Privacy Policy

PRIVACY POLICY FOR BUSINESS PARTNER Comein Asset Management Co., Ltd. (the “Company” or “we”) recognizes the importance of protecting and maintaining the privacy and security of our partners or user that will provide services related to accommodation, transportation and trip booking, other business partner’s personnel, authorized persons, authorized signatories, contact persons, or persons acting on behalf of the foregoing persons (collectively referred to as “you” or “Business Partner”) that provided to us for the partner registration process and when you access and interact on the application, platform and website [www.thecomein.com] called “ComeIn” (collectively referred to as the “Platform”). We, therefore, published this Privacy Policy for Business Partner (“Privacy Policy”) to describe how we collect, use or disclose your personal data, the rights you have regarding your personal data under the Personal Data Protection Act B.E. 2562 (2019) (“PDPA”) and any applicable data protection law.

The scope of this Privacy Policy is limited to the personal data we collected or received through the process of partner registration and your, including your personnel, employee or any administrator act on your behalf, use of the Platform or any interaction you have with us. We are not responsible for the processing of your personal data by third parties, people or companies that are not related to the purposes of using the Platform or purposes specified under this Privacy Policy.

In addition, it is your sole responsibility to inform the personnel, employee or user that will use the Platform on your behalf to be aware that their personal data will be maintained and processed by us during the use of the Platform. Any personal data submission of the aforesaid person shall be deemed that you have complied and followed all obligations and measures as required by PDPA and any applicable data protection law before providing us with their personal data.

COLLECTION OF PERSONAL DATA We will collect your personal data depending on the context of the business relationship and interaction you have with us during the time that you are still our business partners and the user of the Platform, such as providing you with administrator user registration, and access to the Platform for publicize your services. We may collect your personal data directly from you via the following channels and activities: When you submit any information or document related to your business or services to us via the provided channels, such as our website, or directly to our staff while collecting information about your business and services; When you purchase a package or additional services with us (if any); When you register or create a user account as our partner on the Platform; When you fill in the information about your services related to accommodation, transportation or other services relevant to trip booking, and publish it on the Platform; When you visit the Platform via the website; and When you communicate with us by telephone, email, via our website or through other communication channels, for example, through our email for support of the issues of using the Platform.

We may collect your personal data from other available sources or public sources such as: Any public website that already publicizes your personal data; A social media where you publicize your personal data, such as Facebook platform where you post your photo with your property that will be provided on the Platform; Our business partners or service provider, or third person that lawfully obtained your personal data and you are aware of such disclosure; and government authority.

COLLECTED PERSONAL DATA We collected your personal data that can be used to identify your identity, whether directly or indirectly, as following: Identity data e.g., Name, Surname, Age, Gender, Date of Birth, Nationality, Identification card number, Passport number, Tax Identification Number, Signature and Photos, etc. Vehicle data e.g., type of vehicle, license plate number, Copy of car registration book etc. Contact details e.g., Address, Phone number, Email address, Tax receipt address, etc. Proof of identity e.g., Copy of Identification card, Copy of Passport, Copy of Driving license, etc. Transaction and Financial data e.g., Bank account, Transaction details, etc. Account data e.g., Username, Password, etc. Platform usage data e.g., Transactions History, Accommodation Rates, Service etc. Technical data e.g., IP Address, Cookie ID, Activity Log, etc. Other data e.g., Any information that you voluntarily submitted to us that is considered to be personal data such as supporting documents for partner registration or any support documents related to your business and service that intend to be on the Platform and contained personal data, services experience articles, testimonials, feedback, comments, motion picture, information that appeared on any submitted documents (if any), etc. In certain circumstances, we may collect, use or disclose your sensitive personal data that is specially categorized by PDPA, such as health data, religion, biometric data (such as facial recognition data, iris recognition data, fingerprint recognition data) and any data which may affect the data subject, you, in the same manner as sensitive personal data. However, we will take appropriate measures in protecting and using this kind of data only if necessary for us to pursue the purpose specified under this Privacy Policy as permissible under PDPA or we have obtained your explicit consent prior to the collection or use of your sensitive personal data.

Please note that if your personal data collected by us as specified above is necessary for us to grant access or register your account on the Platform, for complying with any legal obligation that we are subject to, or performance of the contract between you and us, such as your identity data and accommodation or transportation detail, and you do not provide such information, we may not be able to provide you access to the Platform or using the Platform for publicizing the detail of your service.

CONTACT INFORMATION If you have any questions about this Privacy Policy or would like to exercise your rights, you can contact us by using the following details:

Comein Asset Management Co., Ltd. Address: 46/3 Moo. 1, Aonang, Krabi, Thailand 81180 Website: www.thecomein.com Email: support@thecomein.com

Data Protection Officer Email: support@thecomein.com