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Privacy Policy

EFFECTIVE FROM 1ST JUNE 2021

Neo Corporate Public Company Limited is located at 888 Soi Sukhumvit 54, Sukhumvit Road, Phra Khanong Tai, Phra Khanong Bangkok 10260 and other brands under Neo Corporate Public Company Limited  (“we” or “our”.) Neo Corporate Public Company Limited operates the business of manufacturing, marketing & distributing consumer products under our product brands in the total of 8 brands including Eversense, Tros, Fineline, D-nee, Vivite, BeNice, Smart, Tomi, of which can be divided into 3 product categories as below:

1) Household Products: consisting Fabric Care Products under Fineline and Smart, and Household Cleaning Products under Tomi.

2) Baby & Kid Products: consisting Cleaning Products, Showering Products, and Skin Nourishing Products for toddlers and kids under D-nee.

3) Toiletry Products: consisting Showering Products, Deodorant Products, and Hair Grooming Products under BeNice, Tros, Eversense and Vivite.

We respect your privacy concerns and value good relationship between you and us. As referred in this Privacy Policy, Personal Data means any information about an individual that identifies or makes that person identifiable. This includes all information that enables the identification of an individual whether directly or indirectly (“Personal Data”.) This Privacy Policy sets out the types of Personal Data we collect, use, disclose in relation to our customers; how we may process Personal Data; the persons with whom we may share Personal Data and the choices our customers may make regarding our use of such information, having the following details:

01. Personal Data Collected

02. Personal Data You Provide

03. Guidelines for the Use of Personal Data

04. Personal Data We Collect by Automated Means

05. Technologies We Use, Cookies, Web Server Logs

06. Third Party Web Analytics Services

07. Targeted Advertising

08. The Use of Personal Data Collected by Automated Methods

09. Push Notifications and Alerts and Updates within the Application or Website

10. Personal Data We Share

11. Your Right and Choices

12. Data Transferring

13. How We Protect Personal Data

14. Links to Other Websites

15. Updates to the Privacy Policy

16. How to Contact Us

17. Conflict between English and Thai

01. Personal Data Collected

As your Personal Data is collected on the websites, we may obtain your Personal Data from several sources or may collect this Personal Data when you display such Personal Data on or through our websites; when you access and/or use our social media/social network sites. (or related platforms or mobile applications for such social media such as Facebook, Instagram, etc.); when you visit one of our stores or attend an event; or when you join our loyalty program or apply our membership program. Even though our products are sold in department stores, supermarkets, convenience stores, top shops, shop for beauty products, online stores, any Personal Data collected in such department stores, supermarkets, convenience stores, top shops, shop for beauty products, online stores will not be sent to us. Additionally, this Privacy Policy does not cover any data collection done by our retail partners. When you visit our applications, websites, social media/social network sites (or any related platform or mobile applications for such social media) or when you use the services or any feature of one of the mobile applications or through our websites, we may collect certain information regarding your devices or use by automated means or by technologies such as cookies, web server logs, and web beacons.

02. Personal Data You Provide

You can provide us Personal Data in a number of ways, such as when you participate in an offer or promotion or when you shop at our store in a department store, supermarket, convenience store, top shop, shop for beauty products, online store, at our store or on our website, through our social media/social networking sites (or related platforms or social mobile applications have such media) or through one of our mobile applications. The types of Personal Data you provide to us (if any) shall include:

• Username and Password;

• Contact information (e.g., Name-Surname, address, E-mail Address and mobile telephone number or any other telephone numbers, mobile phone service provider);

• Age and Date of Birth;

• Nationality, gender, and main language;

• Payment information; any information that is required for processing a purchase order or information you use for placing a purchase order, such as debit or credit card information (cardholder name, card number, expiration date, CVC, etc.) or other forms of payment (if any). In any case, we or our payment service providers will handle payment and financial information in a legal manner, security regulations and standards;

• Tax invoice information (e.g., tax ID number, delivery address, and address for issuing tax invoices);

• Order history;

• Contact information of a friend or other person you would like us to contact (under circumstances where you have obtained necessary consent from such person for our use of such information);

• Favorite products and your preferred communication channels;

• Content created by you (such as photos, videos, reviews, articles, survey responses, and comments);

• Information provided to us when you visit our social media sites or use one of our social networks or mobile applications (e.g., name, profile picture, likes, locations, friends list and other information displayed on the website or social media);

• Network, or sign-up page to use the application, or your geographic location information when you use one of our mobile applications;

• Account number for your membership or loyalty program

Providing your Personal Data to us is voluntary. If you do not provide us with your Personal Data as stated above, you may not receive any or all of our services and promotions described in this Policy, partly or wholly, as for the guidelines for the use of Personal Data.

03. Guidelines for the Use of Personal Data

To the extent permitted or required by applicable law, we may use your Personal Data for the following purposes:

• Communicate with you in connection with the services, customer service, quality control of the services, follow-ups or purchase order confirmation, appointment, product return, or refund of payment, through e-mail, telephone, short message (SMS), or other communication channels;

• Provide services according to your purchase order and to manage subscriptions and registrations;

• Manage the services provided to you and answer your questions;

• Send to you promotional materials or other communications;

• Provide the requested information and services to you;

• Send to you the communications other than marketing communications in relation to the products and services provided to you;

• Process your payment and/or gift card transactions;

• Create and manage your account, including having access to your order history made through online channels and storefront;

• Provide assistance regarding the selection and replenishment of your product, including through our customer registration channels;

• Manage our membership list and loyalty program list (if any);

• Customize advertisements on our websites and social media platforms and other places to match your interests and order history;

• Communicate with you and manage your participation in special events, contests, lucky draws, other programs (such as loyalty programs (if any)), inquiries, other offers including giving benefits and privileges;

• Manage, evaluate and improve our business (including developing or introducing new products and services; optimize and improve our products and services; manage our communication; analyze our products; do market research; data analytics and customer relationship management program and accounting; auditing; and other roles within the organization);

• Additionally, we may also use the information in other ways for which we will specifically notify to you about such use of the data at the time of collection.

However, we will not use your Personal Data for such purposes; except when we have obtained your consent to use such information for the purposes for which we intend to use it. We will be able to take all types of Personal Data listed in Section “Personal Data You Provide” and used it for direct marketing only when you have provided such Personal Data to us and you have given express consent, in writing or in electronic form, to use such information. We will not be able to use your Personal Data for direct marketing purposes, except when we have lawfully asked for your consent in accordance with the requirements of the applicable law. Direct marketing communications may be sent to you through various channels, including by phone, postal service, email, short message, via mobile phone applications, online applications, social media platforms and other online channels.

Neo Corporate Public Company Limited (“we” or “our”) is the supervisor and the distributor of the products under the names: Eversense, Tros, Fineline, D-nee, Vivite, BeNice, Smart, Tomi, and the company that operates www.neo-corporate.com, the leader of Thai consumer products, and a well-known brand owners, i.e., Eversense, Tros, Fineline, D-nee, Vivite, BeNice, Smart, Tomi. For more details about us and our brands through connecting with you, when you register for opening an account or joining a program with us (such as a membership account, loyalty program, etc.) or when you receive services from us in addition to the interactions you may have with the brands you have contacted in the first place, you may also be invited by the brands (i.e., we invite you) to sign up for marketing news of our several other relevant brands which are presented by us. After obtaining your consent, any Personal Data that you have provided in the form or Personal Data that you have provided at the time you had given your consent to register for such news will be used by us simultaneously for such marketing purposes. The handling of any transfer of information by us as referred to in this paragraph will be in compliance with the terms set forth in this Privacy Policy.

Unless specified by the applicable law, if you are not of legal age, it is required that consents from both you and your parent/legal guardian must be obtained. We do not intend to collect Personal Data of an underage person under the age of 13. If you do not wish us to use your Personal Data for direct marketing, you may opt-out of receiving direct marketing at any time by following the steps outlined in Section “Your Rights and Choices” below. We will stop using your Personal Data in direct marketing if you request so. No cost will be collected from you and we will use Personal Data obtained from you for direct marketing purposes only in accordance with the provisions of the Personal Data Protection Act of Thailand (“Personal Data Protection Act”).

04. Personal Data We Collect by Automated Means

When you visit this website or click on our online advertisements (including our advertisements on third party websites); visit our social media/social network sites; (or related platforms or mobile applications for such social media), we will collect certain information about your use or your devices by automated means or using technologies such as cookies, web server logs and web beacons. For example, if you use one of our mobile applications, we may collect your IP address, your device identification number (or other serial numbers), and/or geographic location information in order to offer you certain features or functions within such mobile applications. Moreover, we may also collect information about your use and web browsing habits by using technologies that work on the website. And as for your convenience, our mobile phone applications and social media/social network sites may also have functions that allow you to remain logged in to such applications, so that you do not have to re-enter your password each time you want to access the applications. If you choose to remain logged in, you must be aware that anyone who has access to your mobile device will be able to access and make changes to your mobile phone account and the purchases can be made through your account. For this reason, if you choose to remain logged in to the applications on your mobile phone, we strongly recommend that you enable the password lock security feature on your mobile device to prevent unauthorized access and use of your mobile device and user account in the applications.

05. Technologies We Use

Cookies, web server logs, web beacons, and location technologies

• “Cookies” are small pieces of data or text files that a website sends to your browser. These are then stored on your computer's hard drive as a tag that helps identify your computer. Cookies remember information about your activities on the websites to make your website visits smoother and more valuable by providing a personalized experience and remembering your preferences when you visit our websites. Your browser may tell you how to set a notification when you receive certain cookies and how to limit or disable some cookies. If you choose to disable cookies on your browser, this may cause some functions of our websites to be lost.

• “Flash cookies” (also known as Local Shared Objects (LSOs)) are data files similar to cookies, unless Flash cookies store more complex information. Flash cookies are used to remember settings, preferences, and use, especially for videos, interactive games, and other similar services.

• “Web server logs” are computer-generated activity logs. This will send the web page you requested to your browser. For example, the web server log may record the search terms you enter or the link you clicked. The web server log may also record information about your browser, such as the IP address of the device you use to connect to the Internet, operating system type, browser type, domain, cookies that the server sets on your browser, the language your system uses and the country and time zone where your device is located.

• “Web beacons”, “clear pixels” or “pixel tags” to control which web servers collect this information. We may place tags on our web pages, called “web beacons.” “Web beacons” are computer instructions that link a web page to a specific web server and its cookies. A web beacon is a small graphic image placed on a web page or email. This can be used for purposes such as saving web pages and advertisements that users click on or tracking results of email marketing campaigns.

• “Location Technology” Location technology refers to the technology that allows us to determine your location. We may ask you to manually provide information about your location on our website or request that your mobile device be enabled to send us your precise location. Moreover, we may also automatically collect general location information from your web browser.

06. Third Party Web Analytics Services

We may use third-party web analytics services on this website. Our social media/social network sites (or related platforms or mobile applications for such social media) or our mobile applications such as the Adobe Site Catalyst web analytics service and/or Google Analytics and/or Pixel by Facebook. The service providers that administer these services will use technologies such as cookies, web server logs, and web beacons to help us analyze how visitors use the websites. Information that is collected through these methods (including IP addresses) will be disclosed to the service providers which will use the information to evaluate the use of the websites. You may disable these analytics services, which analyze your browsing activity on this website. If you would like to know more about web analytics services, your right to choose in relation to the collection of information of such services on the websites are as follows:

• Google Analytics: Please download a browser extension that disables Google Analytics as a service provided by Google. Visit http://tools.google.com/dlpage/gaoptout?hl=en

• To learn more about privacy and Google Analytics, please visit the Google Analytics overview provided by Google by visiting http://www.google.com/intl/en/analytics/privacyoverview.html

• For more information about Facebook Pixels, please visit www.facebook.com/pixels. https://www.facebook.com/business/help/1178675675606697?id=2042840805783715

07. Targeted Advertising

We may contact and/or enter into a contract with third-party advertising networks that collect IP addresses and other information through the use of web server performance log cookies, web beacons on the websites, our email on the websites, third-party email, and on our advertisements placed on third-party websites. Those third-party advertising networks will use this information to provide advertisements about products and services tailored to your interests. (This includes advertising for companies that are not related to us). You may see these advertisements on our websites and other websites. Also, we have used certain advertising features of Google Analytics. You can opt-out of using Google Analytics advertising features through your Google Ad settings or by visiting https://tools.google.com/dlpage/gaoptout/. We will use the information provided by the Google Analytics Demographics and Interests Reporting feature as set forth Section “ The Use of Personal Data Collected by Automated Methods.” To disable cookies of other third-party web analytics providers, some browsers will notify you when cookies are sent. This will allow you to opt out of the use of cookies on a case-by-case basis. You can also disable cookies in your browser. Additionally, we may also use third-party platforms including platforms managed by social networks such as Google, Facebook, Youtube, Instagram, LINE, etc., to serve interest-based advertisements. We may convert e-mail addresses, phone numbers or other information of yours into a specific number which allows such third parties to match it with the users on their platforms or match it with other information that may be collected from you. Such matching allows interest-based advertisements to be delivered to the platforms. To opt out of receiving these advertisements, you will need to change your advertisement setting and preferences on such third-party platforms. These platforms may have their own privacy notices or policies, of which we highly recommend that you review it.

08. The Use of Personal Data Collected by Automated Methods

We may use information collected by automated means on this website for market research purposes, data analysis and system administration; for example, to identify whether you have visited our website before or recently visited our website for the first time, to tailor the advertisements shown to you on our websites and elsewhere according to your interests and browsing history, and to comply with our duties, policies and legal practices including compliance with relevant industry standards and the enforcement of our terms and conditions.

09. Push Notifications and Alerts and Updates within the Application, Websites, Social Media

When you visit the websites, we may give you the option whether to receive push notifications from us on your mobile device from such mobile applications or websites. This push notification may include communications to promote our products and services. After downloading a mobile application or launching a social media site and related social media, you may opt out of receiving push notifications by adjusting the settings on your mobile device or your account on our system. Opting out of receiving push notifications will not affect any other communications you receive from us such as communication through e-mail and/or websites. Moreover, you may also receive alerts and updates from our mobile application and/or websites, regarding our products and services, or your account opened with us, or disable the websites and clear the history of related browsing websites on your mobile device.

10. Personal Data We Share

We will not lease out, sell or otherwise disclose (except as set forth in this Policy) your Personal Data collected by us, this will allow such third parties to direct marketing to you. However, we may share your Personal Data with the following persons:

• Our affiliates (including other brands owned by us and/or our affiliates whether in the present or in the future which is under Neo Corporate Public Company Limited for the purposes described in this Privacy Policy or as other provided in the notices made at the time of collection. To know more about our affiliates, you can visit us at www.neo-corporate.com.

• Service providers, licensees, partners and/or joint venture companies which may have locations domestically and internationally and such persons may provide services on our behalf in accordance with our instructions and send to you direct marketing information about products and services. We will not allow these service providers to use or disclose the information; except to the extent necessary to provide services on our behalf, or in order to comply with legal requirements such as credit card payment processors, purchase order processing, and web hosting provider, advertising and marketing services.

• Other third parties, through social networks, widgets and plug-ins. If you use any of the features that third parties make available to you on our websites, that may result in the collection or sharing of information between us and such third parties.

• In the case that we need to share your Personal Data with third parties for the purposes of performing the above-mentioned purposes on our behalf, we will ask such third parties to apply equal or more strict privacy practices to the handling of Personal Data. We may not be able to offer you certain services or benefits, if you do not consent to sharing your information.

11. Your Right and Choices

To change your selection, ask us to remove your information from the mailing list, or submit a request, please contact us as detailed below:

• Unsubscribing from Emails: You can tell us to stop sending you marketing communications via email at any time by clicking on the unsubscribe link contained in the marketing emails you received from us, or by contacting us using the details provided in Section “How to Contact Us” below. You can also unsubscribe from receiving marketing emails from Neo Corporate or its affiliated brands by sending an opt-out request to customerservices@neo-corporate.com

• Cancellation of Receiving Documents by Post: You can request Neo Corporate or its affiliated brands to stop sending you marketing communications via postal service by following the procedures that may be included in our postal promotional materials. You can also request that we stop sending you promotional materials via postal service by sending a request for cancellation of receipt of documents by via postal service to customerservices@neo-corporate.com .

• Showing your Location: When you use one of our mobile applications, your geographic location information may be requested through that mobile application. You may opt-out of sharing your geographic location details by adjusting the location services settings on your mobile device to opt out of sharing your geographic location. Please follow the instructions on your mobile device regarding the change of the relevant settings or contact your carrier or mobile device manufacturer.

• Withdrawal of Consent: Except where consent cannot be withdrawn due to any restrictions of the applicable law, you may withdraw any consent you have previously given to us or object to the processing of your Personal Data at any time, which must be supported with a legitimate cause. We will comply with your choice accordingly. In some situations, withdrawal of your consent to use or disclose your Personal Data means that you will no longer be able to take advantage of some of our products or services.

• Review, Update, and Rectification of Personal Data: Subject to the applicable law, we may retain and use your Personal Data for a period of 10 years. You may have the right to request to access and/or receive details about your Personal Data we hold; request a copy or request a transfer, update and rectify inaccuracies of your Personal Data; request blocking, deletion, destruction of Personal Data or remove any identifiable information from your Personal Data; or limit and/or object to certain activities we do in connection with your Personal Data, as appropriate. The right to access to Personal Data may be limited in certain circumstances pursuant to the national law. We may take reasonable steps to verify your identity before granting you access to your Personal Data or correcting your Personal Data. You may request to exercise such rights by contacting us by sending an email to customerservices@neo-corporate.com addressing to our Personal Data Protection Officer. To the extent allowed by the applicable law and your request is in accordance with the requirements of the law, we will grant you the rights permitted by law. Additionally, you also have the right to lodge a complaint with a competent personal data protection supervisory authority under the applicable law.

12. Data Transferring

We may transfer your collected Personal Data to markets/countries other than the markets/countries in which it was originally collected and your Personal Data may be processed and stored outside of your market/country of residence. You understand and agree that the destination markets/countries may or may not have adequate standards for the protection of Personal Data. These markets/countries may not have the same data protection laws as the market/countries to which you initially provided information. When we transfer your Personal Data to other markets/countries, we will protect your Personal Data as described in this Privacy Policy.

13. How We Protect Personal Data

We ensure that there are appropriate administrative, technical, and physical protective measures which are designed to protect Personal Data obtained from you from accidental destruction, loss, alteration, access, disclosure, transfer or use unintentionally, illegally, or without permission. However, no security system is perfect and we cannot promise that your information is safe in all circumstances, which shall include the security of your information during transmission to us, or the security of your data on your mobile device.

14. Links to Other Websites

Our websites may display links to other websites for your convenience and information. These websites operate independently, not affiliated with us. Websites linked through the links may have their own privacy notices or policies of which we highly recommend that you review it if you would like to visit any linked websites. As the linked websites you visit are not under our ownership or control, we will not be responsible for the content of such websites, the use of such websites, or the privacy practices of such websites.

15. Updates to the Privacy Policy

This Privacy Policy may be updated from time to time without providing a prior notice to you. In order for you to review changes to our privacy practices regarding Personal Data, we will post a clear notice on our websites to notify you of any material changes to our Privacy Policy and indicate at the beginning of the Privacy Policy of the date of the latest update of the Privacy Policy.

16. How to Contact Us

If you have any questions or comments about this Privacy Policy or if you would like us to update the information we have about you or your choices, please contact us via email at customerservices@neo-corporate.com or by phone at +66 (0) 2 017 8900.

17. Conflict between English and Thai

If there is any conflict between the Thai version and English version of this Privacy Policy, the Thai shall prevail.