Personal Data that The Company and Group of Companies are required to collect, gather, and process

1. General information relating to the Customer such as full name, date of birth, gender, nationality, the Customer’s status information such as marital status, job title, type of business, income level, including any other information that the Customer may give to The Company and Group of Companies in the site visit questionnaire or Noble ID information.

2. Identification documentation of the Customer i.e., identification card and passport, including the copy thereof;

3. Customer’s contact information such as address, telephone number, email, and social media account;

4. Any information or documentation that is necessary for the preparation of booking form, sale and purchase agreement, the preparation for ownership transfer document and registration process with various government authorities which may include the personal data of the Customer’s spouse, parents, or other related persons (including without limitation the co-owner); provided that in case the Customer provide any personal data of other persons to The Company and Group of Companies, the Customer shall be deemed to give the representation and warranty that they are fully entitled to give and share those personal data to The Company and Group of Companies to process;

5. Payment information for the purchase price of real estate as well as any other related service fee (such as government fee, transfer fee, and other support service fee (if any)), including without limitation, the cheque, evidence of credit facilities agreement, evidence of payment by bank account or automatic credit card payment, or credit card information;

6. Other personal data that the Customer may give to The Company and Group of Companies in the form prepared by The Company and Group of Companies for the use of other services which may include request form for reparation, co-owner amendment, personal data revision, real estate ownership handover and transfer or any other request form submitted to The Company and Group of Companies;

7. Personal data being collected during the use of any services via application or other electronic, including the application or system registration, including other technical information and the Customer’s service transactional information executed via such system, either in the personal identifiable or statistical form;

8. Any personal data that the Customer may give to The Company and Group of Companies for the participation in the marketing campaign or lucky draw hosted by The Company and Group of Companies, and the Customer’s photo that The Company and Group of Companies may collect during the event participation and the photo evidence of real estate transfer;

9. Other personal data that the Customer may give to The Company and Group of Companies during any other communication or any personal data that the Customer may give consent to The Company and Group of Companies to process.

In addition to receiving a Personal Data directly from the Customer, The Company and Group of Companies may receive the Customer’s Personal Data from other persons that the Customer may contact and give consent to those persons to disclose your personal data to The Company and Group of Companies, for instance, the referrer, oversea sale agent, or the notification of the change of contracting party name, the financial institution that the Customer contact to request for the credit facilities. In such circumstances, once the third party have submitted the Customer’s personal data to The Company and Group of Companies, The Company and Group of Companies would deem that the Customer have given consent to such third party to disclose and share those personal data to The Company and Group of Companies.

Objectives of the Personal Data Processing

The Company and Group of Companies need to collect, use, and process the Customer’s personal data in order to serve the following purposes:

1. To perform any contractual obligation and exercise any contractual right between The Company and Group of Companies and the Customer in particular (i) to respond to the contact or request from Customer (ii) to prepare the documentation starting from reservation form to sale and purchase agreement (iii) to verify and validate the performance of the contractual rights and obligations of any parties under the sale and purchase agreement especially the validation of payment, the process of ownership transfer, the assurance of the defect warranties, and the provision of other support services; and (iv) to manage the contractual relationship between The Company and Group of Companies and Customer and/or transferee under various agreements that have be executed;

2. To perform any legal obligation that The Company and Group of Companies may have such as the preparation of the accounting and taxation report or the ownership transfer registration;

3. To protect The Company and Group of Companies' legitimate interest without excessively cause the impact on the Customer, The Company and Group of Companies will process the Customer’s personal data for the following purposes:

• To build and improve business relationship between The Company and Group of Companies and the Customer that may include data analysis; the investigation and management of problem raised relating to The Company and Group of Companies' service; the request for service satisfaction feedback; the preparation of internal audit report; the assessment and management of overall enterprise risk; provided that for this particular purpose, The Company and Group of Companies will process the Customer’s personal data only as necessary and reserve the right to continuously store the data in non-identifiable statistical form;
• To analyze the Customer’s interest for the purpose of improving the project design or the service provision that would match the Customer’s need and interest, both as an individual and overall;
• To protect and defend The Company and Group of Companies' claim against the Customer throughout the legal prescription period;
• To analyze the Customer’s interest for the purpose of marketing strategy in particular the use of personal data to pursue lookalike marketing techniques; provided that this will not include the direct marketing to the Customer;

4. In case the Customer give consent to The Company and Group of Companies to process their personal data for specific purposes, The Company and Group of Companies would process the Customer’s personal data to serve those purpose, for instance, for the marketing and promotion purposes.

Retention Period of Personal Data

The Company and Group of Companies may need to process and retain the Customer’s personal data for the specified purposes throughout the period of time as follows: (1) throughout the time that The Company and Group of Companies still have the contractual rights and obligations with the Customer; (2) for the period of time necessary for the protection of The Company and Group of Companies' legitimate rights that may have with you especially for the time of prescription period; (3) for the period of time that is necessary for The Company and Group of Companies' business operation, in particular for enterprise risk assessment and management or for the project and service design and development; provided that in case that The Company and Group of Companies have anonymized the Customer’s personal data, those data will be retained for a longer business terms while The Company and Group of Companies commit not to excessively cause the impact on the Customer’s rights and the Customer can exercise the right to object; (4) for the period of time that The Company and Group of Companies has the legal obligations to retain those information as defined under the applicable laws; and (5) in case consent is given, The Company and Group of Companies shall process the Customer’s personal data until the withdrawal of the consent.

Disclosure of Personal Data

Generally, The Company and Group of Companies will not disclose the Customer’s personal data to any third party, but The Company and Group of Companies may need to disclose and/or share the Personal Data to the following persons:

1. To third-party service providers of The Company and Group of Companies including (i) Group of Companies, business partners, third party service provider being engaged to support The Company and Group of Companies' service provision and performance of any obligations that The Company and Group of Companies may have with Customer, for instance, affiliates who own the real estate project in which Customer are interested in, IT system service provider, third-party assisting in the sales, marketing or ownership transfer, or contractor who will provide reparation services in case of defect warranty; (ii) service providers engaged to assist in The Company and Group of Companies' business operation, including without limitation consulting service provider, financial institution providing the credit facilities to The Company and Group of Companies for project development that The Company and Group of Companies may be obliged to disclose Customer’s personal data (i.e. sale and purchase agreement and its details) to such institution, legal counsel who will assist in the defense of The Company and Group of Companies' legitimate interest and rights as well as to protect and investigate the misconduct or fraud committed by the Customer.

For these necessary disclosures, The Company and Group of Companies commit to disclose and share Customer’s personal data to such persons only for the specified purposes on the necessary basis and shall implement the appropriate measure to ensure the information security of the shared and disclosed personal data under the scope of data processing agreement that will be entered into;

2. To relevant government authorities that The Company and Group of Companies is obliged under the relevant laws, judgement or order to disclose such personal data to; provided that The Company and Group of Companies shall only disclose personal data on the necessary basis to perform such statutory obligations solely; or

3. To other persons that the Customer give explicit consent to disclose their personal data to, for instance, the commercial banks or financial institutions that the Customer may request for the credit facilities to purchase The Company and Group of Companies' project.

Security Measures for Personal Data Processing

The Company and Group of Companies represent to implement the appropriate information security to prevent unauthorized access, use, amendment or disclosure of Customer’s personal data that is in The Company and Group of Companies' control and The Company and Group of Companies commit to review the information security measures from time to time in order to ensure the suitability with the best industrial standard and the compliance with the relevant laws.

Data Subject’s Rights over their Personal Data

The Company and Group of Companies respect the Customer’s statutory rights as the data subject over their related personal data in The Company and Group of Companies' control. The Customer can request to exercise their rights under the relevant laws as follows: (1) the right to request for access or copy of their personal data; (2) the right to request for data portability; (3) the right to object to any process of their personal data; (4) the right to request for deletion or de-identification of the their personal data once there is no further necessity; (5) the right to request for the suspension of the processing of their personal data; or (6) the right to withdraw given consent; (7) the right to revise their personal data; and (8) the right to make any complain.

Please feel free to contact The Company and Group of Companies to request for those defined rights and The Company and Group of Companies will consider and get back to the relevant request within proper period under the law. Please contact us at [email protected] or Tel +66 2251-9955 (Office hours: Monday - Friday 8.30 AM - 5.30 PM).