ABOUT US
BANDRES CO., LTD. is a company that engages in the management of hotels and resorts and investments in Thailand. BANDRES CO., LTD. and its properties (“we”, “us”, “our”) greatly value the importance of personal data protection and treat your personal data with the utmost respect. We have a security system to protect your personal data and an international standard procedure to prevent any unauthorized access, disclosure, use, or alteration of personal data. We reserve the right to change and update this privacy notice at any time.
IN THIS PRIVACY NOTICE
“Properties” means hotels, resorts, amenities, and retail spaces which we own and operate, including but not limited to Naiwok Hills (Koh Phangan) and Sand Terrace (Koh Phangan).
“Personal Data” means any data relating to a person which can be used to identify a specific person, whether by direct or indirect means, but not including the data of the deceased persons or anonymized data.
“Cookies” means a small text file consisting of data parts from a download activity that may be stored in a web browser you use to access websites or applications. Cookies data may be saved on your computer devices or any communication tools that you use to access the web browser while you visit our websites and applications.
PERSONAL DATA COLLECTIONS
We will collect your personal data as necessary for lawful purposes. We may receive personal data through both direct and indirect means in either digital format or physical documents, which can be from properties, social media, event profiles, properties Wi-Fi service, inquiries, government agencies, business partners, and/or other service providers such as open communication platforms or chat applications. We may collect your personal data such as;
• Personal data and your interests such as name, surname, gender, age, nationality, date of birth, marital status, address, monthly income, occupation, workplace, postal code, email address, telephone number, national ID number, passport number, purchase and/or booking history, travel history, guest preferences, interests, likings, survey feedbacks, and preferences of products and services.
• Identifiable image data such as pictures and video of you and/or your belongings that SHR may collect from CCTV cameras and cameras when there is access to properties, office buildings, retail spaces, and areas under SHR’s responsibility during events, meetings, or any seminars;
• Sensitive data such as information related to race, religion, health information (food allergy and disability information), sexual orientation, criminal records and etc. We do not usually collect sensitive data unless it is provided by you for the provision of services or products or to facilitate your stay or unless it is required to do so in accordance with applicable laws. We may use health data to facilitate your stay and meet your particular needs; for example, utilize health data to provide services for guests with certain food allergies or use sexual orientation data to facilitate and improve stay experience, using criminal records to conduct a background check of our service providers, and etc. In the event that we have accidentally received other sensitive data and have no intention to collect such data, we will not further process it;
• Technical data such as websites and/or applications usage and searching behaviors. We may use cookies as a tool to collect IP address, the type of web browser used to access the website, and application, user registration, and login information, visit duration, websites and applications that refer to our websites, and your location data during website or application access;
• Marketing and communication data such as your preferences in receiving marketing material, including contact information, participation in membership, loyalty program, marketing program, frequent flyer or travel partner program affiliation and member number, groups with which you are associated for stays with us, and voice recording when you communicate with Call Center or through other social media channels.
• Minor data such as name, surname, age, gender, parental name, and surname.
We collect, use, and disclose aggregated data, such as statistical and demographic information.
The aggregated data may derive from your personal data; however, such data is not considered personal data since it cannot be used to identify a specific individual. For example, we may use some of your data after the process of anonymization to create statistical information about people who access the website.
We are fully aware that the data used must not be able to revert to identifiable data. If the data is then able to be used to identify a specific individual, it will be considered personal data and will be treated in accordance with this Privacy Notice.
Our websites or applications may lead you to a third-party website and/or application via a link, and other websites and applications may be able to collect, use, or disclose your personal data without our involvement. These services, websites, and/or applications may operate independently from us and may have their own privacy notices and policies. We cannot be held accountable for any collection, use, or disclosure of personal data that occurred on other websites and/or applications. Hence, it is encouraged that you read the privacy notices of every website and/or application you have visited.
PORPUSES OF PERSONAL DATA COLLECTION
In order to conduct business operations, activities, and transactions according to your request and/or to achieve our objectives, we may collect and use your personal data, including but not limited to; the following objectives;
• To allow us to identify you and any accounts you have to proceed with your booking and purchase of our products or services as requested;
• To facilitate your stay, including conducting check-in/out, carrying out pre-arrival communication, providing properties’ amenities and additional services, processing payment, fulfilling your requests, as well as provide you with customized services and experiences;
• To enable you to utilize our websites and applications; including facilitating transactions;
• To carry out the contract you have with us or to process your request prior to entering into the contract, whether it is for term and conditions of products or services, service provider performance evaluation, or any other relevant procedures. If you do not provide your personal data, we may not be able to proceed with your request as notified, or there may be additional legal effects;
• To carry out the contract with the contracting party that we procure or use;
• To comply with the law;
• To serve the public interest or carry out tasks assigned to us by government agencies;
• To carry out our legitimate interests such as maintaining a relationship with you, responding to your request or complaint, sending administrative information, enhancing our business operation standard, and preventing illegal activities;
• To develop marketing plans, conduct data analysis, and market research, assess service by conducting guest satisfaction surveys, analyze market trends and customers’ insights, improve and develop our products or services, and enhance the efficiency of the website and application;
• To provide security in properties, office buildings, retail space, or areas under our responsibilities, using data from CCTV cameras when there is access of such locations;
• To achieve our internal objectives or to conduct public relations for external audiences using both print media and our social medial channels. This activity includes our collection of pictures or video from events, meetings, or any seminars held by us;
• In the event that we receive your explicit consent, we will only use your personal data for purposes you have given consent to, including but not limited to sending marketing communications and promotional offers, facilitating your participation in online promotions and etc.;
• In the event that we collect minor personal data, we will only process it in accordance with the purposes which either the minor or the parent has provided it for, and such data will not be used for any other marketing purpose;
• In the event that we want to process sensitive data for purposes other than for the provision of products and services, we have to obtain your explicit consent before or during the collection of such data.
COOKIES STATEMENT
We use cookies to improve your viewing experience and enhance your satisfaction. The cookies will allow us to understand the website usage and make the website more accessible and convenient. Furthermore, the cookie data will be used to develop our website and application to be more suitable for your needs. Hence, we may need to use cookies for statistical analysis, as well as linking data and processing it according to marketing objectives.
Categories of Cookies
We use various types of cookies categorized as follows;
Strictly Necessary Cookies
Cookies are necessary for website functionality which cannot be switched off. These cookies do not store any personal data and are usually only set in response to actions such as your privacy preferences setting, or actions of logging in or filling in forms. You can set your browser to block these cookies; however, if this category of cookies is switched off some parts of the site will not function.
Performance Cookies
These cookies allow us to count the number of visits and traffic, in order to measure and improve the performance of the website. These cookies’ data is on an aggregate level and thus is not personal data. If you switch off these cookies, we will not know the time of your website visit and will not be able to monitor the website’s performance.
Functional Cookies
These cookies allow the website to provide enhanced functionality and personalization. The setting may be made by us and/or by third-party providers. If you switch off these cookies, then some or all website’s services may not function properly.
Targeting Cookies
These cookie settings may be made by us or our advertising partners. They may be used by those companies to build profile data of your interests, in order to show you relevant adverts on other sites. If you switch off these cookies, you will experience less targeted advertising.
Social Media Cookies
These cookies are set by a range of social media services that we added to the site to allow you to share our content with your friends and communities. These cookies are able to track your browser across other sites and build up a profile of your interests which may impact the content and messages you see on other websites you visit. If you switch off these cookies you may not be able to use or see sharing tools.
Managing Cookies
If you want to remove or block Cookies from your device, you can update your browser settings (go to your browser’s “help” menu to learn how to remove or block Cookies); and we are not responsible for your browser settings. Please keep in mind that if you switch off Cookies, it may affect your ability to perform certain transactions on the website, and our ability to recognize your browser for your next visit.
If you are based in Thailand or Europe, you can also adjust your Cookies preferences through the Cookies Settings on Cookies Consent Manager function.
DISCLOSURE OF PERSONAL DATA
We will keep your personal data confidential and do not have a policy to sell your personal data to a third party. If there is a legal necessity to disclose your personal data, we will only disclose your personal data to an authorized person or party as necessary. However, we may disclose and transfer personal data to a person or party as listed below;
• Our business partners and our authorized representative personnel;
• Service providers include representative companies, travel agencies, contractors, consultants, financial institutions, cloud service providers, online travel agents (OTA) websites, marketing companies, and information technology (IT) development companies.
• Franchise companies of hotels and resorts, joint venture companies, and hotel management companies under a hotel management agreement with us;
• Government or regulatory agencies to comply with law or request of authorized departments.
YOUR RIGHTS
You can submit a request to exercise your legal rights. We will then process your request as soon as possible; however, it also depends on the volume and complexity of the request.
• You have the right to withdraw your consent, and we will stop the processing of your personal data as soon as possible;
• You have the right to access and ask for a copy of your personal data or to request disclosure of how we obtained your personal data without your consent; unless it is when we must comply with the law or court order or the request of access or to receive a copy of your personal data may impact that cause damage to the rights and freedoms of others;
• You have the right to request correction and rectification on your personal data to ensure that the data is correct, up-to-date, complete, and does not cause any misunderstandings;
• You have the right to receive or request us to send or transfer your personal data to another data controller or to directly request the personal data that we disclose or transfer to another data controller; unless it is impossible to do so because the technical circumstances;
• You have the right to request us to erase, destroy, or anonymize your personal data, in the event that such personal data is no longer necessary for the purpose for which it is collected, you have withdrawn your consent or object to the processing of personal data for direct marketing purposes and others, there is unlawful processing, and other scenarios as required by law;
• You have the right to restrict the processing of your personal data. We will stop the processing of personal data; however, the personal data will be stored for the following purposes 1). To establish legal claims, or 2). Personal data is under review for the correctness, or it is in the process of proving higher legitimate ground. Nonetheless, we will only store personal data as necessary;
• You have the right to object to the collection, use, or disclosure of personal data for direct marketing or research purposes either in the field of science, history, or statistics; unless it is necessary for the public interest, higher legitimate ground, the establishment of legal claims, legal compliance, the exercise of legal rights, or to defend the exercise of legal rights;
• You have the right to file a complaint to relevant government agencies in the event that you believe we, our employee, or our business partners violate or do not comply with Personal Data Protection Act (PDPA, Thailand)
MARKETING RELATED ACTIVITY
If you wish to cancel or request not to receive marketing materials or newsletters from our business partners or us, you can proceed to submit your request through our contact channels. However, this cancellation will not affect your ability to receive products or services as addressed in the contract or terms and conditions you have accepted.
SECURITY MEASURES FOR PERSONAL DATA
We understand the importance of data security and treat your personal data respectfully and in accordance with legal requirements. Your personal data is classified as confidential, and we have taken appropriate measures to ensure physical protection and organizational and technical measurements on all organization levels and throughout all the properties to prevent your personal data from loss, misuse, or unauthorized access, disclosure, change, and deletion.
We have set the process to manage the personal data breach incident and will notify you following the law. Nonetheless, despite strict security measures for personal data, there is a security limitation regarding data transmission on the internet. Hence, we cannot guarantee the security of your personal data disclosed online.
PERSONAL DATA RETENTION
We will retain your personal data as part of customer profile information (including contact, identity, financial, and transaction data) for ten years from the booking date. With other categories of personal data, we will retain it for as long as necessary to achieve the purposes we have stated in this Privacy Notice. Your personal data will be kept following our Policy and strict legal requirements.
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