercise your rights as set out in this Privacy Notice, you may contact M2 PLUS using the contact details provided below:

Email: info@m2.plus

Phone: +66 95 412 2891

Data Protection Officer:

Email: info@m2.plus

Phone: +66 95 412 2891

3. Groups or Categories of Persons Whom M2 PLUS Collects Personal Data
Under this Privacy Notice, groups or categories of persons from whom M2 PLUS collects and Processes Personal Data are as follows:

• Customers which means persons who purchase products and/or use services of M2 PLUS or those who are expected to purchase products and/or use services of M2 PLUS (prospective customers), or any other persons having similar characteristics, such as business operators that purchase products and/or use services of M2 PLUS, participants in the marketing activities, including competitions and campaigns, gift voucher recipients, website users, persons who make contact to request to receive information or services from M2 PLUS, and persons who provide responses to surveys concerning the products and/or services of M2 PLUS, etc.
• Persons related to customers which means persons who are related to or are representatives or personnel of juristic persons that are the customers or may become the customers of M2 PLUS, such as directors, executives, employees, staff, representatives or personnel of customers who are juristic persons, including persons whose Personal Data appear in relevant documents and processes, such as witnesses, purchasers, consignees and cheque payers, etc.

4. Personal Data Related to Minors M2 PLUS is not directed and intended for Processing of Personal Data of anyone under the age of 20 (“Minors”). Please do not allow your Minors to submit Personal Data to M2 PLUS. We do not knowingly collect Personal Data from anyone under the age of 20. If you are a parent or guardian and you are aware that your Minors have provided us with Personal Data, please contact us by using the contact details set out in Clause 2 of this Privacy Notice. If we become aware that we have collected Personal Data of Minors, we take steps to remove that Personal Data from our possession and storage.

5. Collected Personal Data Your Personal Data that is collected and Processed under this Privacy Notice, regardless of whether such Personal Data was directly provided by you to M2 PLUS or automatically collected from you by M2 PLUS, or was provided to M2 PLUS by other sources or third parties, includes the following:

• – Personal information, such as first name, last name, gender, date of birth, identification number, passport number, photograph, occupation and signature, etc.
• – Contact information, such as type of residence, address, mailing address, delivery address, telephone number, fax number, e-mail, and user IDs and accounts for various applications for communications or other social media (e.g., Facebook, Twitter, Line and Instagram) etc
• – Customer business information, such as name and address of the company you are affiliated with, and position, etc.
• – Information concerning transaction, such as transaction data, photos of installation place, schedule of works, drawing, customer code, purchase amount, bank account details, Personal Data which appears in the invoice, tax invoice, and receipt, and details of complaints concerning products and services (e.g., date of order, type of product, relevant branch and the problem that is found), etc.
• – Information that is used as supporting evidence for the execution of transactions, such as Personal Data which appears in a copy of the national identification card, copy of passport, power of attorney, copy of company affidavit, copy of bank account, map, and sale and purchase agreement or any other agreements relating to the transaction, etc.
• – Sensitive personal data, such as religion, and health data including body temperature, etc.
• – Technical information, such as log file, IP Address, browser type, browser version, the pages of our service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data, and information that M2 PLUS collects through the use of Cookies or other similar technologies, etc.
• – Other information, such as preferred brands, interested products and services, behaviors or trends to purchase products and/or services, photo and video recording by means of CCTV, and record of visitors including license plate number and time in and out, etc.

6. How M2 PLUS Collects and Receives Your Personal Data

M2 PLUS collects and receives your Personal Data via the following methods:

Personal Data which you directly provide to M2 PLUS

You may directly provide your Personal Data to M2 PLUS, such as:

• When you contact, inquire, express an opinion or comment, submit a complaint to M2 PLUS, whether in written or oral communications by face-to-face interaction or by contact at the place of business of M2 PLUS, or by any other channels, such as by telephone, fax, e-mail, mail, website, application for communication or any other media platforms;
• When you express an intention to purchase products or use services of M2 PLUS, enter into a contract with M2 PLUS or deliver documents containing Personal Data to M2 PLUS; and
• When you participate in marketing activities, competitions, campaigns, events or any other activities organized by or on behalf of M2 PLUS, etc.

Personal Data which M2 PLUS automatically collects from you

M2 PLUS may collect your Personal Data by automated means, such as the use of Cookies or other similar technologies. For more details, please see M2 PLUS Cookie Policy.

Personal Data which M2 PLUS receives from other sources or third parties

M2 PLUS may receive your Personal Data from other sources or third parties, such as:

• In case the customer is a juristic person, M2 PLUS may receive your Personal Data from contact persons, representatives or personnel of the juristic person that you affiliated;
• Business partners or service providers of M2 PLUS, such as digital payment platform operators, food delivery platform operators, POS restaurant management system operators, delivery service providers, website service providers, application service providers, property developers, designers, interior design and decoration companies, and suppliers, etc.;
• Designers and interior design and decoration companies that you have contacted or engaged;
• Companies under M2 PLUS;
• Government agencies, such as Department of Business Development; and
• In some cases, M2 PLUS may collect your Personal Data from public data sources, data sources containing information relating to your business or sources containing information relating to trades, irrespective of whether you have disclosed the Personal Data by yourself or have provided consent to somebody else to disclose such Personal Data, etc.

In collecting your Personal Data, you will be informed of the details as set out in this Privacy Notice, including but not limited to, the purposes and lawful bases for the collection, use, disclosure and/or Processing of Personal Data, or in the event that the Laws on Personal Data Protection require your consent for any Processing of Personal Data, M2 PLUS will explicitly request your consent. Where M2 PLUS has previously collected your Personal Data before the Laws on Personal Data Protection have become effective, M2 PLUS will continue to collect and use your Personal Data in accordance with the original purposes of collection. Nevertheless, after the Laws on Personal Data Protection in respect of the collection, use or disclosure of Personal Data have taken effect, if you do not wish for M2 PLUS to collect and use your Personal Data and if M2 PLUS has relied on your consent as a basis in Processing your Personal Data, you may contact M2 PLUS using the contact details set out in Clause 2 of this Privacy Notice to request for the withdrawal of your consent. To this end, M2 PLUS reserves the right to consider your request for the withdrawal of consent and proceed in accordance with the Laws on Personal Data Protection.

7. Purposes and Lawful Bases for the Processing of Personal Data
M2 PLUS Processes your Personal Data for the purposes under lawful basis as follows (collectively, the “Purposes”):

No.	Purposes	Lawful Bases of the Processing
(a)	For the purpose of verifying the identification of customers or persons related to customers.	Legitimate interests basis: The Processing of Personal Data of the customers or persons related to the customers is necessary for the legitimate interests of M2 PLUS in verifying the identification of such persons, such as verifying the identification prior to granting award in a marketing activity.
(b)	For the purpose of creating accounts for customers.	Legitimate interests basis:  The Processing of Personal Data is necessary for the legitimate interests in operating business or complying with M2 PLUS’s policy, or in case where the customer is a juristic person, the Processing of Personal Data of persons related to the customer is necessary for the legitimate interests in operating business or complying with M2 PLUS’s policy, such as the record of history and transaction data (customer’s account or AR code), etc.
(c)	For the purpose of managing customer orders, providing contracts, and performing obligations under the contract between M2 PLUS and customers.	Contractual basis: The Processing of Personal Data of the customers is necessary in executing the request of the customers before entering into contracts, providing the contracts and perform the obligation as stipulated in the sale and purchase agreements, service agreements and rental agreements where the customers are contracting parties, such as quotation, interior design, delivery, shipping, installation, repair, exchange, returning products, refund, billing and delivery of receipts to the customers, etc. Legitimate interests basis: In case where the customer is a juristic person, the Processing of Personal Data of persons related to the customers is necessary for the legitimate interests in operating business, preparing contracts and managing contracts of M2 PLUS, such as the use of director’s or representative’s data of the customers’ company in preparing contracts, managing customer orders, managing contracts and contacting with customers, etc.
(d)	For the purpose of providing customers care and support.	Legitimate interests basis: The Processing of Personal Data of the customers is for facility support, such as the record of order history and delivery location to facilitate the next purchase order and restaurant reservations, dealing with your inquiries and requests, etc.
(e)	For the purpose of receiving complaints from customers or persons related to the customers.	Legitimate interests basis: The coordination and Processing of Personal Data of the customers or persons related to the customers is necessary for legitimate interests of M2 PLUS in solving deficiencies and problems, as well as developing the quality of the products or services provided by M2 PLUS.
(f)	For the purpose of informing news or publicizing products, services or activities.	Consent basis: M2 PLUS will inform news or publicize products, services and marketing activities, such as direct marketing, sending marketing messages to the customers, publicizing marketing activities, etc. M2 PLUS will undertake such actions by relying on the consent received from you. Legitimate interests basis: When you notify, contact or provide information on interested products, services or activities in order for M2 PLUS to contact back, inform news or publicize such matters to you, or in case where the customer is a business operator or juristic person, the Processing of Personal Data of persons related to the customer for publicizing products, services or activities to the persons related to customer is necessary for legitimate interests of M2 PLUS, such as to present new products of M2 PLUS to the contact person of the customer who is a juristic person, etc.
(g)	For the purpose of arranging marketing activities.	Contractual basis: The Processing of your Personal Data is necessary to execute per your request in participating in marketing activities, such as an application and grant awards in the competition or campaign according to the terms and conditions that M2 PLUS prescribed. Legitimate interests basis: The Processing of your Personal Data to issue a gift voucher in a customer’s name, or in case where a customer is a business operator or juristic person, the Processing of Personal Data of persons related to the customer in order to arrange marketing activities is necessary for legitimate interests of M2 PLUS. Consent basis: In this regard, where the Laws on Personal Data Protection require your consent for any Processing of Personal Data, M2 PLUS will explicitly request the consent from you.
(h)	For the purpose of developing quality of the products and services, analysis and planning of marketing strategies.	Legitimate interests basis: The Processing of your Personal Data from purchasing products or services, surveying the interest or satisfaction of the customers on the products and services, including the usage of website or communication via other channels in which is necessary for legitimate interests of M2 PLUS in operating  business and developing the quality of the products and services provided by M2 PLUS, such as the analysis of purchasing strategies and marketing strategies, development of quality of products and services, improvement of the operation, improvement of the website, including the solving deficiencies and problems related to products and services. Consent basis: In case M2 PLUS observes or monitors your behavior or interest to analyze and plan for marketing strategies, or to analyze the behavior and conduct direct publicize or advertise according to your behavior or direct marketing, or in the case where the Laws on Personal Data Protection require your consent, M2 PLUS will undertake such actions by relying on the consent received from you.
(i)	For the purpose of internal and external audit, and analysis of various information that is necessary for business operations of M2 PLUS.	Legitimate interests basis: The Processing of Personal Data is necessary for the legitimate interests of the business operation of M2 PLUS, such as maintenance of IT system, detection, prevention and solution of technical issues, and other service planning, etc.
(j)	For the purpose of the compliance with the laws relating to M2 PLUS’s business and legitimate orders of courts, government agencies and relevant officers.	Legal obligation basis: To comply with the applicable laws of M2 PLUS, such as taxation law, Laws on Personal Data Protection, computer crime law, laws on communicable diseases, laws on customs, and legitimate orders of the courts, government agencies and relevant officers, such as the Customs Department and Office of the Personal Data Protection Commission, etc. Legal obligation basis to achieve the purposes relating to public interests in public health: In some cases, the Processing of sensitive Personal Data is necessary for M2 PLUS in complying with laws to achieve the purposes relating to public interests in public health, such as the collection of health data or body temperature of the persons entering into M2 PLUS in order to protect from the spreading of COVID-19 according to the laws on communicable diseases, etc.
(k)	For the purpose of establishment of legal claims, proceeding in accordance with and exercise of claims, or raising arguments to defend claims pursuant to the laws.	Legitimate interests basis: The Processing of Personal Data is necessary for the establishment, compliance, exercise or defense of legal claims of M2 PLUS in various stages according to the laws, such as investigation and/or inquiry by government officials, reporting the compliant, case preparation, prosecution and/or pursuit of the case in court, etc.
(l)	For the purpose of monitoring and ensuring the security of persons and properties of M2 PLUS.	Preventing or suppressing a danger of person’s life, body or health basis: The Processing of Personal Data is necessary for the benefit in checking, monitoring, preventing or suppressing any circumstances which may be dangerous to person’s life, body or health. Legitimate interests basis: The Processing of Personal Data is necessary for the legitimate interests of M2 PLUS in monitoring and ensuring the security of properties of M2 PLUS. For example, the information of the visitors or the CCTV footage can be used to prevent loss or damage to M2 PLUS’s properties or to track properties or claim damages in the case where the properties of M2 PLUS are lost or damaged, etc.
(m)	For any transaction that is necessary and beneficial to M2 PLUS or other persons or juristic persons which are directly related to the purposes set forth above.	Legitimate interests basis: The Processing of Personal Data is necessary for the legitimate interests of M2 PLUS or other persons or juristic persons in carrying out any transactions which are necessary and/or beneficial to M2 PLUS or any other persons or juristic persons, or directly related to the purposes set forth above. In this regard, where the Laws on Personal Data Protection require your consent for any Processing of Personal Data, M2 PLUS will explicitly request the consent from you.
(n)	For other purposes of which M2 PLUS will notify you.	M2 PLUS will notify you of any other purposes that cause M2 PLUS to Process your Personal Data other than the purposes set forth above or when M2 PLUS changes the original purposes that were set forth. In this regard, where the Laws on Personal Data Protection require your consent for any Processing of Personal Data, M2 PLUS will explicitly request the consent from you.

Your Personal Data which M2 PLUS will Process for the Purposes set forth in Clause 7.1 above that relate to the compliance with laws or contracts or are necessary for entering into contracts with you, is the data which is necessary for the achievement of the said Purposes. If you do not intend to provide such Personal Data to M2 PLUS, there may be legal implications or M2 PLUS may not be able to perform its duties pursuant to the contract which has been entered into with you or may not be able to enter into a contract with you (as the case may be). In such event, it may be necessary for M2 PLUS to decline to enter into the contract with you or to cancel the sale and purchase or services related to you, whether in whole or in part. In the event that M2 PLUS will Process your Personal Data in a manner and/or for purposes which are not consistent with the Purposes set forth above, M2 PLUS will put in place additional policies or notifications for the protection of Personal Data to provide explanations concerning such Processing of Personal Data. In this regard, you should review such additional policies or notifications in conjunction with this Privacy Notice (as the case may be).

8. Disclosure of Personal Data M2 PLUS may disclose your Personal Data in accordance with the Purposes and the rules prescribed under the laws to the following persons and entities:

• Companies in M2 PLUS, including directors, executives, staff, employees and/or relevant in-house personnel, and as necessary on a need-to-know basis for the Processing of your Personal Data.
• Business partners, service providers, suppliers, and data processors designated or hired by M2 PLUS to perform duties in connection with the management/Processing of Personal Data for M2 PLUS in the provision of various services, such as information technological services, website management services, cloud services, document depository services, payment services, printing services, mailing services, delivery services, freight forwarding services, shipping services, installation services, repair services, data analytics services, marketing services, remarketing services, bank, or any other services which may be beneficial to you or relevant to M2 PLUS’s business operations, etc.
• Designers and interior design and decoration companies that you have contacted or engaged;
• Advisors of M2 PLUS, such as legal advisors, lawyers, auditors, or any other internal and external experts of M2 PLUS.
• Court and relevant governmental agencies which have supervisory duties under the laws or which have requested the disclosure pursuant to their lawful powers or relevant to the legal process or which were granted permission pursuant to applicable laws, such as Ministry of Commerce, Revenue Department, Customs Department, Department of Disease Control, Office of the Personal Data Protection Commission, Royal Thai Police and Office of the Attorney General, etc.
• Any persons or other entities that you have given consent to disclose your Personal Data to, such as the disclosure of processed images of activities through various media platforms of M2 PLUS to the general public.
• The disclosure of your Personal Data to third parties shall be in accordance with the Purposes or other purposes permitted by law, provided that if the law requires your consent to be provided, M2 PLUS will request for your prior consent.
• In the event that M2 PLUS discloses your Personal Data to third parties, M2 PLUS will put in place appropriate safeguards to protect the Personal Data that has been disclosed and to comply with the standards and duties relating to the protection of Personal Data as prescribed by the Laws on Personal Data Protection. Where M2 PLUS sends or transfers your Personal Data outside Thailand, M2 PLUS will ensure that the recipient country, the international organization or such overseas recipient has a sufficient standard for the protection of Personal Data or such transfers of your Personal Data outside Thailand have been carried out in accordance with the Laws on Personal Data Protection. In some cases, M2 PLUS may request your consent for the transfer of your Personal Data outside Thailand, subject to the requirements under the Laws on Personal Data Protection.

9. Retention Period

• M2 PLUS will retain your Personal Data for the period necessary to fulfill the Purposes for which the Personal Data was Processed, whereby the retention period will vary depending on the Purposes for which such Personal Data was collected and Processed. M2 PLUS will retain Personal Data for the period prescribed under the applicable laws (if any) by considering the statute of limitations under the laws for any legal proceedings that may occur from or in relation to the documents or Personal Data collected by M2 PLUS and having regard to M2 PLUS’s business practices and relevant business in relation to each category of Personal Data. ​
• In this regard, M2 PLUS will retain your Personal Data for a period not exceeding 10 years, starting from the date your legal relations/transactions with M2 PLUS come to an end. However, M2 PLUS may retain your Personal Data for a longer period of such time prescribed if the laws permit or such retention of Personal Data is necessary for the establishment of the right of claim of M2 PLUS.
• After the period of time set forth above has expired, M2 PLUS will delete or destroy such Personal Data from the storage or system of M2 PLUS and other persons providing services to M2 PLUS (if any) or anonymize your Personal Data, unless in the event that M2 PLUS can continue to retain such Personal Data as prescribed by the Laws on Personal Data Protection or other applicable laws. In this regard, for additional details regarding the retention period of your Personal Data, you can contact M2 PLUS by using the contact details set out in Clause 2 of this Privacy Notice.

10. Your Rights in Relation to Personal Data As the data subject, you have the following rights in relation to your Personal Data, subject to the rules, methods and conditions under the Laws on Personal Data Protection. In this regard, if you wish to make a request to exercise your rights, you can contact M2 PLUS by using the contact details set out in Clause 2 of this Privacy Notice.

• Right of Access You have the right to access your Personal Data and may request that M2 PLUS provide you with a copy of such Personal Data in accordance with the requirements under the Laws on Personal Data Protection.
• Right to Data Portability You have the right to obtain your Personal Data, including to request that your Personal Data is transmitted to another data controller or to you, except where it is technically unfeasible, in accordance with the requirements under the Laws on Personal Data Protection.
• Right to Object You have the right to raise an objection to the Processing of your Personal Data in certain circumstances prescribed under the Laws on Personal Data Protection.
• Right to Erasure You may request that M2 PLUS delete, destroy or anonymize your Personal Data in certain circumstances prescribed under the Laws on Personal Data Protection.
• Right to Restriction You have the right to request that M2 PLUS restrict the Processing of your Personal Data in certain circumstances prescribed under the Laws on Personal Data Protection.
• Right to Rectification You have the right to request that your Personal Data be rectified if the Personal Data is inaccurate, not up-to-date or incomplete, or may cause a misunderstanding.
• Right to Withdraw Consent If M2 PLUS relies on your consent as the legal basis for Processing your Personal Data, you have the right to withdraw such consent which has been provided to M2 PLUS at any time.
• Right to Lodge a Complaint If you have any concerns or questions about any aspect of M2 PLUS’s practices in relation to your Personal Data, please contact M2 PLUS using the contact details set out in Clause 2 of this Privacy Notice. Where there is reason to believe that M2 PLUS is in breach of Laws on Personal Data Protection, you have the right to lodge a complaint to the expert committee appointed by the Personal Data Protection Commission in accordance with the rules and methods prescribed under the Laws on Personal Data Protection. To this end, M2 PLUS reserves the right to consider your request to exercise your rights and act in accordance with the requirements under the Laws on Personal Data Protection.

11. Changes to This Privacy Notice M2 Plus may make changes to this Privacy Notice from time to time to reflect any changes to our Processing of your Personal Data and to comply with any changes to the Laws on Personal Data Protection or any applicable laws. In this regard, M2 PLUS will notify you of any significant changes to the Privacy Notice and the amended Privacy Notice through appropriate means and/or post the amended Privacy Notice on M2 Plus’s website www.m2.plus/privacy-policy/. M2 Plus encourages you to review such communication periodically in order to be aware of any changes made to this Privacy Notice. This Privacy Notice shall be effective from May 31, 2022. Last updated on September 11th, 2022