Personal Data Protection Policy
          Living Joy Co., Ltd. (the “Company”) is a provider of
                websites, including online platforms and other social media channels.  The Company respects the
                privacy of its users and realizes that the user’s personal information is extremely important, and
                as such, the Company has this Personal Data Protection  Policy in place to clarify details and
                methods of arranging, collecting, using or disclosing data protection, access to data, transfer and
                processing of your personal data as follows:
                This Privacy Policy is governed by the Personal Data Protection Act B.E. 2562,, and the Company has the
                authority to make decision regarding the collection, use or disclosure or personal data, which is
                referred to by law as the “Personal Data Controller”.
1. What personal data is collected, used or disclosed by the Company
                    The Company collects personal information which makes it possible to identify you
                whether directly or indirectly, this includes information you provide directly from the registration
                system through the registration system of activities of the Company, cookies, transaction information,
                monitoring usage and electricity bill and usage through the website assignees, or other any channels
                such as:
                - Personal information such as first name, last name, date of birth, ID number, nationality, religion,
                gender, driver’s license number, Passport number, marital status, system user’s name, login
                password. 
                - Contact information such as address by housing system, current residential address, phone number,
                email address.
                - Service usage information such as IP address, Device Information, login information useage information on the system,
                location information based on IP address, cookies usage while opening the website.
                - Other information such as use of the Website, audio, still images, animations, and any other
                information that is considered personal information under personal data protection laws. 
                - Electricity consumption contract account data from CA/Ref No. 1.
                - Financial information such as account number, credit card number, debit card number, outstanding
                payment information. 
                 
2.  Purpose for which information is collected, used or disclosed
                The Company will use your personal data to develop and improve the Website as well as analyzing and
                processing personal data to meet the needs of users, including providing services, product improvements,
                communication channels related to products benefits and more, in an electronic way for you to be more
                efficient. 
                    If the objectives are later changed, the Company will notify you for consent and
                provide a record of amendments as evidence. 
                    The Company will not collect, use or disclose your personal data for benefit other
                than the purposes as stated to you prior to or at the time of collection.
3.  Protection of Personal Data
                The Company will maintain your personal data weil in accordance with technical measures and
                organizational measures to secure proper personal data processing and to prevent personal data breaches,
                losses, etc.  Destroy, edit, convert  your personal information outside this purpose must be
                prior consented by you.  By obtaining your consent, the Company will do so expressly by book
                recording or electronically file as reference.
                However, you are free to consent to the Company’s collection, use or expose your personal
                information.  The Company shall not set the terms of consent to access the service or enter into a
                contract with the Company if the personal data is not necessary or relevant for entering into a contract
                or receiving such services.
                 In addition, the executi    ves, employees, contractors, agents, consultants, and
                data recipients of information of the Company are obliged to maintain personal information in accordance
                with confidentiality measures established by the Company.
                In the event that personal data is from an underage person, which is regarded as the minor person by the
                Civil and Commercial Code, the consent of using the personal data must be prior obtained from the
                custodian who has the authority to act on your behalf.  If the consenting person is a minor person
                up to 10 years, the consent of the custodian must be obtained directly from the custodian.
                The Company will process your information correctly, accurately, up-to-date and non-misleading.
                4.  Collection, use or disclosure, of personal information
                The Company will collect your personal data with your consent first, unless authorized by law under
                Section 24 or Section 26 of the Personal Data Protection Act B.E. 2562.  
                Your information shall be storage by the Company for the period of 10 years from the date of termination
                of the contract.
                The Company will collect your data only as necessary for the purposes stated by the Company in Clause
                2.
                However, if it is necessary for you to provide personal information to the Company in order to comply
                with the law or contract, or to enter into the contract with the Company, the Company will notify you
                first and will inform you of the consequences if you do not agree to provide such information.
                The Company will not collect your information directly from sources other than yours unless the Company
                informs you of your collection from other sources within 30 days and has your consent or is an exempt
                collection without consent stipulated under Section 24 or Section 26 of the Personal Data Protection Act
                B.E. 2562.
                The Company does not collect personal information related to race, ethnicity, political opinions, belief
                in cults, religions, or philosophy, sexual behavior, criminal record, health, disability information,
                union information, genetic information, biological information, or any other information that affect you
                similarly as announced by the Personal Data Protection Commission, without your express consent, unless
                the case under Section 26 of the Personal Data Protection Act B.E. 2562.
                The Company shall not use or disclose your personal information without consent under the Personal Data
                Protection Act B.E. 2562, Section 24 or Section 26.
                The Company will ensure that the employees assigned to this particular matter are not used, displayed or
                make it appear in any other way that your personal data, in addition to the purposes under the rules
                permitted by law to the extent to which you have consented or to the extent involved in this
                Policy.
                In the event that the Company will disclose your Personal Data to a third party or juristic person, an
                external person or entity must provide the purpose of use or disclose your personal data in addition to
                the purpose provided to the Company.
                In the event that the Company sends or transfers personal data to a foreign country, the destination
                country or international organization that receives personal data must have adequate personal data
                protection standards.  This must be in accordance with the guidelines as required by the Personal
                Data Protection Commission, unless the case is under Personal Data Protection Act B.E. 2562 Section 28
                (1) – (6).
            
                5.  Your rights regarding personal data
                Your right to this Policy is the right under the Personal Data Protection Act B.E. 2562 and other
                relevant laws.  You may requested to exercise your rights under the terms of the law and policies
                set forth by the Company prior to or at the time, or to be amended in the future, as well as the
                criteria set forth by the Company.
                5.1 Right to withdraw consent : You have the right to withdraw your consent at any time for the
                 duration of your personal data is being kept by the Company unless there is a
                statutory restriction  on that right or a contract that benefits you (whether it is
                the consent you have provided prior to the  date of Personal Data Protection Act, or
                afterwards).   
                5.2 Right to request access, obtain information, or copy of information : You have the right to request
                access, obtain information or ask the Company to produce a copy of information to you, as well as to
                request the Company to inform how your personal information is acquired by the Company.  
                  
                5.3 Right to object ; You have the right to object to the collection, use, or disclosure of your
                Personal Data at any time In the event that the Company is allowed with the power to collect your
                personal information without first asking for your consent.
                5.4 Right to request correction of personal information : You have the right to correct and update your
                personal information to avoid misleading of your information.      
                5.5 Right to request deletion or destruction : You have the right to delete or destruction of your
                personal information or make the personal data that cannot be identified by the person who owns it as
                follows:
                  5.5.1 Your information is not necessary to be retained for the purpose for which it is
                collected,
                used,
                or disclosed
                  5.5.2 When you have exercised your right to withdraw your consent  and the Company does
                not have the authority to legally collect
                  5.5.3 When you exercise to object under Clause 5.3 and the Company cannot legally refuse
                 
                the request.
                  5.5.4 When your information is collected, used, or disclosed unlawfully  
                5.6 Right to request that the use of data be suspended :  You have the right to ask the Company to
                suspend the use of your data in the following cases:
                  5.6.1 When the Company is under investigation as requested by you.
                  5.6.2 When the personal data is to be deleted or destroyed, but
                you request that information to be suspended instead.
                  5.6.3 When your data is deprived of the need for retention in accordance with the purpose
                for
                which you
                data is collected, However, you requested that such information
                should be temporary suspended and retained for use in setting up a claim in
                accordance with the law, compliance with rules and regulations.
                  5.6.4 When the Company is in the process of proving your request for objection in
                accordance
                       with Article 5.3 to see if the Company has the legal authority to reject your
                objection.            
                5.7 Right to request the Company to process your information correctly You have the right to request
                  the Company to process your information correctly to be updated, accurate,
                complete, so that it   does not cause misleading or misunderstanding.  If
                the Company does not comply with the
                request, the Company will record your request electronically.
                5.8 Right to complain : You have the right to complain to the relevant legal authority if you believe
                that the collection, use, disclosure of your Personal Data is in a manner that violates or fails to
                comply with applicable laws.
                5.9 The exercise of your rights mentioned above may be limited under applicable laws, and there are
                cases where the Company may refuse or fails to process your above requests, such as complying with the
                laws or Court order or the exercising of right can violate other persons rights.
            
                6.  Linking personal data information with other parties or legal entities
                6.1 The Company may link personal data with other persons or legal entities, and the Company will
                notify you before the linking with following details: 
                - The person or juristic person for the information to link.
                - The purposes of linking.
                - Methods of linking.
                - Personal information to be lined.  
                6.2 If there are changes in planned linking data, the Company will notify you of the change and request
                your
                     consent before proceeding.
                                  
                7.  Changes to the Privacy Policy
                The Company may update this Privacy Policy from time to time to reflect changes in the Services or
                Products of the Company.  The Company will announce the change clearly before the change begins, or
                may send you a notice directly.
            
8.  Subscription to access the system 
                    1. Anyone who impersonates or acts in violation of their privacy by using  the
                  information of others to impersonate a member to obtain membership is an offense punishable by
                application of laws.
                2.The applicant consents to the Company by reviewing personal information and any other information
                specified by the applicant in the subscription verify that your information is unclear or false.
                 The Company has the right to terminate the applicant’s membership without prior
                notice.
                3. In order to use the member system, the applicant must strictly comply with the rules established by
                the Company.
                4. The applicant’s information will be kept confidential and the Company will not disclose your
                information for commercial purpose of commercial gains.
                5. Once being a member, the applicant will receive a press release form other media sources that the
                Company may deem appropriate and necessary.
                TERMS AND CONDITIONS OF SERVICE
                These Terms and Conditions apply between “Service Provider or Living Joy Co. Ltd.” and
                “Users or     Subscribers” to use the Company’s online service as
                follows:
                1.  Definition
                    1.1   Service Provider meansLiving Joy Co.
                Ltd.
                    1.2   User means
                subscriber
                2. Subscription to use our Company’s service
                3. User must complete the actual details.  It it detects that such information is not true, the
                User shall be responsible for damages arising from such false information.
                4. For the benefits of the User, The Service Provider is allowed to verify the information accuracy.
                 In the event that the Service Provider determines that the information provided by the User is
                unclear or false, the Service Provider has the right to refuse the registration or the right to cancel
                the User’s username and password.
                5. The User must not use the username and password in a way that is unlawful, against social peaceful
                order, causing rudeness and obscene, and does not pander to the monarchy.
                6. In case of reasonable doubt that someone else has access to the User’s
                password, the User is obliged to reset the password immediately via the system screen.  In the
                event that someone uses a password, the User is also responsible for such action and damage. 
                7. User must strictly comply with the terms and conditions of application, and use of the Service
                Provider for safety reasons.  In the event that such information is stolen, lost or damage by force
                majeure or not due to negligence, the Service Provider has the right to deny responsibility for such
                damages.
                8. Anyone impersonating or acting in violation of their privacy by using someone else’s
                information to impersonate them in applying for username and password is an offense under the Criminal
                Code.
                9. The Service Provider has the right to immediately suspend or terminate the service to the User if it
                appears that the User has failed to comply with any of these Terms and Conditions, even one of them will
                be subject to any Terms and Conditions.
                10. The Service Provider will collect, maintain, and use the User’s information for the benefit of
                providing the Service, or to comply with applicable laws and rules and to improve the service quality of
                Service Provider.  
                11. The Service Provider shall not allow the User’s account to be disclosed to the third party, as
                well as the use of User’s information without prior permission from the User, unless it is
                disclosed to the legal authorities or to other persons authorized by the User.
                12. In case of damage caused by declaration to the third party or other persons with persmission granted
                by the User, the Service Provider shall not be responsible for whatsoever damage.
                13. The User must use polite words, otherwise, the Service Provider has the right not to grant
                membership rights.
                14. QONNEXT System Provider reserves the right to discontinue the membership system at any time without
                prior notice to members.
            
                Article 9   Security of Personal Data
                    The Company has appropriate information technology security measures in place to
                prevent loss, access, use, change, alteration, modification, or disclosure of personal data without
                authority or unlawfully.
            
                Article 10   Review and change of Personal Data Protection Practices
                    The Company reserves the right to change or amend this Person Data Protection
                Practice in order to comply with the law and in accordance with applicable administrative guidelines.
            
Article 11   How can you contact the Company 
                If you have any questions or would like to inquire about the protection your personal data, please
                contact us via the following channels:
                - Email :  dpo@livingjoy.com
                - Telephone:  0 2930 3418  (Monday – Friday 08.30 – 1700 hours)
                - Contact address:  Living Joy Co., Ltd. No. 165/285  Soi Phaholyothin 33, Latyao, Chatuchak,
                Bangkok 10900
                  When you agree to accept this Privacy Policy, the Company shall regard that Your acceptance
                is in full effect. .
                 
Data Security Management
                    Information Technology is an important business asset that must maintained and
                protected.  Currently, the Company has established the security of information systems by
                implementing important security technologies in the organization to help with work and reduce safety
                risks at the appropriate level while performance is remained maximum.
The Company recognizes the importance of Information Technology by maintaining the characteristics of C.I.A:
                1. Confidentiality Only available to eligible persons accessing to data control.
                 Confidential information must not be disclosed to ineligible persons.
2. Integrity There must be a shield against the integrity of the data and processing method. The system must be fault-controlled so that the ineligible do not change it.
3. Availability (always available capabilities) gives only eligible persons access to information at any time they want to. The system must be controlled not to fail and must have the capacity to work continuously, do not allow the ineligible to stop the system from working.
Information Security
                The Company has the policy to provide security and confidentiality of information.  The Company
                uses high-standard security system in both technology and process to prevent the theft of confidential
                information to ensure that the Company’s website and data have standardized security, including
                the choice of Firewall System, Anti-Virus System with high standard, as well as the use of Encrypt Data
                technology at 2048 bits, which is a high level of data encryption for transactions through Internet
                services.
The Company has chosen to use computer system technology with basic security system that is international standard and supplemented by working in the field of specific safety equipment. The general principles of controlling and securing information system include tight control over parts of the system. The methods used to control are as follows:
                1. Software Control 
                There are three levels:  
                Internal Program Control
                The program is being used to control over the access rights and the right to use data within the system,
                which is stored in the local database system itself.    
                Operating System Control
                This program is being used to control the access rights and data usage in different parts of one’s
                user computer system and is distinguished from other users.
                Development Control
                The program is being used to control the design and pre-production testing.
                2. Hardware Control 
                The policy has been enacted and updated to be implemented in accordance with the business operations and
                changing environments, effective throughout the organization.
                3. Use of Policies 
                The policy has been enacted and updated to be implemented in accordance with the business operations and
                changing environments, effective throughout the organization.
                4. Physical Control
                There are measures being used to control the access to computer.  Computer center can only be
                accessed by the relevant authorities.  There is also a regular backup system.
            
Measures and equipment used in security policy
                System security management consists of 3 components:
                1. Security Infrastructure
            
The Company has installed Firewall, a technology that prevents intruder room systemize and define zones,
                services, and access to appropriate information. 
                - Define appropriate scope and work zones
                - Define services and access to the system for authorized person only
                  Installation of anti-virus system to prevent and eliminate viruses that are regularly
                updated.
                To install an operating system with a security level of C2 by installing and enabling only appropriate
                and necessary services.
                - To install SSL System
                The Company opted for the latest version of SSL chosen by most leading companies because of its advance
                security capabilities.   The functions of SSL is to swap data and convert it to digital
                codes. 
                The more detailed encryption, the higher security is resulted which is measured in the number of bits.
                 
                The Company’s website using 2048 bits encryption which is being used by world’s leading
                companies.
                Installing a Web Server System and configuring appropriate parameter.
                2. Properly set up and use (Hardening)
                - Hardening
                - Patch Management
                - Authentication
                - Backup
            
3. Audit
                General usage monitoring.