Data Protection Notice for Customers

VODA FIT EQUIPMENT CO.,LTD

What is personal data?

Personal data is any information that relates to or identifies a living individual, both directly or indirectly. This also includes the collection of less explicit data that leads to an identification of a particular person.

PII being Processed by the Company for the performance of the Platform

1. Directly Identifiable PII, including without limitation name, age, nationality and date of birth
2. Contact information, including without limitation, address, phone number, and e-mail address
3. Payment information, including without limitation the payment transaction, bank account information and credit card information
4. Platform transactional data, including without limitation username, password, transaction number and history that the User transact on the Platform, including the gathered preference and interest from the Platform transactional behavior
5. Technical PII, including without limitation the IP address number, the Platform usage, setting, and web browser connection that have been connected to the Platform.

Access to Personal Data

1. We access personal data directly from the users via the collection during the provision of service including:
   1. User’s account registration, and the submission of application for any services
   2. User’s subscription of any marketing and sales information including advertisement and promotion
   3. User’s consensual agreement when filling out the survey
   4. User’s cookies when accessing the platform
   5. Mutual contact between users and service providers both offline and online such as email enquiries and phone calls
   6. User’s purchase of any particular service or product
   7. User’s log-in on both service provider’s platform and associated sites such as Facebook and Google
2. We collect personal data of the users indirectly from the third-parties in the following cases: username and password login

Objectives for PII Process

1. The Company would need to collect, restore and use the PII of the User in order to perform any services or features of the Platform as defined under the Terms of Use, including without limitation (i) to verify the identity and eligibility of the User; (ii) to monitor the transaction undertaken on the Platform executed by the User; (iii) to contact the relevant User; and (iv) to display the relevant PII on the Platform interface in accordance with the scope of services provided under the Terms of User / Terms of Services;
2. The Company would need to collect and analyze the PII of the User in order to assess the User’s interest with an aim to provide customized and personalized privileges or service that would meet your interest and preference and to improve our customer’s experience with each relevant User;
3. The Company would need to collect and restore the User’s PII in order to assure the appropriate after-sale service provided by the Company in various forms, including the satisfaction survey or the support and complaint redress function;
4. The User would need to collect and restore the User’s PII as obliged under the applicable laws and regulations, for instance, for the withholding tax payment purpose.

The Company would need to collect and store the PII of each relevant User for the defined purposes for as long as the User is still the registered User on the Platform and for 3 (three) years after the User termination, except the relevant laws and regulations defined otherwise. The storage of the PII after the User termination would be necessary for the legitimate interest of the Company in the legal proceedings that the Company may have against the relevant User.

Sharing Personal Data

1. Within VODA FIT EQUIPMENT CO.,LTD for the purpose outlined in this policy.
2. To third-party service providers who require access to personal data in order to assist in the provision of the website, products and services, and other business-related functions such as website analytics providers or our third-party advertisement partners. These third-party service providers are limited to only accessing or using this data to provide services to us and must provide reasonable assurances they will appropriately safeguard the data.
3. We may also disclose visits information to third-parties:
4. Where required by law or regulatory requirement, court order or other judicial authorization
5. In response to lawful requested by public authorities including for the purposes of meeting national security and law enforcement requirements
6. In connection with the sale, transfer, merger, bankruptcy, restructuring or other reorganization of a business
7. To protect or defend our rights interests or property, or that of third parties
8. To investigate any wrongdoing in connection with the website or service
9. To protect the vital interests of an individual.
10. We may also share Personal Information collected through the Website with third party companies so that they may offer products and services that we believe will be of interest to visitors, as well as third party advertising-serving companies to better target the adverts and other content displayed on website and to provide offers we think may be interests of visitors. The unsubscription of marketing is stated in the “Personal Data and Marketing Activities” section.

Personal Data Processing

1. Computer System including On-premise
2. We may use the collected personal data with the purposes mentioned in “Data Collection Objectives”
3. We may disclose users personal data:
   • to staff members under VODA FIT EQUIPMENT CO.,LTD, in order to perform obligations in the course of or in connection with our provision of the goods and services requested by users; or
   • to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned objectives and for safety purposes.

Data Storage and Data Retention

1. Users personal data will be saved as soft copy data stored in our computer systems.
2. Users personal data will be saved in service provider’s devices, such as computers, phones, and tablets. This includes the mentioned Computer System (On-premise).
3. Data retention period will be illustrated in the “Data Retention” section below.

Data Retention Period

No.	Type of Personal Data	Retention Period
1.	Directly Identifiable PII, including without limitation name, age, nationality and date of birth	10 years from contract termination date
2.	Contact information, including without limitation, address, phone number, and e-mail address	10 years from contract termination date
3.	Payment information, including without limitation the payment transaction, bank account information and credit card information	10 years from contract termination date
4.	Platform transactional data, including without limitation username, password, transaction number and history that the User transact on the Platform, including the gathered preference and interest from the Platform transactional behavior	5 years from contract termination date
5.	Technical PII, including without limitation the IP address number, the Platform usage, setting, and web browser connection that have been connected to the Platform.	5 years from contract termination date

Data Subject Rights

1. Right to withdraw consent: Users can withdraw their consent and request the processors to stop collecting their personal data.
2. Right of Access: Users can submit data access requests, which oblige processors to provide a copy of any personal data they hold regarding data subjects. This includes a request for a disclosure of platforms and methods in which the processors collected the data from.
3. Right of Rectification: Users can request an update on an inaccurate or incomplete personal data.
4. Right to Erasure: Users can request that the service provider erase their data in certain circumstances, such as when the data is no longer necessary, the data was unlawfully processed or is no longer meeting the lawful ground for which it was collected. This includes the instance where the individual withdraws consent.
5. Right to Restriction of Processing: Users can request the service provider to limit the way their personal data is used.
6. Right to Data Portability: Users are permitted to obtain and reuse their personal data for their own purposes across different services.
7. Right to be informed: Users have the right to be notified about the collection of their personal data such as storage periods and purposes.
8. Right to Object: Users can object to the processing of personal data that is collected on the grounds of legitimate interests or the performance of a task in the interest/exercise of official authority.

Note : There is no additional charge regarding the mentioned right entitlement, and users will be contacted within 30 days from the date of request

Personal Information Request Form

1. Data access request
2. Data correction request
3. General Consent Withdrawal request
4. Complaint submission

Please contact our Data Protection Officer through the following details in the "Contact Us" section down below.

Personal Data and Marketing Activities

To optimize users satisfaction, we may distribute the information regarding our marketing activities such as promotion, discount, and news. This also includes information related to your preferences. Users can withdraw their consents after the subscription contacting 24phuketfitness@gmail.com.

What are Cookies?

Cookies are text files stored on your computer's browser directory or program data subfolders. Cookies are created when you use your browser to visit a website that uses cookies to keep track of your movements within the site. If you wish to learn more about cookies, visit https://www.allaboutcookies.org/.

How Do We Use Cookies?

1. To increase the efficiency and safety in users log-in process
2. To collect user’s platform usage, content adjustments, and personal settings
3. To research an individual user’s behaviour on the platform for satisfaction optimization purposes
4. To research the behavioral trend of all users in order to increase the efficiency of the platform

Types of Cookies

1. Functionality Cookies: Functionality cookies record information about choices you have made in the platform such as personal settings, languages, and fonts. This allows us to tailor our platform to you.
2. Advertising Cookies: Advertising cookies record your on-site behaviour and history of sites visited. This allows us to provide you the services, products, and advertisements that suit your preferences.
3. Strictly Necessary Cookies: These cookies are essential for you to browse the website and use its features, such as accessing secure areas of the site.
4. Performance Cookies: These are cookies used for gathering site visitors data anonymously, including the page that is visited most frequently in the website. This allows us to efficiently improve our platform regarding users preferences.
5. Third-party Cookies: These cookies will be determined by the third parties such as Google Analytics

Cookies Setting

1. Click the “Safari” menu, and tap “Preferences”.
2. Click the “Privacy” tap and manage the following setting choices:
   1. Enabling “Prevent cross-site tracking” to block third-party cookies and prevent third-party websites from storing data on your computer.
   2. Enabling “Block all cookies” will prevent First-Party cookies, as well as Third-Party cookies. Enabling this may cause websites to work improperly, and Safari will warn you about this if you choose this option.
   3. Choose the “Manage Website Data” button to remove certain website domains which have stored data on your computer.

1. Open Chrome and tap on “Settings” at the top right.
2. Click “Advanced” at the bottom.
3. Under 'Privacy and security', click “Site Settings”.
4. Click “Cookies”, then tap “ See all Cookies and Site Data”.
5. If you wish to remove your cookies, tap “Remove All”.

1. Open Internet Explorer and click “Tools” in the browser toolbar.
2. Choose “Internet” Option.
3. Click the “Privacy” tap.
4. Under “Settings” move the slider to the top to block all cookies or to the bottom to allow all cookies, and then click OK.

Effect of Notice and Changes to Notice

We may revise this notice from time to time without any prior notification. You may determine if any such revision has taken place by referring to the date on which this notice was last updated. Your continual use of our services constitutes your acknowledgement and acceptance of such changes.

29/06/2020

29/06/2020

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