Jera Cloud Privacy Policy for Business

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

• Personal Identifiers such as your username, nickname,  first name, last name, job title, and images;

• Demographic information such as, your language and date of birth; 

• Contact Information such as your phone number, email address, physical address, LINE ID, and other applicable social media accounts;

• Financial Information such as your payment information/referenced card number, bank statement, wallet balance, outstanding balance, bank account number, type, and branch, tax ID, VAT registration; 

• Behavioral Information such as your time spent, browsing history, function usage,  orders, discounts, and ads spending on our platform, as well as income and expenses that are disclosed to us through your usage of our Services platform;

• Technical Identifiers such as the technical identifiers we or a third party created to identify you (ex. Internal ID, referral codes), device and advertising ID, technical address, and device information, including, carrier and operating system information as well as device storage, languages This Privacy Policy of Lamunpun IT Company Limited ("Lamunpun IT", "we", "us", or "our") is targeted towards the merchant and customers, including potential customers,  (“you”, “your”, or the “User”) of Lamunpun IT’s services, POS services (provided under the brands Jera Cloud, Jera Dent, and Sherwe), which are offered through our platform regardless of the access channel, whether accessed via mobile application, POS device, or website (“Lamunpun IT Services” or “our services”). This Privacy Policy (“Policy”) explains the details of how we collect, use, and disclose your information in connection with your use of our services."

• 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

• and timezones, TID Code, sensor data information, Root/Jailbreak status;

• Location Data such as your approximate location, business and device location (latitude and longitude);

• Other Identifiers such as those present in your chat logs or communications with our support services or sales team, including voice records, if applicable;

• Official Documents Information such as the personal data in your Thai ID card and passport copies and signatures as necessary.

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. (Our collection of your data on gender is not targeted towards sexual behavior). 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 (such as your employee), you are responsible for informing that person about our Services 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. 

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, Demographic Information, Contact Information, Financial Information, Location Data, Copies of Official Documents Information, and Other Identifiers that you have provided to us through our Services.

• Information collected directly from persons related to you (e.g. family, friends, referees). These include, for example, the Technical Identifiers shared to us via referral programs. 

• Information collected automatically through your use of our Services. These include, for example, the Behavioral Information and Technical Identifiers that we automatically collect about your use of the Services. Note that, based on your prior permission, we may also automatically collect information from third parties such as LINE and we may combine this information with other information that we have collected about you.

• Information collected from affiliates and business partners. These include, for example, the personal data that we exchange with electronic goods stores when you decide to purchase their product through our Services.

• Information collected from third-party. We typically receive your information from third-parties based on the prior permission you have given to such parties and/or us. These include the Personal and Technical Identifiers that we exchange with third parties such as LINE when you link our Services to them.

• 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 to provide and operate the Services, to fulfill our contractual obligation with you, respond to your requests, communicate with you, to provide customer service and technical support, and to offer you ad promotions from us and/or from our affiliates and business partners. These include, for example:

• Use of your Personal and Technical Identifiers as well as any relevant Contact Information for platform and device registration, onboarding and login;

• Use of your Personal Identifiers, as well as your Contact, Financial, and Official Documents Information for entering into contract and generating invoices; 

• Use of your Personal Identifiers, Contact information, and Location to deliver Services products such as POS hardware to you;

• Use of your Contact Information and Location to enable customers to be able to reach you as part of Lamunpun IT services;

• Use of your Behavioral and Contact Information to inform you of various reports, such as sales and performance and low stock inventory notification;

• Use of your Financial Information for Services payments and payouts;

• Use of your Technical Identifiers and chat logs with our support staff for responding to your requests and troubleshooting;

• Use of your Contact Information for satisfaction surveys and other forms of communications with you;

• Use of your Personal Identifier, Behavioral and Contact Information, as well as your Location Data to inform you of relevant promotions and ads, such as merchant privileges and campaigns with us as well as eligibility for loan products and electronic goods sales with our partners; 

• Use of your store information for the purpose of facilitating service reservations of your store through our business partners.

We may also use your personal data:

• To manage contract renewals and cancellation processes;

• To personalize your user experience, including tailoring our Services, displays, and recommendations to you.

• To deliver targeted marketing, targeted advertising, service updates, and promotional offers to you,  including sending you push notifications and alerts;

• To acquire business contacts/online leads and help manage customer accounts;

• To send you notices, order confirmations and communications;

• To verify your identity and prevent spam or other unauthorized or illegal activity;

• To better understand how users access and use our Services, both on an aggregated and individualized basis, in order to improve our Services and respond to user desires and preferences, and/or for other business research and analytical purposes;

• To optimize our ads on social media and other platforms;

• To prevent, detect, mitigate, and investigate fraud, security breaches or other potentially prohibited or illegal activities;

• To conduct various verification processes such as verifying cross-selling product information for ads manager and ads listing, verifying sales orders for media purchasing, and verifying your account before approving specific requests; 

• To provide any necessary refunds or credit withdrawal service;

• To make accounting records, manage payroll, confirm VAT registration, perform financial reconciliation, collect debts and hardware, conduct day to day financial operations, adjust payments or claims, issue refunds, and resolve e-payment disputes;

• To deliver you rewards and free marketing sampling products;

• To offer training and organize online and offline events that are beneficial for you; 

• To allow you to register your employees and suppliers for our Services (e.g. registering your cashier to and linking supplier’s information to inventory stock in the POS system);

• To allow you to set up special payment channels like QR payment;

• To create testimonial content and conduct interviews;

• To issue goods sales tax invoices and credit notes;

• To manage insurance subscription and refund processes;

• To verify coupons;

• 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:
 

• For meeting our legal obligations, such as the responsibilities that we have to our regulators, tax officials, and law enforcement authorities

• 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 specific Services, 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 identifiers may be needed for compliance with due diligence laws for merchants. As such, if you do not provide your personal data to us, we may not be able to facilitate, communicate, or provide some or all of our Services to 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 third party vendors and service providers such as our payment service providers; we may also disclose your personal data to our website, telephone, internet, cloud and physical storage services 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 your personal data with third-party business partners, such as merchants, retail and wholesale stores or electronic goods vendors, as needed to fulfill your order and issue tax invoices or related documents. We may also share your data with loan providers to offer financial services or better loan terms, subject to your consent or request or the purpose of facilitating the reservation of services from your shop/restaurant, the information that may be disclosed for the reservation includes your name, reservation details (such as date and time), promotional information, etc.

• Advertisers and Researchers. We may also share your data with advertisers and researchers. For example, if you interact with content that mentions one of our advertisers, we may share that with them, or we may work with a researcher to analyze the content on a particular feed.

• 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;

• Aggregate and De-Identified Information. We may also share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes;

• Other Users. As part of the Services, we may make your personal data available to other users ( for example, as part of a referral scheme and as merchant contact information for end-customers and riders);

• Per your request. We may also disclose your personal data to other third parties per your request. For instance, where you authorize us to send emails to others on your behalf using third-party services, such as an email API. This may include sharing limited personal data, such as your email address, with the service provider to facilitate the functionality.

How We Share Your Personal Data Abroad

Our Services are targeted towards end customers who are in Thailand. However, 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 Services to you. This includes the processing of your personal data for:

• Registration, onboarding and login;

• Providing reservation services for your store through our business partners.

• Entering into contract and generating invoices;

• Services delivery, including, as applicable, delivering POS products to you, providing you with Jera Cloud and advertisement reports, and enabling customers to contact you as part of Lamunpun IT;

• Services payments and payouts;

• Debt collection and hardware re-collection;

• Sending notices, order confirmations and communications;

• Allowing you to register your employees and suppliers for our Services; 

• Allowing you to set up special payments channels; 

• Providing any necessary refunds or credit withdrawals;

• Contract renewal and cancellation.

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

• Informing you of relevant product services promotions and ads;

• Personalizing user experience, including tailoring our Services, displays, and recommendations;

• Conducting Service-related surveys;

• Responding to your requests and troubleshooting;

• Better understanding how users access and use our Services, both on an aggregated and individualized basis, in order to improve our Services and respond to user desires and preferences, and/or for other business research and analytical purposes;

• To optimize our ads on social media and other platforms;

• For system and product testing before launch;

• Conducting financial reconciliation and resolving e-payment disputes;

• Various verification purposes and as part of our auditing process; 

• Delivering free marketing sample products related to our Services;

• Offering training and online and offline events for our merchants.

In some cases, our processing of your personal data may be required as part of our legal obligations under the law, 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). 

If necessary, we will rely on your consent for the following activities:
 

• Processing the  sensitive data in your ID card for contracting and verification purposes;

• Delivering targeted marketing, targeted advertising, service updates, and promotional offers based on your communication preferences;

• Transferring your personal data to our business partners such as loan service providers or electronic goods stores (based on your specific interests and requests for their relevant services and products);

• Testimonial content and interviews.

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 the preparation of historic documents or research for public interests, the protection of vital interests, for the legitimate actions with 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 for the performance of our Services and/or obligations and for as long 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 your last usage of the relevant Services as per the general prescription period under Thai law.

Minors, Incompetent, or Quasi-Incompetent Persons
 

Our Services 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 Services 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.

Push Notifications/Alerts
 

We may send push notifications or alerts to your device. You can deactivate these messages at any time by changing the notification settings on your device or by changing your browser or application’s settings.

Third Party Analytics
 

We may use automated devices and applications, including those offered by third parties to evaluate usage of our Services. We may also use other analytic means to evaluate our Services. We use these tools to help us improve our Services, 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 facilitate, communicate or provide some or all of our Services to 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 your usage of our Services 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 Services, please contact our Data Protection Officer at dpo@lmwn.com. 

Information about Your Data Controller

Lamunpun IT Company Limited

245 68 Ramkhamhaeng 112 Alley, 

Khwaeng Saphan Sung, Saphan Sung, 

Bangkok 10240

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.