For the purpose of complying with the Personal Data Protection Act B.E. 2562 (2019) and subordinate laws issued thereunder, including any amendment which may be made thereto, (“Laws on Personal Data Protection”), Chanintr Living Limited and its subsidiaries (“CHANINTR”, “us”, “we” or “our”) have prepared this personal data privacy notice for processes related to customers of CHANINTR (“Privacy Notice”) to inform you regarding how CHANINTR handles information which can or may identify you, whether directly or indirectly, according to the Laws on Personal Data Protection (“Personal Data”), for instance, the methods by which Personal Data is collected, used, disclosed or dealt with, whether by manual or automated means, such as recording, organization, storage, adaptation or alteration, retrieval, sending, transfer, disclosure or making available by any means, sorting, combination, restriction on or prohibition of access, erasure or destruction (“Processing”, “Process”, “Processes” or “Processed”), as well as to notify you of the purposes for such Processing, the retention period of Personal Data and your rights as the data subject. In this regard, CHANINTR recommends that you read and understand the following terms under the Privacy Notice.

Under the Privacy Notice, CHANINTR means any one or more of the following companies:

• Chanintr Living Limited;
• Chanintr Living (Thailand) Limited
• Chanintr Systems & Solutions Limited;
• Anilaphat Limited; and/or
• Priewpayom Limited.

Furniture

CHANINTR, the company in which Spruce is under, began as a furniture importer, launching in Bangkok in 1994 with the brands Baker and McGuire. We were drawn to their shared approach to living — one of relaxed luxury that we were surrounded by while growing up in America. But it was their commitment to quality, attention to craftsmanship and grace of their service — placing importance on relationships with those they work with — that we wanted to share with our customers.

Over the past two decades, our business and our family of brands have grown but our approach has remained constant. Quality and service are still part of everything we do. We consider every detail, from fitting a joint to furnishing a full apartment, and believe that relationships extend beyond the first interaction. They last a lifetime.

These values have informed our understanding of the home and how we help to build it. Through our brand partners, which produce everything from furniture to fixtures, and our services, which range from styling and consultancy to full-service interior architecture and design, we endeavor to create spaces that exceed expectations. At CHANINTR, we believe in living well, in the everyday and in the most special moments.

For more information, please visit: www.chanintr.com

If you have any questions or would like to exercise your rights as set out in this Privacy Notice, you may contact CHANINTR using the contact details provided below:

CHANINTR

E-mail: info@chanintr.com

Address: 110 Soi Sukhumvit 26, Khlong Ton, Khlong Toei, Bangkok, Thailand 10110

Phone: +662 015 8888

Data Protection Officer

E-mail: dpo@chanintr.com

Address: 110 Soi Sukhumvit 26, Khlong Ton, Khlong Toei, Bangkok, Thailand 10110

Phone: +662 015 8888

Under this Privacy Notice, groups or categories of persons from whom CHANINTR collects and Processes Personal Data are as follows:

3.1 Customers

Customers which means persons who purchase products and/or use services of CHANINTR or those who are expected to purchase products and/or use services of CHANINTR (prospective customers), or any other persons having similar characteristics, such as business operators that purchase products and/or use services of CHANINTR, participants in the marketing activities, including competitions and campaigns, gift voucher recipients, website users, persons who make contact to request to receive information or services from CHANINTR, and persons who provide responses to surveys concerning the products and/or services of CHANINTR, etc.

3.2 Persons related to customers

Persons related to customers which means persons who are related to or are representatives or personnel of juristic persons that are the customers or may become the customers of CHANINTR, such as directors, executives, employees, staff, representatives or personnel of customers who are juristic persons, including persons whose Personal Data appear in relevant documents and processes, such as witnesses, purchasers, consignees and cheque payers, etc.

CHANINTR is not directed and intended for Processing of Personal Data of anyone under the age of 20 (“Minors”). Please do not allow your Minors to submit Personal Data to CHANINTR. We do not knowingly collect Personal Data from anyone under the age of 20. If you are a parent or guardian and you are aware that your Minors have provided us with Personal Data, please contact us by using the contact details set out in Clause 2 of this Privacy Notice. If we become aware that we have collected Personal Data of Minors, we take steps to remove that Personal Data from our possession and storage.

Your Personal Data that is collected and Processed under this Privacy Notice, regardless of whether such Personal Data was directly provided by you to CHANINTR or automatically collected from you by CHANINTR, or was provided to CHANINTR by other sources or third parties, includes the following:

5.1 Persional information

Personal information, such as first name, last name, gender, date of birth, identification number, passport number, photograph, occupation and signature, etc.

5.2 Contact information

Contact information, such as type of residence, address, mailing address, delivery address, telephone number, fax number, e-mail, and user IDs and accounts for various applications for communications or other social media (e.g., Facebook, Twitter, LINE and Instagram), etc.

5.3 Customer business information

Customer business information, such as name and address of the company you are affiliated with, and position, etc.

5.4 Information concerning transaction

Information concerning transaction, such as transaction data, photos of installation place, schedule of works, drawing, customer code, purchase amount, bank account details, Personal Data which appears in the invoice, tax invoice and receipt, and details of complaints concerning products and services (e.g., date of order, type of product, relevant branch and the problem that is found), etc.

5.5 Information that is used as supporting evidence for the execution of transactions

Information that is used as supporting evidence for the execution of transactions, such as Personal Data which appears in a copy of the national identification card, copy of passport, power of attorney, copy of company affidavit, copy of bank account, map, and sale and purchase agreement or any other agreements relating to the transaction, etc.

5.6 Sensitive personal data

Sensitive personal data, such as religion, and health data including body temperature, etc.

5.7 Technical information

Technical information, such as log file, IP Address, browser type, browser version, the pages of our service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data, and information that CHANINTR collects through the use of Cookies or other similar technologies, etc.

5.8 Other information

Other information, such as preferred brands, interested products and services, behaviors or trends to purchase products and/or services, photo and video recording by means of CCTV, and record of visitors including license plate number and time in and out, etc.

6.1 CHANINTR collects and receives your Personal Data via the following methods:

(a) Personal Data which you directly provide to CHANINTR

You may directly provide your Personal Data to CHANINTR, such as:

• When you contact, inquire, express an opinion or comment, submit a complaint to CHANINTR, whether in written or oral communications by face-to-face interaction or by contact at the place of business of CHANINTR, or by any other channels, such as by telephone, fax, e-mail, mail, website, application for communication or any other media platforms;
• When you express an intention to purchase products or use services of CHANINTR, enter into a contract with CHANINTR or deliver documents containing Personal Data to CHANINTR; and
• When you participate in marketing activities, competitions, campaigns, events or any other activities organized by or on behalf of CHANINTR, etc.

(b) Personal Data which CHANINTR automatically collects from you

CHANINTR may collect your Personal Data by automated means, such as the use of Cookies or other similar technologies. For more details, please see our Cookie Policy.

(c) Personal Data which CHANINTR receives from other sources or third parties

CHANINTR may receive your Personal Data from other sources or third parties, such as:

• In case the customer is a juristic person, CHANINTR may receive your Personal Data from contact persons, representatives or personnel of the juristic person that you affiliated;
• Business partners or service providers of CHANINTR, such as digital payment platform operators, food delivery platform operators, POS restaurant management system operators, delivery service providers, website service providers, application service providers, property developers, designers, interior design and decoration companies, and suppliers, etc.;
• Designers and interior design and decoration companies that you have contacted or engaged;
• Companies under CHANINTR;
• Government agencies, such as Department of Business Development; and
• In some cases, CHANINTR may collect your Personal Data from public data sources, data sources containing information relating to your business or sources containing information relating to trades, irrespective of whether you have disclosed the Personal Data by yourself or have provided consent to somebody else to disclose such Personal Data, etc.

6.2

In collecting your Personal Data, you will be informed of the details as set out in this Privacy Notice, including but not limited to, the purposes and lawful bases for the collection, use, disclosure and/or Processing of Personal Data, or in the event that the Laws on Personal Data Protection require your consent for any Processing of Personal Data, CHANINTR will explicitly request your consent.

6.3

Where CHANINTR has previously collected your Personal Data before the Laws on Personal Data Protection have become effective, CHANINTR will continue to collect and use your Personal Data in accordance with the original purposes of collection. Nevertheless, after the Laws on Personal Data Protection in respect of the collection, use or disclosure of Personal Data have taken effect, if you do not wish for CHANINTR to collect and use your Personal Data and if CHANINTR has relied on your consent as a basis in Processing your Personal Data, you may contact CHANINTR using the contact details set out in Clause 2 of this Privacy Notice to request for the withdrawal of your consent. To this end, CHANINTR reserves the right to consider your request for the withdrawal of consent and proceed in accordance with the Laws on Personal Data Protection.

7.1 CHANINTR Processes your Personal Data for the purposes under lawful basis as follows (collectively, the “Purposes”):

(a) For the purpose of verifying the identification of customers or persons related to customers.

• Legitimate interests basis: The Processing of Personal Data of the customers or persons related to the customers is necessary for the legitimate interests of CHANINTR in verifying the identification of such persons, such as verifying the identification prior to granting award in a marketing activity.

(b) For the purpose of creating accounts for customers.

• Legitimate interests basis: The Processing of Personal Data is necessary for the legitimate interests in operating business or complying with CHANINTR’s policy, or in case where the customer is a juristic person, the Processing of Personal Data of persons related to the customer is necessary for the legitimate interests in operating business or complying with CHANINTR’s policy, such as the record of history and transaction data (customer’s account or AR code), etc.

(c) For the purpose of managing customer orders, providing contracts, and performing obligations under the contract between CHANINTR and customers.

• Contractual basis: The Processing of Personal Data of the customers is necessary in executing the request of the customers before entering into contracts, providing the contracts and perform the obligation as stipulated in the sale and purchase agreements, service agreements and rental agreements where the customers are contracting parties, such as quotation, interior design, delivery, shipping, installation, repair, exchange, returning products, refund, billing and delivery of receipts to the customers, etc.
• Legitimate interests basis: In case where the customer is a juristic person, the Processing of Personal Data of persons related to the customers is necessary for the legitimate interests in operating business, preparing contracts and managing contracts of CHANINTR, such as the use of director’s or representative's data of the customers’ company in preparing contracts, managing customer orders, managing contracts and contacting with customers, etc.

(d) For the purpose of providing customers care and support.

• Legitimate interests basis: The Processing of Personal Data of the customers is for facility support, such as the record of order history and delivery location to facilitate the next purchase order and restaurant reservations, dealing with your inquiries and requests, etc.

(e) For the purpose of receiving complaints from customers or persons related to the customers.

• Legitimate interests basis: The coordination and Processing of Personal Data of the customers or persons related to the customers is necessary for legitimate interests of CHANINTR in solving deficiencies and problems, as well as developing the quality of the products or services provided by CHANINTR.

(f) For the purpose of informing news or publicizing products, services or activities.

• Consent basis: CHANINTR will inform news or publicize products, services and marketing activities, such as direct marketing, sending marketing messages to the customers, publicizing marketing activities, etc. CHANINTR will undertake such actions by relying on the consent received from you.
• Legitimate interests basis: When you notify, contact or provide information on interested products, services or activities in order for CHANINTR to contact back, inform news or publicize such matters to you, or in case where the customer is a business operator or juristic person, the Processing of Personal Data of persons related to the customer for publicizing products, services or activities to the persons related to customer is necessary for legitimate interests of CHANINTR, such as to present new products of CHANINTR to the contact person of the customer who is a juristic person, etc.

(g) For the purpose of arranging marketing activities.

• Contractual basis: The Processing of your Personal Data is necessary to execute per your request in participating in marketing activities, such as an application and grant awards in the competition or campaign according to the terms and conditions that CHANINTR prescribed.
• Legitimate interests basis: The Processing of your Personal Data to issue a gift voucher in a customer’s name, or in case where a customer is a business operator or juristic person, the Processing of Personal Data of persons related to the customer in order to arrange marketing activities is necessary for legitimate interests of CHANINTR.
• Consent basis: In this regard, where the Laws on Personal Data Protection require your consent for any Processing of Personal Data, CHANINTR will explicitly request the consent from you.

(h) For the purpose of developing quality of the products and services, analysis and planning of marketing strategies.

• Legitimate interests basis: The Processing of your Personal Data from purchasing products or services, surveying the interest or satisfaction of the customers on the products and services, including the usage of website or communication via other channels in which is necessary for legitimate interests of CHANINTR in operating business and developing the quality of the products and services provided by CHANINTR, such as the analysis of purchasing strategies and marketing strategies, development of quality of products and services, improvement of the operation, improvement of the website, including the solving deficiencies and problems related to products and services.
• Consent basis: In case CHANINTR observes or monitors your behavior or interest to analyze and plan for marketing strategies, or to analyze the behavior and conduct direct publicize or advertise according to your behavior or direct marketing, or in the case where the Laws on Personal Data Protection require your consent, CHANINTR will undertake such actions by relying on the consent received from you.

(i) For the purpose of internal and external audit, and analysis of various information that is necessary for business operations of CHANINTR.

• Legitimate interests basis: The Processing of Personal Data is necessary for the legitimate interests of the business operation of CHANINTR, such as maintenance of IT system, detection, prevention and solution of technical issues, and other service planning, etc.

(j) For the purpose of the compliance with the laws relating to CHANINTR’s business and legitimate orders of courts, government agencies and relevant officers.

• Legal obligation basis: To comply with the applicable laws of CHANINTR, such as taxation law, Laws on Personal Data Protection, computer crime law, laws on communicable diseases, laws on customs, and legitimate orders of the courts, government agencies and relevant officers, such as the Customs Department and Office of the Personal Data Protection Commission, etc.
• Legal obligation basis to achieve the purposes relating to public interests in public health: In some cases, the Processing of sensitive Personal Data is necessary for CHANINTR in complying with laws to achieve the purposes relating to public interests in public health, such as the collection of health data or body temperature of the persons entering into CHANINTR in order to protect from the spreading of COVID-19 according to the laws on communicable diseases, etc.

(k) For the purpose of establishment of legal claims, proceeding in accordance with and exercise of claims, or raising arguments to defend claims pursuant to the laws.

• Legitimate interests basis: The Processing of Personal Data is necessary for the establishment, compliance, exercise or defense of legal claims of CHANINTR in various stages according to the laws, such as investigation and/or inquiry by government officials, reporting the compliant, case preparation, prosecution and/or pursuit of the case in court, etc.

(l) For the purpose of monitoring and ensuring the security of persons and properties of CHANINTR.

• Preventing or suppressing a danger of person’s life, body or health basis: The Processing of Personal Data is necessary for the benefit in checking, monitoring, preventing or suppressing any circumstances which may be dangerous to person’s life, body or health.
• Legitimate interests basis: The Processing of Personal Data is necessary for the legitimate interests of CHANINTR in monitoring and ensuring the security of properties of CHANINTR. For example, the information of the visitors or the CCTV footage can be used to prevent loss or damage to CHANINTR’s properties or to track properties or claim damages in the case where the properties of CHANINTR are lost or damaged, etc

(m) For any transaction that is necessary and beneficial to CHANINTR or other persons or juristic persons which are directly related to the purposes set forth above.

• Legitimate interests basis: The Processing of Personal Data is necessary for the legitimate interests of CHANINTR or other persons or juristic persons in carrying out any transactions which are necessary and/or beneficial to CHANINTR or any other persons or juristic persons, or directly related to the purposes set forth above.

In this regard, where the Laws on Personal Data Protection require your consent for any Processing of Personal Data, CHANINTR will explicitly request the consent from you.

(n) For other purposes of which CHANINTR will notify you.

• CHANINTR will notify you of any other purposes that cause CHANINTR to Process your Personal Data other than the purposes set forth above or when CHANINTR changes the original purposes that were set forth.

In this regard, where the Laws on Personal Data Protection require your consent for any Processing of Personal Data, CHANINTR will explicitly request the consent from you.

7.2

Your Personal Data which CHANINTR will Process for the Purposes set forth in Clause 7.1 above that relate to the compliance with laws or contracts or are necessary for entering into contracts with you, is the data which is necessary for the achievement of the said Purposes. If you do not intend to provide such Personal Data to CHANINTR, there may be legal implications or CHANINTR may not be able to perform its duties pursuant to the contract which has been entered into with you or may not be able to enter into a contract with you (as the case may be). In such event, it may be necessary for CHANINTR to decline to enter into the contract with you or to cancel the sale and purchase or services related to you, whether in whole or in part.

7.3

In the event that CHANINTR will Process your Personal Data in a manner and/or for purposes which are not consistent with the Purposes set forth above, CHANINTR will put in place additional policies or notifications for the protection of Personal Data to provide explanations concerning such Processing of Personal Data. In this regard, you should review such additional policies or notifications in conjunction with this Privacy Notice (as the case may be).

8.1

CHANINTR may disclose your Personal Data in accordance with the Purposes and the rules prescribed under the laws to the following persons and entities:

• Companies in CHANINTR, including directors, executives, staff, employees and/or relevant in-house personnel, and as necessary on a need-to-know basis for the Processing of your Personal Data.
• Business partners, service providers, suppliers and data processors designated or hired by CHANINTR to perform duties in connection with the management/Processing of Personal Data for CHANINTR in the provision of various services, such as information technological services, website management services, cloud services, document depository services, payment services, printing services, mailing services, delivery services, freight forwarding services, shipping services, installation services, repair services, data analytics services, marketing services, remarketing services, bank, or any other services which may be beneficial to you or relevant to CHANINTR’s business operations, etc.
• Designers and interior design and decoration companies that you have contacted or engaged.
• Advisors of CHANINTR, such as legal advisors, lawyers, auditors, or any other internal and external experts of CHANINTR.
• Court and relevant governmental agencies which have supervisory duties under the laws or which have requested the disclosure pursuant to their lawful powers or relevant to the legal process or which were granted permission pursuant to applicable laws, such as Ministry of Commerce, Revenue Department, Customs Department, Department of Disease Control, Office of the Personal Data Protection Commission, Royal Thai Police and Office of the Attorney General, etc.
• Any persons or other entities that you have given consent to disclose your Personal Data to, such as the disclosure of processed images of activities through various media platforms of CHANINTR to the general public.

8.3

In the event that CHANINTR discloses your Personal Data to third parties, CHANINTR will put in place appropriate safeguards to protect the Personal Data that has been disclosed and to comply with the standards and duties relating to the protection of Personal Data as prescribed by the Laws on Personal Data Protection. Where CHANINTR sends or transfers your Personal Data outside Thailand, CHANINTR will ensure that the recipient country, the international organization or such overseas recipient has a sufficient standard for the protection of Personal Data or such transfers of your Personal Data outside Thailand have been carried out in accordance with the Laws on Personal Data Protection. In some cases, CHANINTR may request your consent for the transfer of your Personal Data outside Thailand, subject to the requirements under the Laws on Personal Data Protection.

CHANINTR will retain your Personal Data for the period necessary to fulfill the Purposes for which the Personal Data was Processed, whereby the retention period will vary depending on the Purposes for which such Personal Data was collected and Processed. CHANINTR will retain Personal Data for the period prescribed under the applicable laws (if any) by considering the statute of limitations under the laws for any legal proceedings that may occur from or in relation to the documents or Personal Data collected by CHANINTR and having regard to CHANINTR’s business practices and relevant business in relation to each category of Personal Data.

In this regard, CHANINTR will retain your Personal Data for a period not exceeding 10 years, starting from the date your legal relations/transactions with CHANINTR come to an end. However, CHANINTR may retain your Personal Data for a longer period of such time prescribed if the laws permit or such retention of Personal Data is necessary for the establishment of the right of claim of CHANINTR.

After the period of time set forth above has expired, CHANINTR will delete or destroy such Personal Data from the storage or system of CHANINTR and other persons providing services to CHANINTR (if any) or anonymize your Personal Data, unless in the event that CHANINTR can continue to retain such Personal Data as prescribed by the Laws on Personal Data Protection or other applicable laws. In this regard, for additional details regarding the retention period of your Personal Data, you can contact CHANINTR by using the contact details set out in Clause 2 of this Privacy Notice.

As the data subject, you have the following rights in relation to your Personal Data, subject to the rules, methods and conditions under the Laws on Personal Data Protection. In this regard, if you wish to make a request to exercise your rights, you can contact CHANINTR by using the contact details set out in Clause 2 of this Privacy Notice.

10.1 Right of Access

You have the right to access your Personal Data and may request that CHANINTR provide you with a copy of such Personal Data in accordance with the requirements under the Laws on Personal Data Protection.

10.2 Right to Data Portability

You have the right to obtain your Personal Data, including to request that your Personal Data is transmitted to another data controller or to you, except where it is technically unfeasible, in accordance with the requirements under the Laws on Personal Data Protection.

10.3 Right to Object

You have the right to raise an objection to the Processing of your Personal Data in certain circumstances prescribed under the Laws on Personal Data Protection.

10.4 Right to Erasure

You may request that CHANINTR delete, destroy or anonymize your Personal Data in certain circumstances prescribed under the Laws on Personal Data Protection.

10.5 Right to Restriction

You have the right to request that CHANINTR restrict the Processing of your Personal Data in certain circumstances prescribed under the Laws on Personal Data Protection.

10.6 Right to Rectification

You have the right to request that your Personal Data be rectified if the Personal Data is inaccurate, not up-to-date or incomplete, or may cause a misunderstanding.

10.7 Right to Withdraw Consent

If CHANINTR relies on your consent as the legal basis for Processing your Personal Data, you have the right to withdraw such consent which has been provided to CHANINTR at any time.

10.8 Right to Lodge a Complaint

If you have any concerns or questions about any aspect of CHANINTR’s practices in relation to your Personal Data, please contact CHANINTR using the contact details set out in Clause 2 of this Privacy Notice. Where there is reason to believe that CHANINTR is in breach of Laws on Personal Data Protection, you have the right to lodge a complaint to the expert committee appointed by the Personal Data Protection Commission in accordance with the rules and methods prescribed under the Laws on Personal Data Protection.

To this end, CHANINTR reserves the right to consider your request to exercise your rights and act in accordance with the requirements under the Laws on Personal Data Protection.

CHANINTR may make changes to this Privacy Notice from time to time to reflect any changes to our Processing of your Personal Data and to comply with any changes to the Laws on Personal Data Protection or any applicable laws. In this regard, CHANINTR will notify you of any significant changes to the Privacy Notice and the amended Privacy Notice through appropriate means and/or post the amended Privacy Notice on our website www.sprucesimple.com/privacy-notice. CHANINTR encourages you to review such communication periodically in order to be aware of any changes made to this Privacy Notice.

This Privacy Notice shall be effective from May 31, 2022.