Last Updated 1 November 2023 

 

 

This Privacy Policy of LINE MAN (Thailand) Company Limited and LINE MAN Corporation Pte. Ltd ("LINE MAN", "we", "us", or "our") is targeted towards the end customers, including potential customers, (“you”, “your”, or the “User”) of LINE MAN’s services that are offered through our platforms such as Food Delivery, LINE MAN Mart, Messenger, and LINE MAN Ride services, regardless of channel of access, be it via mobile application or website (the "Services"), and provides you with information on how we collect, use, and disclose your personal data in furtherance of the 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

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

• Personal Identifiers such as your username, nickname, full name, and images;
• Demographic information such as your language and lifestyle;
• Contact Information such as your phone number, email address, physical address, LINE ID, and other applicable social media accounts;
• Financial Information such as your bank statement, bank account number, type, and branch, truncated credit card number, and wallet balance;
• Behavioral Information such as your browsing history, orders and other behaviors, and time spent on our Services platform;
• Technical Identifiers such as the technical identifiers we or a third party created to identify you (ex. LINE and LINE MAN’s internal IDs and referral codes), device and advertising ID, technical address, and device information, including carrier and operating system information as well as languages and timezones, and information that helps us discover relevant third-party applications (for example, to check whether the relevant payment/banking applications are installed on your device);
• Location Data such as your approximate location and device location (latitude and longitude);
• Other Identifiers such as those present in your order history and chat logs or communications with our riders, drivers, and/or support services, including voice records, if applicable;
• Official Documents Information such as the personal data contain in your Thai ID card and passport 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. 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, 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, Official Documents Information, Technical Identifiers, and Other Identifiers that you have provided to us while using 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 group orders features and referrals;
• Information collected automatically through your use of our Services. These include, for example, the Behavioral Information and Technical Identifiers that we automatically create and/or 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, group companies, and business partners. These include, for example, the Personal Identifiers that we exchange with affiliates like Wongnai and LINE when you order LINE MAN via their platforms;
• 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 Social Networking Services when you link our Services to them;
• Information collected from the public. On rare occasions, 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 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 registration, onboarding and login;
• Use of your Personal Identifier, Contact Information, and Location Data for Services delivery;
• Use of your Financial Information for Services payments;
• Use of your technical identifiers and order history and chat logs for responding to your requests and troubleshooting;
• Use of your Technical Identifiers to personalize the appearance of our platform and related backend systems for you.
• Use of your Contact Information for communicating with you;
• Use of your Personal Identifier, Contact Information, Behavioral Information, and Location Data to inform you of relevant promotions and ads.

We may also use your personal data:

• 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 send you notices, order confirmation and communication;
• 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 the likes;
• For system and product testing before launch;
• To prevent, detect, mitigate, and investigate fraud, security breaches or other potentially prohibited or illegal activities;
• To verify and complete group orders;
• To verify your account before approving your request;
• To provide any necessary refunds or credit withdrawal service;
• For the purpose of financial reconciliation and resolving e-payment disputes;
• 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:

• To meet our legal obligations, such as the responsibilities that we have to our regulators, tax officials, and law enforcements;
• 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 user verification laws. 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 also disclose and/or transfer your personal data to the following types of parties:

• Affiliates and Subsidiaries. For instance, we are closely linked with Wongnai Media Company Limited as part of the LINE MAN Wongnai (LMWN) platform;
• Group Companies. We are part of the LINE Group Companies;
• 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 the personal data with our third party business partners, including 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, we may make relevant details available to our riders, drivers, and merchants, or we may share your data to other end-customers if you are part of a group order;
• Per your request. We may also disclose your personal data to other third parties per your request.

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, we may transfer your personal data to cloud services overseas for the purpose of the provision of the Services 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;
• Services delivery;
• Services payments;
• Sending you notices, order confirmation and communication;
• Verifying and completing group orders and providing any necessary refunds or credit withdrawal service.

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

• Broadly informing you of relevant promotions and ads;
• Broadly 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 the likes;
• Conducting financial reconciliation and resolving e-payment disputes;
• Verifying your account and as part of our auditing process.

In some cases, our processing of your personal data may be required as part of our legal obligations under the law or for the establishment, compliance, exercise, or defense of legal claims, 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).

We typically rely on your consent for the following activities:

• Delivering targeted marketing, targeted advertising, service updates, and promotional offers based on your communication preferences, including sending you push notifications and alerts;

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 of with appropriate safeguards by 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:

• To help us maintain your session when you visit our website or application;

• To enhance the 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 on your electronic device, you may not be able to obtain the full benefit of the website or application or access all of its 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 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.

In-Car Camera

Where you are a passenger using our Services for LINE MAN Ride service, we are not in any way involved with or responsible for installation, operation, or use of in-car cameras, which are solely within the responsibility of each LINE MAN Ride driver providing their services to you. LINE MAN does not collect, use or disclose any personal data obtained via recordings of such in-car cameras. If you have any questions, you should request more information on the use of in-car cameras from the LINE MAN Ride driver directly.

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 (Thailand-Specific)

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.

For non-privacy related issues, you may reach us here.

Information about Your Data Controller

For Thailand:

LINE MAN (Thailand) Company Limited

8 T-One Building, Floor 26

Soi Sukhumvit 40, Phra Khanong Subdistrict

Khlong Toei District, Bangkok 10110

For Singapore:

LINE MAN Corporation Pte. Ltd

10 Collyer Quay,

#10-01, Ocean Financial Centre,

Singapore 04315

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.