Privacy policy

 

VV Retail Co., Ltd. (“we”, “us”, or “our”) believes that the privacy of our customers is not only a legal obligation that must be protected under applicable laws, and a key indicator of sustainable business operations today, but also a value that modern Thai society collectively recognizes as something worthy of protection.

In addition to complying with the law, we wish to be part of Thai society in promoting transparency and appropriate control over your Personal Data. We thank you for the trust you have placed in us, and we will handle your Personal Data with the utmost care while continuing to deliver the best products and services that we can offer to you.

This Privacy Policy covers our retail stores, website, social media channels, online communication channels, customer service channels, and any other locations where your Personal Data is collected in Thailand.

We may amend this Privacy Policy from time to time to reflect changes in our business operations. Any changes to this Privacy Policy shall take effect immediately once we publish the revised Privacy Policy on our website, application, or other communication channels, unless we determine that the enforcement of the policy should be postponed. In such case, we will specify the effective date of the policy in this document in advance.

Please read this Privacy Policy carefully and contact us through the channels specified in this document if you have any questions.

1. Personal Data We Collect

We collect or receive information that may identify an individual. Such information may be categorized as follows:

• Personal information, such as name, title, age, date of birth, photo, and eyesight prescription information for the purpose of preparing eyeglasses.
• Contact information, such as telephone number, postal address, delivery information, email address, social media information, including LINE ID, Facebook and/or Google account, as well as contact person information or contact information through other channels.
• Financial and transaction information, such as bank account information or other payment methods, PromptPay identification number, payment information, payment date and/or time, payment amount, refund information, accumulated points, purchase date and place, order number, service appointment date, address, date and time of receipt or delivery, recipient response messages, email signature of the recipient, product warranty information, claims, and other information related to the products and/or services you purchase.
• Membership information, such as membership number, accumulated points, point expiration date, membership type, customer type, date and month of joining or registration, membership duration, and records of your preferences for receiving our marketing communications.
• Technical information, such as Internet Protocol address (IP address), cookies, time spent on our website, login information, location data (GPS), latitude, longitude, time spent on each web page, search history, browsing information, browser type and version, time zone setting and location, browser plug-in type and version, operating system, platform, and other technologies on the devices you use to access our website, including any other technical information arising from the use of our systems and services.

The Personal Data we collect may vary depending on the context of our relationship with you and the purposes of data use described in this Privacy Policy.

2. Purposes of Our Use of Personal Data

We set out below the purposes and legal bases for our use of Personal Data under the following circumstances:

Purposes of Our Use of Personal Data	Legal basis
Sale of Products and Provision of Services This includes eye examination, eyeglass assembly, delivery arrangements, product pick-up appointments, product warranty, product exchange, correction, return, and refund.	Performance of the contract between us and provision of health-related services to you in accordance with the professional standards of optometrists.
Customer Relationship Contact This includes customer satisfaction surveys regarding products and/or services, customer service through various channels, and handling complaints or claims.	Performance of the contract between us and you and/or our legitimate interest in providing services to you.
Identity Verification This includes registration or identity verification to confirm that you are the correct person entitled to receive services or exercise legal rights with us.	Performance of the contract between us and you.
Marketing Communications Through Various Channels This includes advertising contact, promotional offers through email, and various social media platforms.	We will proceed only when we have obtained your consent.
Business Operations, Product Development, and Service Improvement This includes preparing anonymized business overview reports, measuring marketing performance, and assessing our operations and service performance.	Our legitimate interest.
Compliance with Legal Obligations This includes actions required to comply with laws or orders of government agencies, cooperation in legal proceedings, issuance of tax invoices, disclosure of information to tax authorities, and disclosure of information for investigation or prevention of unlawful acts.	Compliance with laws and regulations, and public interest.
Protection of Our Interests This includes detecting, preventing, and responding to fraud or unlawful acts, and preventing damage to our property and reputation.	Our legitimate interest.

Consent that we rely on to contact you may be managed through channels that we cannot control, such as your agreement to receive promotional communications through LINE or other social media platforms. You may manage your consent or communication preferences by using the settings available within those applications or platforms.

3. Third Parties Who May Receive Your Personal Data From Us

We do not have a policy to disclose or transfer your Personal Data to third parties. However, in certain necessary cases, we may need to disclose Personal Data for specific reasons to the following persons or entities:

• Other companies within the VV Retail group, such as Namsinthai Co., Ltd., as these companies support our business operations.
• Our service providers, such as logistics companies, printing companies, outsourced customer service centers, data analytics service providers, sales agents, advertising and marketing event agencies, computer system or software service providers, and cloud computing service providers, for the purpose of facilitating services provided to you.
• Social media service providers, such as Facebook, Google, or Instagram.
• Business partners, such as e-commerce platforms or any other platforms on which we may offer our products or services.
• Government agencies, such as law enforcement authorities, courts, government bodies, or other third parties, where we believe it is necessary to comply with legal obligations, protect our rights, or protect the lawful rights of others.
• Our advisors, such as lawyers, technical specialists, auditors, or other experts, for business operations, the protection of our interests, or the lawful interests of third parties.
• Assignees or transferees of legal rights or obligations, such as in the case of corporate restructuring, merger, or business transfer.

Where these persons or entities act or provide services on our behalf, we will control the use of your data only to the extent necessary and in accordance with the assignment given to such third parties by us. We will also impose data security obligations through data processing agreements and/or appropriate data security assessments.

However, where third parties have the right to use your data independently, we may not be able to control their use of such data. Therefore, please review the privacy policies of the relevant third parties to understand how they collect, use, or disclose your Personal Data.

4. Collection and Processing of Personal Data of Legally Incapable Persons

We may collect information of minors, quasi-incompetent persons, or incompetent persons as part of our normal services. However, if we discover that we have collected or used information of such persons in a manner that cannot be lawfully carried out on any legal basis other than consent, or where such consent is legally ineffective, we will consider immediately ceasing such processing.

5. Retention Period of Your Personal Data

We are required to retain your Personal Data in strict accordance with our internal policies for an appropriate period that does not exceed the principles of legal professional practice, which generally corresponds to the limitation period for legal claims.

After such period, we will delete the data or anonymize it as appropriate in order to prevent potential risks that may arise to you in the future.

6. Data Security

We will make appropriate efforts to protect your data to prevent it from being lost, accessed, destroyed, used, altered, modified, or disclosed without authorization or unlawfully.

We have implemented security measures for Personal Data, including the following examples: (1) Standardized computer systems with valid licenses, kept up to date and capable of supporting appropriate security patches; (2) Enterprise-grade antivirus programs; (3) Multi-factor authentication for systems containing important data; (4) Active Directory systems to control employees’ access rights to computer systems and revoke such rights when an individual ceases to be an employee; (5) Physical security measures, such as identity verification systems before entering data storage areas; and (6) Other measures in accordance with our information security policies.

7. Cookie Policy

When you visit our website, we automatically collect certain information from you through cookie technology. Cookies are generally used to remember details of website visitors or browsing history for application in various situations.

Some cookies are strictly necessary for the website to function efficiently. Other cookies are used to track information about your use of the website and to analyze your website usage behavior.

You may manage your cookie settings through your internet browser. However, refusing the use of cookies may affect the performance of the website and may also affect your service experience, making your visit to or use of our website less convenient.

8. Rights of Personal Data Subjects

Subject to the Personal Data Protection Act, applicable legal exceptions, and the conditions specified by us, you may have the following rights as a Personal Data subject:

• Right of access: You may have the right to request access to or obtain a copy of the Personal Data that we collect, use, or disclose about you.
• Right to rectification: You may have the right to request that we correct the information we have collected about you so that it is accurate, complete, and up to date.
• Right to data portability: You may have the right to receive your data in a structured and electronically readable format, and to send or transfer such data to another Personal Data controller.
• Right to object to processing: You may have the right to object to the collection, use, or disclosure of your data in certain cases.
• Right to restriction of processing: You may have the right to request restriction of the use of your data in certain cases.
• Right to withdraw consent: For purposes where we request your consent before processing, you may withdraw such consent, which will result in us ceasing the processing that relies on your consent.
• Right to erasure: You may have the right to request that we delete your data or anonymize it in accordance with our procedures. We will consider deleting your data as appropriate. However, we may continue to retain your Personal Data for purposes necessary for our business operations, such as compliance with laws or protection of our legitimate interests or those of lawful third parties.

For the privacy and security of your Personal Data, we may request that you verify your identity before we proceed with any request to exercise the rights stated above.

In addition, as certain rights are subject to strict legal conditions, we may need to consider and approve your request on a case-by-case basis.

9. Contact Details

If you wish to exercise your rights as a Personal Data subject, or if you would like to make an inquiry or complaint regarding the use of your Personal Data under this Privacy Policy, please contact us at: pdpa@visionventures.co.th