Privacy Policy
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LMWN Privacy Policy for Business Partners, Vendors and Others

Last Updated 12 November 2024

This Privacy Policy of LINE MAN (Thailand) Company Limited,  LINE MAN Corporation Pte. Ltd, Wongnai Media Co., Ltd., LINE Pay (Thailand) Company Limited,  and other subsidiaries, (“LMWN Group”, “we”, “us”, or “our”) is targeted towards persons for which we have or will potentially have a business relationship with, including business partners, vendors, and suppliers. (“you”, “your”, or the “User”).  

We take the protection of your privacy seriously, and we want you to understand exactly how and why we use your information. Please read this Privacy Policy carefully as it describes how we collect, use, disclose, and/or transfer your personal data.

The Personal Data We Collect

We may collect the following types of personal data about you that are relevant to the business:

  • Personal Identifiers such as your first name, last name, nickname, honorifics, job title, and images.
  • Contact Information such as your phone number, email address, physical address, and work equivalents as well as your LINE ID, and other applicable social media accounts;
  • Financial Information such as your payment details, including bank account numbers, payment methods, outstanding balances, bank statements, and tax identification. This also encompasses the accounts or methodologies we use to remit payments for the services you provide;
  • Official Documents Information such as the personal data in your Thai ID card, passport copies, and/or housing registration, as well as your signature; 
  • Other Identifiers such as those present in your chat logs or communications with our support business services or sales team, including voice records, partner codes, transaction or communication history with the company, reference information, information regarding bankruptcy or insolvency, and/or any other information we may request from you in connection with entering into contracts, services, or other operations related to the use of our products or the provision or receipt of services from us or by us, if applicable.

Note that, as a matter of practice, we do not generally collect your sensitive personal data,  such as the data pertaining to your race, ethnic origin, political opinion, cult, religious or philosophical beliefs, sexual behavior, criminal record, health data, disability, trade union information, genetic data and biometric data. If you are required to send us documents or information containing sensitive personal data that is not required for the particular purpose you agree to redact such data before providing the document or information to us. For instance, when sending us a copy of your ID card you should cross out the sensitive information in the ID card, such as your blood type and religious beliefs, as applicable. In the event that we are intentionally collecting your sensitive personal data, we will only do so with your explicit consent and/or in strict compliance with the applicable laws. 

Additionally, in the event that you provide the personal data of other person to us, you are responsible for informing that person about our business and the associated data processing (via the relevant Privacy Policy) prior to the submission of those persons’ personal data to us, as well as obtaining their consents or relying on other applicable legal basis as exception to their consent for the disclosure of their data to us. For instance, as part of our formal due diligence process, we may obtain the name, surname, starting date, salary, benefits, performance rating, job title, and education of key staff at your company.

Finally, please note that you are responsible for the accuracy of your own data and for notifying us of any changes in your personal data so that we can adjust your information to be as accurate, as up-to-date, and as complete as possible.

How We Collect Your Personal Data

Our sources of your personal data  may include but is not limited to:

  • Information collected directly from you. These include, for example, the Personal Identifiers, Contact Information, Financial Information, Copies of Official Documents Information, and Other Identifiers that you have provided to us through our business;
  • Information collected directly from persons related to you. These include, for example, the personal data shared to us via your company;
  • Information collected from third parties. These include, for example, the personal data that we obtain from affiliates and business partners who recommends your services to us;
  • Information collected from the public. We  may need to verify your identity from public sources for purposes such as fraud prevention.

How We Use Your Personal Data

In general, we use the personal data we collect about you for partner selection and vendor registration, for entering into agreements, for fulfilling our contractual obligation with you, for responding to your requests, and for communicating with you. These include, for example:

  • Use of your Personal Identifier and Contact Information for partner research and/or selection process;
  • Use of your Personal Identifier, Contact and Financial Information for vendor account creation and registration in our system;
  • Use of your Personal Identifiers, as well as your Contact, Financial, and Official Documents Information for entering into agreements and contract; 
  • Use of your Personal Identifiers, as well as your Contact, Financial, and Official Documents Information 

for making payment and generating invoices;;

  • Use of your chat logs with our support staffs for responding to your requests and troubleshooting;
  • Use of your Contact Information for partner and vendor surveys 

We may also use your personal data:

  • For managing our relationship and any disputes;
  • To send you notices, order confirmation and other forms of communication;
  • For contract evaluation, renewals, and cancellation processes;
  • For facilitating access to our business, including, as relevant, hotels and plane tickets to our conferences and events; 
  • For listing you as our guest, including as our speaker and/or trainer;
  • For public and government relations purposes; 
  • For our evaluation, including both formal and informal due diligence on potential partners, vendors, and target companies;
  • To conduct market research and perform other business research and analysis purposes;
  • To verify your identity and prevent spam or other unauthorized or illegal activity;
  • To prevent, detect, mitigate, and investigate fraud, security breaches or other potentially prohibited or illegal activities;
  • For the purpose of making accounting record, payroll, confirming VAT registration, financial reconciliation, debt collection, day-to-day financial operation, payment/claim adjustment, refund, and resolving payment disputes;
  • For testimonial content and interviews;
  • For surveys to understand demand for our services;
  • As part of our auditing process.

Additionally, in compliance with the applicable personal data protection law(s), we may also otherwise use your personal data as necessary:

  • To meet our legal obligations, such as the responsibilities that we have to our regulators, tax officials, and law enforcements;
  • For our legitimate interests or legitimate interests of any other person or legal person where such interests are not overridden by the fundamental rights that you have concerning your Personal Data;
  • For preventing or suppressing a danger to a person’s life, body or health;
  • For the performance of a task we carried out in the public interest, or for the exercising of official authority vested in us;
  • For the achievement of the purpose relating to the preparation of the historical documents or the archives for public interest, or for the purpose relating to research or statistics with appropriate security measures;
  • For the establishment, compliance, exercise, or defense of legal claims.
  • For the legitimate actions with appropriate safeguards by not-for-profit bodies. 
  • Where your personal data is information that you disclosed to the public with your explicit consent. 

Depending on the occasion, the provision of your personal data may be necessary for compliance with a law or contract or may be necessary for the purpose of entering into the contract. For instance, the processing of certain personal identifiers and contact information may be needed to fulfill the terms of a contract. As such, if you do not provide your personal data to us, we may not be able to facilitate, communicate, or enter into business with you.

How We Share Your Personal Data

For the purposes as described under this Privacy Policy (including the purposes on how we use your personal data as described above),  we may disclose and/or transfer your personal data to the following types of parties:

  • Affiliates and Subsidiaries. For instance, both Wongnai Media Company Limited and LINE MAN (Thailand) Company Limited are closely linked as part of the LINE MAN Wongnai (LMWN) platform; 
  • Data Processors. We may disclose your personal data to data processors and contractors or agents who perform functions on our behalf; 
  • Service Providers. We may disclose your personal data we collect to other third party vendors and service providers such as our website, telephone, internet, cloud and physical storage business providers;
  • Consultants. We may disclose your personal data to third party advisors such as our attorneys, auditors, business consultants, and other subject-matter consultants and experts;
  • Business Partners. We may share personal data with our other third party business partners for business contacts purposes
  • Business Transfers. We may transfer the personal data we have collected to another company in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business;
  • In Response to Legal Process. We may disclose your personal data in order to comply with the law, a judicial proceeding, court order, subpoena, or other legal process. For example, we may share your technical information and location data to comply with a police warrant; 
  • Regulators. We may disclose your personal data to regulators for legal compliance or per their reasonable request; 
  • To Protect Us and Others. We also may disclose your personal data if we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service, or as evidence in litigation in which we are involved;
  • Per your request. We may also disclose your personal data to other third parties per your request. 

How We Share Your Personal Data Abroad

While our business is primarily based in Thailand, for the reasons identified above, we may also send or transfer your personal data to countries abroad, which may or may not have similar data protection standards to Thailand. For instance, for the purpose of the provision and improvements of our Services, we may transfer your personal data to our LMWN group affiliates and data processors overseas, and we may share your personal data to members of the LINE Group Companies abroad. 

In all cases, we will put in place protection measures as necessary and appropriate for the data transfer in order to maintain and protect the security of your personal data. 

On What Legal Basis Do We Collect, Use, and Share Your Personal Data

In general, we rely on our contractual obligations to provide and operate the business to you. This includes the processing of your personal data for:

  • Entering into agreements and contracts; 
  • Making payments and generating invoices;
  • Sending notices, order confirmation and communication;
  • Contract renewal and cancellation.

Additionally, we generally rely on our legitimate interests to process your personal data for:

  • Vendor research and selection process;
  • Vendor account creation and registration in our system;
  • Contract evaluation;
  • Managing our relationship and any disputes;
  • Public and government relations purposes;
  • Facilitating access to our business;
  • Listing you as our guest or speaker/trainer;
  • Our evaluation, including contract evaluation and formal and informal due diligences processes;
  • Market research and other business research and analysis purposes;
  • Conducting Service-related surveys;
  • Responding to your requests and troubleshooting;
  • System and product testing before launch;
  • Conducting financial reconciliation and resolving e-payment disputes;
  • Various verification purposes and as part of our auditing process; 

In some cases, our processing of your personal data may be required as part of our legal obligations under the law or for the establishment, compliance, exercise, or defense of legal claims, including the processing of your personal data for: 

  • Verifying your identity and prevent spam or other unauthorized or illegal activity;
  • Preventing, detecting, mitigating, and investigating fraud, security breaches or other potentially prohibited or illegal activities. (We also consider such activities as part of our legitimate interests under the law even if they do not strictly arise to the levels of legal obligations for us to follow 

Finally, we may rely on another lawful basis to process your data, depending on the specific occasion, including the legal basis for which we have already listed above as well as your consent, the preparation of historic documents or research for public interests, the protection of vital interests, for the legitimate actions of appropriate safeguards by our not-for-profit bodies,  the processing of your personal data that is disclosed to the public with your explicit consent, and as part of our public task. Note that for data transfers abroad, we may also rely on the basis for the transfer of your personal data abroad as being necessary for the compliance with a contract between us and other persons or juristic persons for your interests.

How Long Do We Keep Your Personal Data

We generally only keep your personal data to the extent necessary as is reasonably required for the purposes explained in this Privacy Policy or as required by applicable laws. We will also retain personal data if we reasonably believe there is a prospect of dispute/litigation to the extent permitted by applicable laws. 

For estimation purposes, the general expected retention period of your personal data is 10 years from the end of your last legal interaction with us as per the General Prescription period under Thai law.

Minors, Incompetent, or Quasi-Incompetent Persons

Our business dealings are not directed to or designed for children under the age of majority under the applicable laws, and incompetent, or quasi-Incompetent persons and we do not knowingly collect, use, and/or disclose the personal data of such individuals without obtaining their legal guardian/custodian/curator’s consent.

If we are aware that the personal data of children under the age of majority or of incompetent, or quasi-Incompetent persons under the applicable laws have been collected, used, and/or disclosed on the Service without appropriate consent, then we will take the appropriate steps to delete or anonymize this information unless there is legal ground for us to otherwise collect, use, and/or disclose  of such information.

Cookies

We use cookies and similar tracking technologies on our websites and applications.

A cookie is a small text file that is stored on your computer, mobile, or other electronic device when visiting a website or application. This text file stores information that can be read by the website or application when visiting it again at a later date. Some of these cookies are necessary because otherwise the site or application will be unable to function properly. Other cookies are convenient for the visitor: for example, they remember your username in a secure way as well as your language preferences. The use of such cookies means that you do not need to fill out the same information each time you visit a website or application.   

We use cookies and similar tracking technologies:

•    To help us maintain your session when you visit our website or application

  • To enhance security of our systems.
  • To store your preferences and provide website or application customization for you.
  • To help us understand how people use our website and application and to improve them.

Most Internet browsers and iOS and Android devices allow you to control whether or not to accept cookies in the settings function. If, however, you deactivate cookies or limit the ability to set cookies, you may not be able to obtain the full benefit of the website or application or access all of their functions, which may limit your overall user experience.

Third Party Analytics

We may use automated devices and applications, including those offered by third parties to evaluate the usage of our website. We may also use other analytic means to evaluate our website. We use these tools to help us improve our business, performance and user experiences. The information collected may include unique device identifiers, device manufacturer and operating system, IP address, mac address, location, browser type, session start/stop time and user activity.

Third-Party Links

Our website or application may contain links to third-party websites and/or applications. Any access to and use of such websites and/or applications is not governed by this Privacy Policy, but instead is governed by the privacy policies or notices of those third party websites and/or applications.

Your Rights

Subject to applicable laws, you may have the following rights with respect to your personal data:

  • The right to withdraw consent for the collection, use, or disclosure of your personal data that is based on your consent at any time. However, if you withdraw your consent, we may not be able to enter into business with you;
  • The right to request access to or obtain a copy of your personal data that we hold about you as well as the right to request the disclosure of the acquisition of personal data obtained without your consent;
  • The right to request us to provide your personal data in a commonly readable format or transmit that personal data in such a format to another organization;
  • The right to request us to erase or destroy or anonymize your personal data in certain circumstances;
  • The right to object to us or restrict us from collecting, using, or disclosing your personal data in certain circumstances;
  • The right to request us to rectify your personal data to be accurate, up-to-date, complete, and not misleading;
  • The right to lodge a complaint with the competent public authority if you believe that we have not complied with the law.

You can exercise these rights by contacting us per the details below. Note that we may ask for additional information and/or documentation to verify your identity before proceeding with your request. 

Pre-Regulation Notice

We are entitled to continue processing your personal data that have previously been collected by us before the effectiveness of the Personal Data Protection Act B.E. 2562 in accordance with the original purposes of processing. If you do not wish us to continue collecting and using your personal data, you may notify us to withdraw your consent at any time per the contact information below..

Personal Data Security

We have implemented appropriate technical and organizational measures, ranging from user access control to data encryption and anonymization, to prevent the unauthorized or unlawful loss, access to, use, alteration, correction or disclosure of your Personal Data. These measures and policies are regularly reviewed for updates when necessary. 

While we employ robust security measures, it is crucial to recognize that internet-based data transmission inherently involves risks beyond our control. We cannot ensure the complete security of your data during online transmission, and you acknowledges and assumes this risk. 

Contact Us

If you want to exercise any of the rights as permitted by applicable laws as set out above or have any questions about the privacy aspects of our business, please contact our Data Protection Officer at [email protected]. 

For non-privacy related issues, you may reach us here.

Information about Your Data Controller

LINE MAN (Thailand) Company Limited
195 One Bangkok Tower 4, Unit No. 2411 – 2412, 
24th Floor and Unit No. 2501-2514, 25th Floor, 
Witthayu Road, Lumphini, Pathumwan, Bangkok, 10330

Wongnai Media Co., Ltd (Head Office)
195 One Bangkok Tower 4, Unit no. 2403 – 2410, 
24th Floor, Witthayu Road, Lumphini, Pathumwan,
Bangkok, 10330

LINE Pay (Thailand) Company Limited
195 One Bangkok Tower 4, Unit no. 2401 – 2402, 
and 2413-2414 24th Floor, Witthayu Road, Lumphini, 
Pathumwan, Bangkok, 10330

Living Mobile Company Limited
195 One Bangkok Tower 4, Unit no. 2403 – 2410, 
24th Floor, Witthayu Road, Lumphini, Pathumwan,
Bangkok, 10330

For Singapore:

LINE MAN Corporation Pte. Ltd
10 Collyer Quay,
#10-01, Ocean Financial Centre,
Singapore 04315

Changes to this Privacy Policy

We may modify this Privacy Policy. The latest version of the Privacy Policy will always be posted on this site, and we encourage you to review the contents of the latest version of the Privacy Policy carefully.

When we make any material changes to this Privacy Policy, we will notify you through reasonable means.