Privacy Policy

With the recognition of the importance of personal data and protecting our users' data, we have provided this Personal Data Policy in accordance with the law. In order for the relevant persons who are responsible under the Personal Data Protection Act B.E. 2562 to comply with the established guidelines and ensure that our users are protected in accordance with the criteria for the protection of personal data and in accordance with their rights.

Definition

The Company /Us /We /Ours
means orbnet (Thailand) Co., Ltd. and affiliated companies.

Services/Products
means FlowWell and/or any other services of FlowWell provided under the Company.

User/You/Your
means a person or juristic person who is the recipient of the Service, whether it be customers, job applicants, employees, as well as those who provide any personal information to the Company in accordance with the goals of collecting information set forth in this Privacy Policy.

Means the Personal Data Protection Act B.E. 2562, including amendments which may take place in the future, and including the regulations set out under Regulations, Guidelines/Orders issued under the Personal Data Protection Act B.E. 2562 (2019) which may also be issued in the future.

Means any information relating to an identifiable person, either directly or indirectly, such as name, family name, address, email address, phone number and other contact information (if any), but not including data of the deceased. This includes "Sensitive Data", which is any information relating to race, ethnicity, cult, gender, religious or philosophical beliefs, criminal record, health, disability, including photographs or any data that may impact the data subjects in a similar manner as stipulated in the Personal Data Protection Regulations, Guidelines/Orders issued under the Personal Data Protection Act B.E. 2562 (2019).

Objectives

The Company recognizes the importance of personal data in order for our users to receive personal data protection and for the Company to comply with the law under the Personal Data Protection Act B.E. 2562 and the international standards for the protection of personal data. Therefore, we have set out the Personal Data Privacy Policy goals as follows:

In order for the User to use the Services/Products or any other Service of the Company, including the Company's software applications which will be provided as computer programs or mobile application software, the User will be required to agree to using the services of the Company and/or to take any other action at the User's request before using the Service or using any product of the Company.

The program FlowWell does not collect any personal data. The program works completely offline and the data is never leaving the users' device.

The program FlowWell also doesn't collect any analytical data from program usage or any other form (error tracking).

Period for personal data retention

Without collecting any data, we have no data that we could keep.

Use and/or disclose of personal data

Without collecting any data, we can't disclose anything.

External Service Connections

The program FlowWell does not integrate any third-party application, nor does it sideload any third-party or external services.

Rights of data subjects

This Privacy Policy is established to assure data subjects/users that they are acknowledged and able to exercise the following rights available to them under the law:

1. Right of access: The data subjects/users have the right to access their personal data and are able to request the Company to make a copy of such data, including the right to request the Company to disclose any acquisition of their personal data for which consent has not been given.
2. Right to data portability: The data subjects/users have the right to transfer personal data that they have provided to the Company to other Data Controllers or to themselves for certain reasons, in a generally readable or usable format, unless technically not possible. Therefore, the personal data mentioned under clause 2 must be personal data for which the data subjects/users have given consent to collect, use or disclose.
3. Right to withdraw or restriction of consent: The data subjects/users have the right to withdraw or restrict their consent in all or some part of the data for the processing of personal data that they have given to the Company throughout the period in which the personal data is kept by the Company.
4. Right to object: The data subjects/users may object to the collection, use or disclosure of the personal data without consent and with no reason to act as required by law.
5. Right to erasure: The data subjects/users are able to request the Company to delete data collected in the following cases:
   • The personal data is no longer necessary to be preserved according to the objectives under this Privacy Policy for which it was collected, used or disclosed.
   • The data subjects/users withdraw their consent to collect, use or disclose such personal data.
   • The data subjects/users object to the collection, use or disclosure of the personal data for which consent has not been given and without the reason to act as required by law.
   • The personal data has been unlawfully collected, used or disclosed according to the personal data protection laws specified.
6. Right to rectification: The data subjects/users have the right to request the Company to rectify incorrect or incomplete data, in cases of inaccuracies, errors or incompleteness of personal data and without misleading.
7. Other rights as specified by Personal Data laws which are under the Company's authority to process.

However, we may refuse the exercise of the above rights, provided that the rejection is in accordance with the Company's rules and is not in violation of the law. Or we may refuse the data subjects/users' request under the applicable law or court order where it is considered that the request may cause damage or infringe upon the rights and freedoms of others. Data subjects/users can contact the Company to make requests to exercise the above rights using the contact information provided. In the event that the Company refuses the request or commits any act in violation of the law, the data subjects/users have the right to file a complaint with the Personal Data Protection Committee.

Consent/Decline

Since your personal data is necessary to verify and use our services for the purpose of usage, subscription and identifying your data to access the Company's services as mentioned in the above "Objectives" section, any disclaimer or request for cancellation of consent under this Privacy Policy means the User will not be able to access or use the Services of the Company, and such refusal or request to cancel consent shall be deemed to be the User's refusal to use our Services. The User agrees and consents to the Company collecting, using and processing personal data for the purposes specified. If the User does not consent to the Company collecting, using and processing personal data for any of the stated "purposes," please inform us as detailed in the "Contact Information" section. For the benefit of usage of the services and under the law, we reserve the right to refuse requests of the User in the exercise of the above rights as necessary.

Contact Information

If you need more details or wish to inquire about the collection, use and/or disclosure of your personal data, including requesting to exercise the above rights in accordance with this Policy, you can contact our Company and/or Personal Data Protection Officer via email: privacy@orbnet.co.th