Privacy Policy

Overview
We provide an overview of our Privacy Policy and where you can find more information below.  For your comprehensive understanding of our practices with respect to your information, please refer to the details set out in this Privacy Policy.  All capitalized terms are as defined in this Privacy Policy.

Who are we?

We are Flare (Thailand) Co., Ltd., a corporation having its registered office at 496-502 Amarin Building, 9th Floor. Unit No.2, 2.1 Phloen Chit Rd, Lumphini, Pathum Wan District, Bangkok. We are acting as a Data Controller for information collected through Our Services.
Details

What information do we collect about you?

We collect the following type of information about you:

 

Why do we collect this information?

We collect and use this information to:

 

Some of information is necessary to be provided for compliance with laws, or conclusion of contract with us, or performing  a contractual obligation with us.  If you do not provide such information, you may not use the whole or part of Our Services.

Who is this information shared with?

Your information is shared with:

How long do we store your information?

We retain your Personal Data until it is no longer necessary to fulfill the purposes of collecting your Personal Data, or until you request us to erase or destroy your Personal Data. We may be required to retain certain information in order to comply with the laws which we are subject to.

What are your rights with respect to your Personal Data?

Regarding your Personal Data which we collect and store, you have the rights to:  


If you are located in the European Economic Area or the United Kingdom (the “European Countries”), you have certain rights and protections under the applicable law regarding the processing of your “personal data” as defined in the applicable law.  

 

Contact us

You may contact us through our Data Controller or Representative. 

  1. Introduction

 

​This Privacy Policy describes how we collect, use, disclose, share, store, and transfer (collectively, “process”) information about you when you use our services or products (collectively, “Our Services”).   We act as a Data Controller for any information collected through Our Services.

1.1. Who are we?
We are Flare (Thailand) Co., Ltd., a corporation having its registered office at 496-502 Amarin Building, 9th Floor. Unit No.2, 2.1 Phloen Chit Rd, Lumphini, Pathum Wan District, Bangkok.
We have the following affiliate companies (“Our Affiliates”):
- Flare inc., a corporation having its registered office at 2-67-10 Ikebukuro, Toshima-ku, Tokyo 171-0014, Japan

1.2. What is Personal Data?
In this Policy, “Personal Data” means information relating to a natural person, which is identified or identifiable, whether directly or indirectly, but excluding information of deceased natural persons.  Please note that at all times we will adhere to the applicable statutory definition in determining what information is and is not Personal Data for the purposes of this Privacy Policy.


1.3. Scope of this Privacy Policy
This Privacy Policy applies to information, including Personal Data, which we collect in relation to your access or use of Our Services only.  Regarding any information which you provide to or is collected by any third party other than us, please refer to privacy policy separately established by such third party.


1.4.Changes to this Privacy Policy
We will amend this Privacy Policy from time to time.  We will notify you of the amendment of this Privacy Policy through Our Services, or other measures determined by us in case we make any substantive or material amendments.  Any amendment will become effective upon our posting of the amended privacy policy on Our Services.

 

 2. What information do we collect about you?

 

1) We collect the following information about you:
Information which you choose to provide to us through Our Services 

2) Information collected as you use Our Services

3) Information provided from third parties

3. Why do we process your Personal Data?

 

3.1. We process your Personal Data for the following purposes, to the extent applicable.

We process your Personal Data for providing you with Our Services.  For example, we collect your name, email address, and other information to create your account of Our Services, and we use your user ID and password to verify you as a user of Our Services.  If you use a chargeable service, we collect  and use your payment information, such as banking account, credit card information, to charge you fees and other payment relating to Our Services.

 

4. Disclosure, Share, or Transfer of Personal Data


4.1. We may share your Personal Data with the following categories of recipients:

4.2. Except for the recipients prescribed above, we will not disclose your Personal Data to any third party without your prior consent, except where we collected your Personal Data based on any of the legal basis prescribed in 5. below.
4.3. We transfer your Personal Data to any of our Affiliates or third-party service providers outside of Thailand.  When we transfer it to such entities outside of Thailand, we ensure that appropriate safeguards and protections are taken in place pursuant to applicable laws.  However, please acknowledge that some countries that we transfer your Personal Data might not have appropriate safeguards and protections under the applicable laws of Thailand.

 

5. The legal basis on which we process Personal Data


We process your Personal Data based on a different legal basis depending on the nature of Personal Data and the type of processing involved.  We rely on the following legal bases (single or multiple) other than or in addition to your consent, insofar as it applies.

6. What do we do to keep your Personal Data secure?

We seek to take reasonable security measures to protect your Personal Data against loss, misuse, alteration, and divulgation.  Such reasonable security measures include use of adequate security software, restricted access, and assigning a person in charge of managing Personal Data. 
However, please note that although we take appropriate steps to protect your Personal Data, no website, product, device, online application or transmission of information, computer system or wireless connection is completely secure and therefore we cannot guarantee the security of your Personal Data.

 

7. How long do we store your Personal Data?

We retain your Personal Data until it is no longer necessary to fulfill the purposes of processing your Personal Data, or until you request us to erase or destroy your Personal Data. We may be required to retain certain information in order to comply with the laws to which we are subject. 
Specific retention periods are determined based on the following considerations: purposes of processing, the nature of Personal Data, and the necessity of retaining Personal Data for legal or business reasons.  For example, if you are a user of Our Services, we will normally erase your Personal Data within 6 months from the date on which you become no longer a user of Our Services; however, we may be necessary to retain the whole of part of your Personal Data for the purpose of establishment, compliance, or exercise of legal claims, defense of legal claims, or the purpose of compliance with the law. On the other hand, we will erase the analytical data which is processed in a format that cannot identify a specific individual after the purposes of processing are fulfilled.

8. What are your rights regarding your Personal Data?

Regarding your Personal Data which we collect and store, you have the rights to:

9. Information for Residents of European Countries

If you are located in the European Countries, you have certain rights and protections under General Data Protection Regulation (“GDPR”) regarding processing of your “personal data” as defined in the GDPR.  Some of information that we process may constitute the “personal data”.


9.1. Our Role as a Controller or Processor
If you are located in one of the European Countries, we act as a “controller” as defined in the GDPR when processing your personal data.  We may also act as a “processor” as defined in the GDPR to the extent that we process your personal data on behalf of and at the instruction of another party.


9.2. Legal Basis of Processing
If you are located in the European Countries, we collect and process your “personal data” based on the following legal basis:

Please refer to 5. The legal basis on which we process Personal Data for more details.

9.3. Automated Individual Decision-Making, Including Profiling
We do not use a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.


9.4. Your Rights
If you are located in the European Countries, regarding your “personal data” which we collect and store, you have the rights to:

a. the decision is necessary for entering into, or performance of, a contract between you and us; 
b. the decision is authorized by Union or Member State law to which we are subject, and which also lays down suitable measures to safeguard your rights, freedoms, and legitimate interests; or 
c. the decision is based on your explicit consent.
Those rights may be subject to a certain conditions as set forth in the GDPR.


9.5. Data Transfers
We transfer your “personal data” to any of our Affiliates or third-party service providers outside of the European Countries. When we transfer your “personal data” to such entity outside of the European Countries, we ensure that appropriate safeguards and protections are took in place pursuant to the GDPR.  For example, we enter into agreements including standard data protection clauses adopted by the European Commission or other appropriate arrangements with various entities located outside the European Countries with whom we share your “personal data”. However, please acknowledge that some countries that we transfer your “personal data” might not have appropriate safeguards and protections under the GDPR.  If we transfer your “personal data” to any of such countries, we will notify you of the possible risks of such transfer for you due to the absence of an appropriate safeguards and obtain your consent with such transfer. If you wish to receive a copy of documentation related to these safeguards, please contact us.
9.6. Complaints
If you are located in one of the European Countries, you may file a complaint with the Data Protection Supervisory Authority of the Member State of your habitual residence, place of work, or place of the alleged infringement.

Contact Details
If you have any questions regarding this Policy, please contact us here; or you may also contact us through the following contacts set out below. 

Flare (Thailand) Co., Ltd.
496-502 Amarin Building, 9th Floor. Unit No.2, 2.1 Phloen Chit Rd, Lumphini, Pathum Wan District, Bangkok 

Contact us

info [at] flare.run

 

This Policy was last updated on November 6, 2020.

Copyright 2020 Flare Inc., All rights reserved.