We, AP (Thailand) Public Company Limited, strictly abide by our customers’ privacy. When we use your personal data to run our business and provide service to you, your personal data is protected under the Personal Data Protection Act B.E. 2562.

As the data controller, we are obliged by the law to inform you of our privacy policy which explains the way we collect, use or disclosure your personal data as well as your rights to your personal data as the data subject. We reaffirm that we comply with the law to protect your personal data.

1. Definition of Personal Data

Personal Data can be divided in 2 categories
Personal Data (General) Personal Data means any information related to a person, which enables the identification of such person, whether directly or indirectly. For example, name address e-mail address Identification Number.
Sensitive Personal Data Sensitive Data is special category of personal data that needs appropriate protection and carefully collect, use or disclose. Sensitive Data pertains racial, ethnic origin, political opinions, cult, religious or philosophical beliefs, sexual behavior, criminal records, health data, disability, trade union information, genetic data and biometric data.

2. Personal data that we collect from you

We collect your information when:
  • You use our website;
  • You provide information to us through our website or applications;
  • You provide information to us when you make enquiry via online or offline channel.

We only collect your personal data as necessary to provide the service to you and to correspond to your queries as well as to carry on our business in a way that you would normally anticipate.
Contact Data
Includes name-surname, address, email, telephone number, interested properties or project, budget range, reasons to purchase.
Technical Data
Includes internet protocol (IP) address, browser type and version, time zone setting and location, operation system and platform and other technology on the devices you use to access this website.
Usage Data
Includes information about your use of our service through and from our website, websites that you view, elements you viewed or words you searched for in platforms, date and time of visit, and interaction information such as clicks on item in a website.
Communication Data
Includes email, notes of conversation, communication notes.
Contract-related Data
National identification number, address, credit card number, date of birth, sex.

3. Sources of Personal Data

1. We receive your personal data directly from you through the following channels:
  • You register with us by creating an account on our website or application.
  • You make a query with us relating to your interested property/ project.
  • You make an appointment with us to visit the project site.
  • You provide information to us when you visit the project site.
  • You participate in our marketing activity through an electronic platform, social media, or an offline platform.
2. We receive your personal data from a third party that collects, uses or discloses your personal data as instructed by us or on our behalf. Your personal data will not be used other than the purposes for which we instruct or require such third party to do. We require such third party to protect confidentiality of your personal data and to have measures to protect your personal data as required by the Thai personal data protection law.
3. We receive your personal data from cookies when you visit our website. This data helps us provide you better, faster, safer services and for your own privacy when you use the service and / or enter the platform.

4. Purpose of collection, use and disclose of personal data

We may use your personal data to the extent permitted by the personal data protection law. We only collect your personal data as necessary and to the extent that is related to provision of our service to you, where it is necessary:
  • For our legitimate interests or any other person and your interests, which do not override your fundamental rights;
  • For the performance of a contract to which you are a party, or in order to take steps at your request to enter into a contract;
  • For compliance with a law to which we are subjected or for preventing or suppressing a danger to a person’s life, body or health.
We explain in the table below about how we use your personal data, and which lawful basis we rely on to do so.
Purpose/activity
Types of data
The lawful basis of processing
To provide service including communicate with you about a residential project that you are interested in.
- Contact data
- Communication data
1) Necessary for the performance of contract.
2) For our legitimate interest to provide information to you on your interested property/ project.
To manage our relationship with you.
- Contact data
- Communication data
1) Necessary for the performance of contract.
2) For our legitimate interest to recommend a project that meets your needs and to keep our records and study the way that customers use our service to improve our business.
To administer our website, improve our business, and solve a technical problem on website.
- Contact data
- Technical data
For our legitimate interests to use statistical and usage information on website to plan our business strategy in order to increase efficiency of our service.
To use data analytics to improve our website, our services and customer relationships and experiences.
- Technical data
- Usage data
For our legitimate interests to define types of customers and the nature of their usage as well as to keep our website updated and relevant to respond to customers’ way of using our service.
To enter into a contract relating to property purchase.
- Contact data
- Contract-related Data
1) Necessary for the performance of contract
To contract and communicate with banking business group for facilitating you to apply for credit.
- Contact data
- Contract-related Data
Necessary for the performance of contract to apply for credit.
To provide a direct marketing to you in offering projects or other services that might be of your interest.
- Contact data
We will obtain your explicit consent in allowing us to use your personal data for direct marketing purposes to offer residential projects or other services that you might be interested in.
To provide service in terms of residential and juristic person management after signing a contract by Smart Service and Management Co., Ltd (affiliated company) and Vaari Digital Co.,Ltd and other affiliates for the purpose of providing residential related services.
- Contact Data
- Communication Data
Necessary for the performance of contract with Smart Service and Management Co., Ltd (affiliated company) and Vaari Digital Co.,Ltd and other affiliates for the purpose of providing residential related services.


We may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

5. Disclosing or sharing your personal data

1. We may have to disclose or share your personal data with selected third parties as follows:
  • Our affiliated companies;
  • Online advertising platforms;
  • Marketing companies or consultants;
  • Regulator such as the Office of the Personal Data Protection Committee;
  • Professional advisors and consultants
We require that the third parties above protect confidentiality and protect your personal data in accordance with requirements under the Thai personal data protection law. They may use your personal data only for purposes as instructed by us. Your personal data will not be used other than the purposes for which we instruct or require them to do so.
2. Upon request, we may disclose your personal data to a relevant authority for compliance with a law such as prevention of a danger to a person, legal compliance, setting for an indictment, exercising legal rights, and preventing fraud.

6. Retention policy and retention period of personal data

We collect your personal data in our information system and provide standard security to keep our information systems and the use of your personal data secure with following measures:
  • Restrict access to personal data which may be accessed by employees, agents, contractors and other third parties. They can only access your personal data on our instructions, and they are subject to a duty of confidentiality and protection of personal data.
  • Provide technological methods to prevent unauthorized access to computer systems.
  • Destroy your personal data for security purposes when such information is no longer needed for legal and business purposes.
  • Put in place procedures to deal with any suspected personal data breach and will notify a regulator of a breach where we are legally required to do so.
Retention period of personal data
  • We will keep your personal data for as long as necessary to fulfil the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements.
  • To determine the appropriate retention period for personal data, we consider the amount, nature, purpose and sensitivity of the personal data, the potential risk of harm from unauthorised use of your personal data, and the applicable legal requirements.
  • We collect your personal data obtained from cookies when you use our website. We will keep your personal data for no more than 13 months or as required by relevant laws.

7. Right of Data Subject

Data subjects have the right to proceed to the extent permitted by law as follow;
  • The data subject shall have the right to withdraw his or her consent at any time. When processing personal data, you give us consent throughout the duration of your personal data with us (The Right to withdraw).
  • The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, request for a copy of his or her personal data, including request to disclose personal data acquisition that you did not give us consent to (The Right to Access).
  • The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her (The Right to Rectification).
  • The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay (The Right to Erasure).
  • The data subject shall have the right to obtain from the controller restriction of data processing (The Right to Restriction of Processing).
  • The data subject shall have the right to transmit their personal data to another controller without hindrance from the controller to which the personal data have been provided (The Right to Data Portability).
  • The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her. (Right to Object)
You can contact the DPO or company’s staff in order to proceed with the request to exercise the above rights.

8. Marketing activities and promotion

We may conduct marketing activities and promotion or use third parties as instructed by us to do so:
  • In case that we use your personal data for a purpose of providing a direct marketing to you, we will be able to do so only when you give us explicit consent and we have already informed you the purpose of your personal data’s use on direct marketing. However, you can withdraw your consent on direct marketing with us at any time through our opt-out system.
  • In the case of your participation in our sale promotional activities such as gaming activities or other activities through various social network channels for promoting our products and services to the public, we will not process your data for direct marketing unless you give us an explicit consent to use your personal data for direct marketing and we have already informed you the purpose of your personal data’s use on direct marketing. However, you can withdraw your consent on direct marketing with us at any time through our opt-out system.

9. Cookies policy

Cookies is text files located in your computer to be used to store details of log data on your internet use or your website's visiting behavior. You can learn more about Cookies from https://www.allaboutcookies.org We use Cookies to collect your data on visiting to our website to help us provide better, faster and safer services and support your privacy when you use our services through our website. We use Cookies in the following cases:
  • Cookies for website operations (Functionality Cookies): We use this type of cookies to help us remember your device or browser. Thus, we can quickly create content in consistent with your personal interests as well as provide the service and platform more convenient and beneficial to you. By disabling this cookie, you can set up your device by watching helping methods on your browser or device.
  • Cookies for analytics (Analytic cookies): We use Analytics Cookies providing by Facebook and Google for analyzing how visitors use our website with the objective of offering products or services via Social Media. In case you do not allow those third parties process your personal data, you can choose to disable this type of cookies on our website.

10. Privacy policy of other websites

This Privacy Policy is used for our service and our website use only. If you click on a link to another website (although via our website). You will have to study and comply with the privacy policy displayed on that website separate from ours.

11. Change of privacy policy

We will review our privacy policy regularly. In case of changing privacy policy, it will be announced on our website or other platforms.

12. Contact

Details of the data controller
If you need use your rights to your personal data under the Personal Data Protection Act B.E. 2562, you can contact;

AP (Thailand) Public Company Limited
Contact Address : 170/57 Ocean Tower 1, 18 Fl., Ratchadapisek Rd., Klongteoy, Bangkok 10110
Contact Tel : 02-018-9999
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