1. Introduction

1.1 Welcome to PRYNWAN, a platform operated by Prynwan Tech Co., Ltd. and its affiliates (collectively referred to as “PRYNWAN”, “we”, “us”, or “our”). PRYNWAN takes its responsibilities under applicable privacy laws and regulations (“Privacy Laws”) seriously. We are committed to respecting the privacy rights of all users of our PRYNWAN website and mobile application (collectively, the “Platform”).

• “Services” refers to the Platform and the services we provide as described therein.
• “User” refers to an individual who has registered an account with us and uses the Platform (“you” or “your”).

1.2 “Personal Data” means data, whether true or false, about an individual who can be identified from that data, or from that data and other information to which an organization has or is likely to have access. Common examples include name, identification number, and contact information.

1.3 By using the Services, registering an account, or accessing the Platform, you acknowledge and agree that you accept the practices, requirements, and/or policies outlined in this Privacy Policy, and you consent to our collection, use, disclosure, and/or processing of your personal data as described herein. If you do not consent, please do not use the Services or access the Platform.

2. When Does PRYNWAN Collect Personal Data?

We may collect personal data when you:

• Register for an account or use our Platform/Services.
• Submit forms (online or physical) related to our products and services.
• Enter into agreements or provide documents regarding your interactions with us.
• Interact with us via telephone (which may be recorded), letters, fax, face-to-face meetings, social media, or email.
• Use electronic services or interact via cookies.
• Grant permission on your device to share information with our app/platform.
• Link your PRYNWAN account to your social media or other external accounts.
• Carry out transactions through our Services.
• Provide feedback or submit complaints.
• Register for contests or promotions.

3. What Personal Data Does PRYNWAN Collect?

The personal data PRYNWAN may collect includes, but is not limited to:

• Name, Email address, and Date of birth.
• Billing and/or shipping addresses.
• Bank account details and payment information.
• Contact number and Gender.
• ID card or Passport number and registered address.
• Network information and people/accounts you interact with.
• Photographs, audio, or video recordings.
• Government-issued identification for Due Diligence, Know Your Customer (KYC), and Fraud Prevention.
• Marketing and communication data (preferences and history).
• Transaction and usage data (search history, orders, content viewed).
• Location data (GPS/IP-based).

4. Other Data Collection

4.1 As with most websites and mobile apps, your device sends information that is recorded by a web server, including your IP address, operating system, browser version, device type, and unique device identifiers (UDID/MEID). 4.2 Our mobile applications may collect precise location data (GPS, Wi-Fi). You may withdraw this permission via your device settings, though it may affect location-based services.

5. Cookies

5.1 We and our third-party service providers/advertising partners may use “Cookies” to help us improve the Platform and Services, or provide personalized content and advertisements. 5.2 You may refuse cookies via your browser settings, but this may limit your ability to use the full functionality of the Platform.

6. How Do We Use Your Information?

We process your data for purposes including:

• Processing your transactions and communications with third parties.
• Managing and administering your account and relationship with us.
• Responding to customer service inquiries and troubleshooting issues.
• Enforcing our Terms of Service.
• Protecting personal safety and the rights/property of others.
• Identity verification and KYC (Know Your Customer) procedures.
• Credit and risk assessment.
• Marketing and advertising (which you can opt-out of at any time).
• Research, analysis, and development to improve user experience.
• Complying with legal processes, government requirements, or audits.
• Facilitating business asset transactions (mergers, acquisitions, or sales).

7. Protection and Retention of Personal Data

7.1 We implement a variety of security measures to ensure the safety of your personal data on our systems. Access is limited to authorized employees only. 7.2 We retain data only as long as necessary for legal or business purposes. Once it is no longer required, we will securely destroy or anonymize the data.

8. Disclosure to Third Parties

We may disclose your data to:

• Affiliates and related companies.
• Buyers/Sellers you interact with on the Platform.
• Service providers (Logistics, Financial, IT, Marketing, Telecommunications).
• Government or regulatory authorities.
• External parties in the event of a merger or business sale.

9. Children’s Privacy

Our Services are not intended for children under 13. We do not knowingly collect data from children under 13. Parents/guardians are requested to ensure children do not submit personal data. If a child has provided data without consent, we will delete the information and close the account.

10. Third-Party Services

Our Platform uses Google Analytics. Google may process your data (including IP address) on servers in the USA to evaluate site usage. We are not responsible for the privacy practices of third-party applications you choose to use through our Platform.

11. International Data Transfers

Your data may be transferred, stored, or processed outside of Thailand, primarily in Singapore (where our servers are located). While privacy standards may differ internationally, we ensure appropriate safeguards are in place to protect your data as required by Thai law.

12. Your Rights (The "Right to..." Section)

Under the PDPA, you have the following rights:

• Right to Withdraw Consent: You may withdraw consent for data processing at any time by emailing dpo@prynwan.com.
• Right of Access & Rectification: You may request to see the data we hold or request corrections.
• Right to Erasure: You may request the deletion of your data under certain conditions.
• Right to Restriction: You may request that we pause the processing of your data.
• Right to Data Portability: You may request to receive your data in a structured format to transfer to another controller.
• Right to Object: You may object to the processing of your data for certain purposes (e.g., direct marketing).

13. Contact Information

If you have questions, concerns, or wish to exercise your rights, please contact our Personal Data Protection Officer (DPO):

• Email: dpo@prynwan.com
• Copy (CC): legal@prynwan.com (for legal notices)
• Address: Prynwan Tech Co., Ltd. VPPW Building, No. 1990, New Phetchaburi Rd, Bangkapi, Huai Khwang, Bangkok 10310
• Tel: 02-716-0617-22