Privacy Policy
Last
Update 12 August 2026
HERITAGE CROC (THAILAND) LTD. (the “Company,” “we,” “us,” or “our”) as the distributor of Lacoste recognizes the importance of the protection of
personal data for you of our products and services. We know you care how information about you is collected,
used, disclosed, and transferred outside of Thailand. The information you share with us allows us to provide the products and
services you need and want appropriately tailored for you, not only from us,
but also those within Central Group's data ecosystem. We appreciate your trust that we will carefully and sensibly handle your
personal data while giving you the very best personalized experience and customer services.
This privacy policy (this "Privacy Policy") applies to our retail
stores, websites, mobile applications, call center, social
networking sites, online communication
channels, and other locations where we collect your
personal data. However, please read this Privacy Policy in
conjunction with the terms and conditions of particular service that you use. (This may be provide separately according to the type of Personal
Data that we collect from you)
For the purpose of this Privacy Policy, “Personal Data” means any information relating to an identified
or identifiable natural person.
We reserve the right to modify this Privacy Policy from time to time, so
please review it frequently to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become
effective when we post the revised Privacy Policy on our website or application. We will provide additional notice of significant
updates. In case any
modification deprives your rights of sensitive data in relation to this Privacy
Policy, the Company will first obtain your consent, except as otherwise permitted
by law.
1. What Personal Data we
collect
We may collect or obtain the following types of information
which may include your Personal Data directly or indirectly from you or other
sources or through our affiliates, subsidiaries, business partners
or other companies. The specific type of Personal Data collected
will depend on the context of your interactions with us, and the services or
products you need or want from us and companies in Central Group's data
ecosystem.
1.1. Personal
details, such as title, full name, gender, age, occupation,
qualifications, job title, position, business type, company name, nationality, country of residence, date of birth, marital
status, number of family members and children, ages of children, information on
government-issued cards (e.g., national
identification number, photograph
of the national identification, information on the national identification, control
number on the reverse side of the national identification (Laser
ID), social security number, passport number, tax identification number,
driver's license details or similar identifiers), immigration
details such as arrival and departure date, signature, voice, voice record, photograph, facial features for
recognition, CCTV records, work
place, education, insurance
details, license
plate details, house registration, household income, salary and personal income;
1.2. Contact
details, such
as postal address, delivery details, billing address, residential address,
workplace address, address shown in the national identification card, telephone number, fax number, email address, LINE
ID, Facebook account, Facebook ID, Google ID, Twitter ID, and other ID from
social networking sites, your contact person's contact details (e.g., telephone number, contact data on any correspondence (e.g. written communication
with you), and any other contact
details you provided to us;
1.3. Membership details, such as account details, member card number,
reward points, member ID (e.g. The 1 member card number, The 1 ID, Siebel ID,
member ID, customer ID), member type, customer type, member join/registration
date and month, membership period, bank account and payment details, service and product applications (e.g. membership
application, insurance application);
1.4. Financial details, such as debit/credit card or bank information, credit/debit
card number, credit card type, issuance/expiration date, cycle cut, account details, bank account details, prompt pay number payment details and records, your information regarding the risk profile for the
business partner, credit rating and solvency, information in accordance with
the declaration of suitability, suitability
of transaction and any other financial
details;
1.5. Transaction details, such as details about payment to and from
you, payment date and/or time, payment amount, details about refund, refund
amount, points, date and location of purchase, purchase/order number, appointment date for service,
address/date
and time for pick up or delivery, acknowledgement of receipt, recipient email’s signature,
warranty details, complaints and claims, booking details, rental details, transaction, transaction
history, location, transaction status, past sales transaction, status,
transaction status, purchasing behaviour, and any other details of products and services
you have purchased, including but not limited to any information incurring from
using of products or services provided on our platform, such as e-pocket,
digital asset, lending product, insurance product and the product related to
wealth management, etc.;
1.6. Technical
details, such
as Internet Protocol (IP) address, cookies, media access control (MAC) address,
web beacon, log, device ID (such as international mobile equipment
identifier (IMEI),
electronic serial number (ESN), mobile equipment identifier (MEID) and
serial number (SN)),
device model and type, formats of software and hardware of the device when it is activated in the
system, network,
connection details, access details, single sign-on (SSO), login log, access time and location, time
spent on the page, login
data, GPS, latitude,
longitude and time spent on each webpage, login information, applications
downloaded on a communication devices, search
history, browsing details, browser type and version, time zone setting and
location, browser plug-in types and versions, operating system and
platform and other technology on devices you use to access the platform,
including any other technical information arising from the use of our
platform and
systems;
1.7. Behaviour details, such as information about your purchasing
behavior and data supplied through the use of our products and services;
1.8. Profile
details, such as
your username and password, profile details and picture, purchases, historical
orders, past orders, purchase history, items bought, item quantity, orders or product
recalls made by you, orders via website, Cash On Delivery details, order ID, financial
records, PIN, your interests, preferences, feedback and survey responses,
satisfaction survey, social media engagement, participation
details, loyalty programs, your use of discount codes
and promotions, customer order description, customer service, attendance to
trade exhibitions and events, trade exhibitions, litigation, testing and trials;
1.9. Usage
details, such as information on how you browse or use
our websites, platform, application products and services, products in
customer's cart, wish list record, remind me flash sale record, follow-shop record, and timestamp
of last click and Q&A record;
1.10. Marketing and
communication details, such as your preference in receiving
marketing from us, our affiliates, subsidiaries, business partners or other companies, and your
communication preferences; and/or
1.11Sensitive
data, such
as race, religion,
political opinions, fingerprints,
facial recognition, person identity information (biometrics), face,
information from the iris recognition, physical or mental health or condition,
genetic data, medical history, disability and criminal records.
If you provide Personal Data of any third party to us, e.g., their name, family name, address
details, and telephone number for emergency contact, family member income, or if
you use the
service on any of our platforms with your consent, we can access and collect
third party personal information relating to you, such as information on name, picture and/or
phone number, as well as personal and contact information of family, friends, emergency contact
persons, recommended persons or referrals accessible from your mobile number, etc.; please provide this Privacy Policy for their
acknowledgement and/or obtaining consents if necessary.
We will only collect, use, or disclose
sensitive data on the basis of your explicit consent or where
permitted by law.
We only collect the information of children, quasi-incompetent persons, and
incompetent persons where their parent or guardian has given their consent. We do not knowingly collect
information from customers under the age of 20 without their parental consent
when it is required, or from quasi-incompetent persons and incompetent persons without their legal guardian's
consent. In the event we learn that we have unintentionally collected
personal information from anyone under the age of 20 without parental consent when it is required, or from quasi-incompetent persons and
incompetent persons without their legal guardians, we will delete it
immediately or process only if we can rely on other legal bases apart from
consent.
2. Why we collect, use or disclose your Personal
Data
2.1. The purpose for which your consent would be
required
Marketing and Communications: We
collect, use and disclose your Personal Data to provide privileges and promotions, discounts, special
offers, advertisements, notices, news, information and any marketing and
communications about the products and services from us,
Central Group, our affiliates, subsidiaries and business partners which
we cannot rely on other legal bases.
Please contact HERITAGE CROC (THAILAND)
LTD. to manage your consent for marketing and communications.
· 3388/25-37 Sirinrat Building,
8th-11th Floors, Rama IV Road, Klongton Sub-district, Klongtoey District,
Bangkok, Thailand
· Tel : 02-2297000
2.2. The purposes we may rely on and other legal
grounds for processing your Personal Data
We may also rely on (1) contractual basis, for our initiation or
fulfilment of a contract with you; (2) legal obligation, for the fulfilment of the legal
obligations; (3) legitimate
interest, for the purpose of our legitimate interests and the legitimate
interests of third parties; (4) vital interest, for preventing or suppressing
a danger to a person’s life, body, or health; and/or (5) public
interest, for the performance of a task carried out in the public interest or
for the exercising of official authorities.
We may collect, use and disclose your Personal
Data for the following purposes
1) To provide products and services to you: To enter into a contract and
manage our contractual relationship with you; to support and perform other
activities related to such services or products; to
complete and manage bookings and to carry out financial transaction and services related
to the payments including transaction checks, verification, and cancellation;
to process your orders, delivery, and collections and returns; refund and
exchange of products or services; to provide updates and on the delivery of the
products, and to perform warehouse internal activities, including picking,
packing, and labelling of packages; to verify warranty period; to provide
aftersales services, including maintenance and facility reservation;
2) Marketing and Communications: To
provide privileges, offers, updates, sales, special offers, promotions,
advertisements, notices, news, information and any marketing and communications
about the products and services from us, Central Group, affiliates,
subsidiaries and business partners.
3) Promotions, special offer, loyalty programs,
reward programs, prize draws, competitions, and other offer promotions:
To allow you to participate or earn promotions, special offers, loyalty
programs, reward
program, sweepstakes,
privilege, prize draws, competitions, and other
offer/promotions (e.g.,
sending you reminder emails and transferring your Personal Data to business partners ) to participate in activities and seminars, and all
services related to advertising. This includes to process and administer your
account registration, gift registration, event registration; for processing, collection,
addition, exchange, earning, redemption, payment,
and transfer of points; to examine your entire user history, both online and
offline; to provide and issue gift vouchers, gift cards, and invoices;
4) Registration and Authentication: To
register, verify, prove, affirm, identify, and/or authenticate you or your identity;
5) To manage our relationship with you: To contact and communicate
with you as requested by you or in relation to the products and services you
obtain from us, those within Central Group's data ecosystem, affiliates, subsidiaries and business partners; to handle customer
service-related queries, request, feedback, complains, claims, disputes
or indemnity; to provide technical assistance and deal with technical issues;
to process and update your information; to facilitate your use of the products
and services;
6) Personalization,
profiling and data analytics: To recommend products
and services that might be of interest to you, identify your preferences and
personalize your experience; to learn more about you, the products and services
you receive and other products and services you may be interested in receiving;
to measure your engagement
with the products and services, undertake data analytics, data cleansing, data
profiling, market
research, surveys, assessments,
behaviour, statistics and segmentation, consumption trends and patterns; profiling based on the processing of your
Personal Data, for instance by looking at the types of products and services
that you use, how you like to be contacted; to know you better; to improve
business performance; to better adapt our content to the identified
preferences; to determine the effectiveness of the promotional
campaigns, identify and resolve of issues with existing products and services; qualitative
information development. For this purpose, we will collect, use and
disclose your Personal Data for your interest and benefit and for legitimate
interest and businesses of Central Group, affiliates, subsidiaries and our business partners where such
interests and businesses are not overridden by your fundamental rights to
personal data. We will
request your consent where consent is required from time to time;
7) To improve
business operations, products, and services: To evaluate, develop, manage, and
improve, research and develop the services, products, system, and business
operations for you and all of our customers within Central Group's data
ecosystem, including but not limited to our business partners; to identify and resolve
issues; to create aggregated and
anonymized reports, and measure the performance of our physical products,
digital properties, physical measurement of products performance,
digital features and marketing campaigns as well as developing business models,
model for loan consideration, insurance and debt collection model;
8) To learn more about you: To learn more about
the products and services you receive, and other products and services you may
be interested in receiving, including profiling based on the processing of your
Personal Data, for instance by looking at the types of products and services
that you use from us, how you like to be contacted and so on;
9) Functioning of the sites, mobile application, and
platform: To
administer, operate, track, monitor, and manage the sites and platform to facilitate
and ensure that they function properly, efficiently, and securely; to
facilitate your experience on the sites and platform; improve layout, and
content of the sites and platform;
10) IT Management: For business management purpose including for IT
operations, management of communication system, operation of IT security and IT
security audit; internal business management for internal compliance
requirements, policies, and procedures;
11) Compliance
with regulatory and compliance obligations: To
comply with legal obligations, legal proceedings, or government authorities'
orders which can include orders from government authorities outside Thailand, and/or
cooperate with court, regulators, government authorities, and law enforcement
bodies when we reasonably believe we are legally required to do so, and when
disclosing your Personal Data is strictly necessary to comply with the said
legal obligations, proceedings, or government orders. This includes to provide and handle VAT refund
service; issue tax invoices or full tax forms; record and monitor
communications; make disclosures to tax authorities, financial service
regulators, and other regulatory and governmental bodies, and investigating or
preventing crime;
12) Protection
of our interests: To
protect the security and integrity of our business; to exercise our rights or
protect our interest where it is necessary and lawfully to do so, for example
to detect, prevent, and respond to fraud claims, intellectual property
infringement claims, or violations of law; to manage and prevent loss of our
assets and property; to secure the compliance of our terms and conditions; to
detect and prevent misconduct within our premises which includes our use of
CCTV; to follow up on incidents; to prevent and report criminal offences and to
protect the security and integrity of our business;
13) Fraud
detection: To verify your
identity, and to conduct legal and other regulatory compliance checks (for example, to comply
with anti-money laundering
regulations, and prevent fraud). This
includes to perform sanction list checking, internal audits and records, asset
management, system, and other business controls;
14) Corporate transaction: in the event of sale,
transfer, merger, reorganization, or similar event we may transfer your Personal
Data to one or more third parties as part of that transaction;
15) Risks: To
perform risk management, audit performance, and risk assessments; and/or
16) Life: To prevent or suppress
a danger to a person’s
life, body, or health.
If you fail to provide your Personal Data when
requested, we may not be able to provide our products and services to you.
3. To whom we may disclose or transfer your Personal
Data
We may disclose or transfer your Personal Data to the
following third parties who collect, use and disclose Personal Data in
accordance with the purposes under this Privacy Policy. These third parties may be located in
Thailand and areas outside Thailand. You can visit their privacy policies to learn
more details on how they collect, use and disclose your personal data as you could also be subject to their privacy policies.
3.1. The company within Central Group's data ecosystem
As HERITAGE CROC (THAILAND) LTD. is part of data ecosystem
of Central Group which all collaborate and partially
share customer services, products and systems including website-related platforms and systems, we may need to disclose or transfer
your Personal Data to, or otherwise allow access to such Personal Data by other companies
within Central Group's data ecosystem for the purposes
set out in this Privacy Policy. Please see list
of companies for further details here.
3.2. Our service providers
We may use other companies, agents or
contractors to perform services on behalf or to assist with the provision of
products and services to you. We may share your Personal Data to our service
providers or third-party suppliers including, but not limited to (1) infrastructure,
internet, infrastructure technical, software and website, and IT service providers; (2) warehouse
and logistic service providers; (3) payment service providers; (4) research
agencies; (5) analytics
service providers; (6) survey agencies; (7) auditors; (8) marketing, advertising media, and communications
agencies; (9) call
center; (10) campaign
and event organizers; (11) sale representative agencies; (12) telecommunications and communication service
providers; (13) payment,
payment system, authentication, and dip chip service providers and agents; (14) outsourced
administrative service providers; (15) data storage and cloud service providers; (16) verifying
and data checking (Netbay and Department of Provincial
Administration)
service providers; (17) dispatchers; and/or (18) printing service providers.
In the course of providing such services, the
service providers may have access to your Personal Data. However,
we will only provide our service providers with the Personal Data that is
necessary for them to perform the services, and we ask them not to use your
information for any other purposes.
3.3. Our business partners
We may transfer your Personal Data to our
business partners in
the businesses of banking, finance, credit, loan, asset management, investment,
insurance, credit cards, telecommunications, marketing, retail, e-commerce, warehouse,
logistics, wellness, lifestyle products and
services, spa and fitness, reward and loyalty program, and data analytics,
including platform
sellers or providers whom we
may jointly offer products or services, or whose products or services may be
offered to you. Data shared in this way will be governed by the third
party’s privacy policy and
not this Privacy Policy.
3.4. Social networking
sites
We allow you to login
on our sites and platforms without the need to fill out a form. If you log in using
the social network login system, you explicitly authorize us to access and
store public data on your social network accounts (e.g. Facebook,
Google, Instagram), as
well as other data mentioned during use of such social network login system. In addition, we may
also communicate your email address to social networks in order to identify
whether you are already a user of the concerned social network and in order to
post personalized, relevant adverts on your social network account if appropriate.
We also partner with certain third parties that allow you to enroll
in their services or participate in their promotions. For example, certain companies
allow you to use your loyalty program number or online services login to
receive or register for their services. Additionally, your social network account provider allows you to
connect your social network account to your online services account or log into
your online services account from your social network account. When you enroll in those
services, we will share your Personal Data to those third parties. If you do not want to share
your Personal Data in this way, do not provide your loyalty or reward program
number to third parties, do not use your online services account to register
for third-party promotions and do not connect your online services account
with accounts on third-party services. Data shared in this way will be governed by the third party’s privacy policy and not this Privacy
Policy.
3.5. Third parties required by law
In certain
circumstances, we may be required to disclose or share your Personal Data in
order to comply with a legal or regulatory obligations. This
includes any law enforcement agency, court, regulator, government authority or
other third party where we believe it is necessary to comply with a legal or
regulatory obligation, or otherwise to protect our rights, the rights of any
third party or individuals’ personal
safety, or to detect, prevent, or otherwise address fraud, security, or safety
issues.
3.6. Professional advisors
This includes lawyers,
technicians and auditors who assist in running our business, and defending or
bringing any legal claims.
3.7. Associations
We may transfer your Personal Data to other member associations, such as
Thailand E-Payment Association (TEPA), Electronic
Transactions Development Agency (ETDA), the Association of Confederation of Consumer
Organization, Thailand (ACCOT), Foundation for consumers, the Thai Chamber of Commerce,
Thai E-Commerce
Association, Thai Retailers Association, Thai Shopping Center Association and
the Ratchaprasong Intersection Group.
3.8
Assignee of rights and/or obligations
Third
parties as our assignee, in the event of any reorganization, merger, business
transfer, whether in whole or in part, sale, purchase, joint venture,
assignment, transfer or other disposition of all or any portion of our
business, assets or stock or similar transaction; will comply with this Privacy
Policy to respect your Personal Data.
4. International
transfers of your Personal Data
We may disclose or transfer your Personal Data to third parties or servers located overseas,
which the destination countries may or may not have the same equivalent level
of protection for Personal Data protection standards. We take steps and measures to ensure that your
Personal
Data is securely transferred and
that the receiving parties have in place an appropriate level of protection standards
or other derogations as allowed by laws. We will request your consent where consent to
cross-border
transfer is required by law.
5. How long do we keep your Personal Data
We retain your Personal Data for as long as is
reasonably necessary to fulfil purpose for which we obtained it, and to comply
with our legal and regulatory obligations. However, we may have to retain your Personal
Data for a longer duration, as required by applicable law.
6. Security of your Personal Data
The Company recognizes the importance of maintaining the security
of your Personal Data. Therefore, the Company endeavours to protect your information by
establishing security measures for your Personal Data appropriately and in
accordance with the confidentiality safeguard of Personal Data, to prevent
loss, unauthorized or unlawful access, destruction, use, alteration, rectification
or disclosure; provided, however, that the Company will ensure that the method
of collecting, storing and processing of your Personal Data, including physical
safety measures follow the information technology security policies and
guidelines of the Company.
7. Cookies and how they are used
If you visit our websites, we will gather certain information
automatically from you by using cookies.
Cookies are small pieces of information or text issued to your
computer when you visit a website and are used to store or track information
about your use of a website and used in analyzing trends, administering our
websites, tracking users’ movements around the
websites, or to remember users’ settings. Some cookies are strictly necessary
because otherwise the site is unable to function properly. Other Cookies allow us to enhance your browsing experience, tailor
content to your preferences, and make your interactions with the site more convenient: they remember your username in a secure way, as well as your
language preferences.
Most Internet browsers allow you to decide whether or not to
accept cookies. If you reject, remove or
block Cookies can affect your user experience
and without cookies, your ability to use some or all of the features or areas
of our websites may be limited.
In addition, some
third parties may issue Cookies through our websites to serve ads that are
relevant to your interests based on your browsing activities. These third parties
may also collect your browser history or other information to determine how you
reached our websites and the pages you visit when you leave our websites. Information gathered
through these automated means may be associated with the Personal Data you
previously submitted on our website.
8. Your rights as a data subject
Subject to applicable laws and exceptions
thereof, you may have the following rights to:
1)
Access:
You may have the right to access or request a copy of the Personal Data we are collecting,
using or disclosing about you. For your own privacy and security, we may
require you to prove your identity before providing the requested information
to you.
2)
Rectification: You may have the right to have incomplete, inaccurate,
misleading, or or not
up-to-date Personal Data that we collect,
use or disclose about you rectified.
3)
Data Portability: You may have the right to
obtain Personal Data we hold about you, in a structured, electronic format, and
to send or transfer such data to another data controller, where this is (a) Personal Data which you have
provided to us, and (b) in the case where we are collecting, using or disclosing such data on the basis of your
consent or to perform a contract with you.
4)
Objection: You may have the right
to object to certain collection,
use or disclosure of your Personal Data such as objecting to direct
marketing.
5)
Restriction: You
may have the right to restrict the use of your Personal Data in certain circumstances.
6)
Withdraw
Consent: For the purposes you have consented to our collecting,
using or disclosing of your Personal Data,
you have the right to withdraw your consent at any time.
7)
Deletion: You
may have the right to request that we delete or de-identity Personal Data that we collect,
use or disclose about you, except we are not obligated to do so if we need to
retain such data in order to comply with a legal obligation or to establish,
exercise, or defend legal claims.
8)
Lodge a complaint: You
may have the right to lodge a complaint to the competent authority where you
believe our collection,
use or disclosure of your Personal Data is unlawful or noncompliant
with applicable data protection law.
9. Our Contact Details
If you wish to contact us to exercise the
rights relating to your Personal Data or if you have any queries about your
Personal Data under this Privacy Policy, please contact us or our Data
Protection Officer at:
1)
Company Name
· [HERITAGE CROC (THAILAND) LTD.]
· No.
3388/25-37, Sirinrat Building, 8th-11th Floors, Rama 4 Road, Klongton
Sub-district, Klongtoey District, Bangkok Metropolis.
· 02-2297000
2)
Data
Protection Officer
·
Data
Protection Officer
· Data Protection Office, Central Group
22 Soi
Somkid Ploenchit Road, Lumpini, Pathumwan, Bangkok, 10330 Thailand
·
email: dpo@central.co.th
**********
