Privacy Policy

Introduction

1. Welcome to HotPlay website run by HotPlay (Thailand) Limited and related corporations (individually and collectively referred to as “HotPlay”, “we”, “us” or “our”). HotPlay seriously takes its responsibilities under Personal Data Protection Act B.E. 2562 of the Kingdom of Thailand along with any other applicable laws, regulations and their future amendment(s) (if any) (“Personal Data Protection Law”) and commits to respect the privacy rights and concerns of all users of HotPlay and our Hotplay website (“Website”) (we will refer the games, Website and the services we provide collectively as the “Service”). We recognize the importance of the Personal Data you have entrusted to us and believe that it is our responsibility to properly collect, use and disclose your Personal Data according to this privacy policy (“Privacy Policy” or “Policy”).

Our platforms may contain links that link to or from websites or platforms of third parties. If you choose to engage the link to access other website, we would like to inform you that your Personal Data will be processed in accordance with the privacy policies specified on that website. We encourage you to read and understand the privacy policies posted on such website once you personally access that platform.

1. “Personal Data” means any information relating to a person, which enables the identification of such person, whether personally directly or indirectly, but does not include the information of the deceased persons in particular.
2. If you do not consent to the processing of your Personal Data as described in this Privacy Policy, we request you to cease the use of our Service and access to our Website. If we change our Privacy Policy, we will post those changes or the amended Privacy Policy on the Website. We reserve the right to amend this Privacy Policy at any time.

Sources of Personal Data.

1. HotPlay will/may collect your Personal Data as follows:
Direct interaction: when you register or open an account on our platform, search for our products or Service on online social media, have a conversation or share comment(s) with us via telephone calls, emails, platforms or online social media as well as when you participate in activities, marketing campaigns or any surveys organized by us;
Personal Data collected from other sources: these sources include third parties (namely business partners, service providers of websites that you access, service providers of applications/ platforms that you have an account with or access, advertising service providers, data processing service providers, search engine service providers, etc.);
In the event where we receive or collect your Personal Data provided by sources other than you directly, we will inform you of such collection within thirty (30) days from the day on which we have collected the mentioned Personal Data. We will make sure that we have received your consent to collect, use and process your Personal Data, unless we are able to rely on any relevant legal basis to justify an absence of the consent.

Collection of your Personal Data by HotPlay

The Personal Data that we collect from you is information which enables the identification of your identity whether directly or indirectly which includes as follows:

1. Personal information such as name; email address; telephone number; information sent by or associated with the device(s) used to access our Services;
2. Details of your requirements and comments towards our platform as well as records of conversation between you and us either in any form or methods such as a phone call, an email, chat massages and communication on the platform or online social media as well as information that you provide to us when you participate in activities, marketing campaigns or any survey organized by us;
3. Technical information such as an Internet Protocol Address (IP Address) which is used to connect your computer to the internet.

Purposes of the processing of the Personal Data

We will collect, use, disclose your Personal Data only if necessary. This includes circumstances where we are obliged to perform in accordance with our regulatory obligations, agreement concluded between you and us and the legitimate interest of HotPlay including an implementation according to your given consent and/or under legitimate ground of other applicable law(s) depending on case by case basis. The detail of how we will use your Personal Data for each purpose is described below:

Purpose / Activity	Type of information	Legitimate power for processing the information and legitimate interest
To confirm your identity or identify you when you use our platform To perform our duty to provide you with information, content, products and services. To identify you and distinguish you from other platform users To track or record your usage on the platform as well as to prepare relevant reports To implement the request(s) you made before you enter into an agreement or a contract with us To consider and approve the provision of service including delivering our products and/ or services to you	Personal information Contact information Social media information	For legitimate interest (For the security of our network and the prevention of fraudulent act) For our legal compliance For the performance under the agreement or contract you have made with us
To improve our Service We may use your information for purpose of improving our Service such as a background check in order to provide and improve products and services and a gathering of your information to create statistical data so as to meet your best interests	Personal information Contact information	For legitimate interest For our Service development
To communicate our obligations and policies We may use your information to inform you about your obligations towards us and any changes of our terms, conditions or Policies. To manage the relationship between us and you (such as, customer care, assessing satisfaction and handling of complaints)	Technical information Contact information Social media information	For legitimate interest For informing you about your obligation towards us and changes of policies) For our legal compliance
Conversation regarding problem solving To notify you or fix problems that may arise in our Service. To manage Interactive function of the platform	Personal information Contact information Social media information	For legitimate interest (Helping you fix problems)
To protect business and platform To manage and protect our business and platform including investigation of any violations of the terms and conditions of using our platform and solving problems regarding analysis of information from testing report-supporting maintenance system and hosting data	Personal information Contact information Technical information Social media information	For legitimate interest (Providing our Service, administrative and IT services, network security and preventing fraudulent act.) For our legal compliance

Since there are certain purposes for which we will/may collect, use, disclose or process your Personal Data subject to situation at that time, hence; such purposes may not be specified above. However, we will notify you and ask for your consent again when there is a purpose which a law specifies that a consent is needed to be obtained from you.

Protection and retention of your Personal Data

1. We implement a variety of security measures and strive to ensure the security of your Personal Data on our systems. User’s Personal Data is contained behind secured networks and is only accessible by a limited number of employees who have special access rights to such systems. However, we cannot guarantee of an absolute security of your Personal Data.
2. In the event that we or you have set a password for you to engage the Service provided on our platform, it is your responsibility to keep the password confidential to prevent other people from unlawfully accessing your Personal Data.
3. We would like to inform you that the transfer of information though the internet is not 100% risk free. However, we will do our best to protect your Personal Data.

Disclosure of the information collected from our visitors to outside parties

In conducting our business, we may need to disclose your Personal Data to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties, whether sited in the Kingdom of Thailand or outside of the Kingdom of Thailand for one or more of the above-stated purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your Personal data either on our behalf or otherwise, for one or more of the above-stated purposes. Such third parties include, without limitation:

Our subsidiaries, affiliates and related corporations;
Other users of our Platform for one or more of the above-stated purposes;
Contractors, agents, service providers and other third parties we use to support our business. These include those which provide administrative or other services to us such as mailing houses, telecommunication companies, information technology companies and data centers.

Information collected by third parties

Our Website and Games use Google Analytics, a web analytics service provided by Google, Inc. (“Google“). Google Analytics uses cookies, which are text files placed on your device, to help the website analyze how users use our Services. The information generated by the cookie about your use of the Services or device (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of our Services, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.

Transfer of your information overseas.

Your Personal Data and/or information may be transferred to be stored in Singapore providing that there will be no other person who can access such information other than us. In most cases, your Personal Data will be processed in the Kingdom of Thailand, where our servers are located and our central database is operated. We will only transfer your information overseas in accordance with Personal Data Protection.

Period for which Personal Data will be stored

We will retain your Personal Data for the duration you remain a user of our platform in order to achieve the purposes set out in this Policy. In addition, we may have to store your Personal Data according to prescription or period specified by a relevant law. The details of the period we will store your Personal Data for each type of information are as follows:

No.	Type/ list of Personal Data	Processing period
1.	Personal Information	5 years form the date you cease the usage of our platform
2.	Details of your requirements and comments towards our platform	5 years form the date you cease the usage of our platform
3.	Technical information	5 years form the date you cease the usage of our platform

We will erase, destroy or anonymize your Personal Data when it is no longer necessary or when the period specified above lapses. If we plan to destroy or delete any of your Personal Data, we will inform you in advance.

Your rights

You may make a request to exercise any of these rights regarding your Personal Data within legal requirements and policies/ regulations at the present or as amended in the future. If you are under 10 years of age or have a limited capacity to do a juristic act, your father, mother, guardian or legal representative may request to exercise the right on your behalf.

1. Right to access and obtain copy of Personal Data: you have right to access and obtain copy of your Personal Data retained by us.
2. Right to rectification: You have right to request correction of or update a not up-to-date, inaccurate or incomplete Personal Data concerning you.
3. Right to erasure: You have right to request us to erase or destroy your Personal Data or anonymize your Personal Data to become the anonymous data which cannot identify you.
4. Right to restrict processing: You have right to request us to restrict the use of your Personal Data when we are in the process of reviewing your request to correct your Personal Data or your objection, as well as in any other event where you request the restriction of the use of your Personal Data instead of deleting or destroying the Personal Data that is no longer necessary.
5. Right to object: You have right to object the collection or disclosure of your Personal Data in the circumstances where the collection or disclosure is carried out under legitimate ground or for direct marketing purposes or for scientific, historical or statistical purposes.
6. Right to data portability: You have right to receive your Personal Data that we have arranged it in the format which is readable or used by ways of automatic tools or equipment and can be used or disclosed by automate means. You are also entitled to request us to directly send or transfer your Personal Data in such format to other data controller unless it cannot be done due to technical reasons.
7. Right to withdraw consent: If you have given us a consent to collect, use and/or disclose your Personal Data (whether before or after the effective date of the Personal Data Protection law), you have right to withdraw your consent at any time throughout the period your Personal Data available to us. The withdrawal must be made according to the format that we have set unless there is a legal restriction to the right or you are still under beneficial contract.

Withdrawal of your consent will not affect the collection, use or disclosure of your Personal Data that we have done according to your given consent. The withdrawal may affect your use of our platform. For example, you may not receive privileges, promotions, news or new offers, products or service that are enhanced and consistent with your needs or not you may no longer able to use our platform, etc. Therefore, after we receive you request to withdraw the consent, we will notify you the potential consequences of withdrawing your consent for you to reconsider your withdrawal.

1. Right to lodge complaint: You have right to complain to competent authorities pursuant to relevant laws (such as Office of the Personal Data Protection Committee or the Personal Data Protection Committee) if you believe that the collection, use and/or disclosure of your Personal Data is violating or not in compliance with relevant laws.

The exercise of rights listed above may be restricted under relevant laws and it may by necessary for us to deny or not be able to carry out your requests, e.g. to comply with laws or court orders, public tasks, your request in breach of rights or freedom of other persons, etc. If we deny the request, we will inform you of the reason.

Any request made pursuant to the right as described above must be made in writing according to the format we have set. We will use our best effort to take action and clarify within 30 days or not exceeding the period specified by law.

Additional provision for EU users only

1. The provisions in this Section only apply if you are a user who is located in the European Union (“EU”). These provisions take precedence over any inconsistent provisions in the remainder of this Privacy Policy.
2. Portability

You have the right to obtain from us the Personal Data that you have previously provided to us, and which we process on the basis of your consent in a structured, commonly used and machine-readable format and a right to request that we transfer such Personal Data to another party. If you wish for us to transfer the Personal Data to another party, please ensure you detail that party and note that we can only do so where it is technically feasible. We are not responsible for the security of the Personal Data or its processing once received by the third party. We also may not provide you with certain Personal Data if providing it would interfere with another’s rights (e.g. where providing the Personal Data we hold about you would reveal information about another person).

1. Erasure

You may request that we erase the Personal Data we hold about you in the following circumstances:

you believe that it is no longer necessary for us to hold the Personal Data we hold about you;
we are processing the Personal Data we hold about you on the basis of your consent, and you wish to withdraw your consent and there is no other ground under which we can process the Personal Data;
we are processing the Personal Data we hold about you on the basis of our legitimate interest and you object to such processing. Please provide us with detail as to your reasoning so that we can assess whether there is an overriding interest for us to process and retain such Personal Data;
you no longer wish us to use the Personal Data we hold about you in order to send you promotions, special offers, marketing and lucky draws; or
you believe the Personal Data we hold about you is being unlawfully processed by us

Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. However, we may retain the Personal Data if there are valid grounds under law for us to do so (e.g., for the defense of legal claims or freedom of expression) but we will let you know if that is the case. Please note that after deleting the Personal Data, we may not be able to provide the same level of servicing to you as we will not be aware of your preferences.

1. Retention of Personal Data

We retain your Personal Data as long as needed to provide services or products to you, or as required or permitted by applicable laws, such as tax and accounting laws. If you make a request for erasure of your Personal Data 3 and we determine that there is a valid basis for your request, we will endeavor to erase the Personal Data within 30 days of your request, or inform you if it will take longer.

1. Objection against Profiling and Direct Marketing

At any time you have the right to object to our processing of Personal Data about you in order to send you promotions, special offers and marketing messages, including where we build profiles for such purposes and we will stop processing the Personal Data for that purpose. Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for objection. However, we may retain the Personal Data if there are valid grounds under law for us to do so.

1. Restriction of Processing to Storage Only

You have a right to request that we restrict the processing of the Personal Data we hold about you to storage purposes only, where;

You believe the Personal Data is not accurate, for the period it takes for us to verify whether the Personal Data is accurate;
We wish to erase the Personal Data but you want us to just store it instead;
We wish to erase the Personal Data as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defense of legal claims; or
you have objected to us processing Personal Data we hold about you on the basis of our legitimate interest and you wish us to stop processing the Personal Data whilst we determine whether there is an overriding interest in us processing and retaining such Personal Data.

1. Transfer of Personal Data outside the EU

Your Personal Data may be transferred outside of the EU. We take appropriate steps to ensure that recipients of your Personal Data are bound to duties of confidentiality and we implement measures such as appropriate contractual clauses to ensure that the recipients of such transfer protect and treat your Personal Data in accordance with all applicable personal data protection laws.

1. Information on children

The Services are not intended for children under the age of 16 who are located in the EU. We do not knowingly collect or maintain any personal data or non-personally-identifiable information from anyone under the age of 16 who is located in the EU, nor is any part of our Website, Games or other services directed to children under the age of 16 who are located in the EU. We will close any accounts used exclusively by such children and will remove and/or delete any Personal Data we believe was submitted by any child under the age of 16 who is located in the EU.

Marketing Media

We and our business partners may send marketing, advertising and promotional information through in-application notification, post, phone call, short message service (SMS), email and/or other messaging applications (“Marketing Media”) to you and/or your parents, guardians or legal representatives. In the event that you agree to subscribe in a contract list and/or accept to receive marketing and promotional media from us, you may opt-out of sending of such media in accordance with the format and channels that we set at any time. We would like to inform you that if you choose not to receive such media, we will still be able to send messages that are not marketing and promotional related to you.

Changes to this Policy

If we have done any amendments/ changes to our Privacy Policy, we will announce the changes on this page. Please occasionally revisit and read content on this page for an update of changes to our Privacy Policy. In case of material changes, we will notify you of the changes as soon as possible.

Contact us

If you have any inquiries about our Privacy Policy or wish to exercise your rights under this Privacy Policy or send any complaint regarding processing of your Personal Data by us, please contact us at [email protected] or Tel 02-150-0577 or our head office address: 656, Soi Sukhumvit 50, Sukhumvit Road, Khwaeng Phra Khanong, Khet Khlong Toei, Bangkok 10260