Privacy Notice

Bluebik Group Public Company Limited and its affiliates in Thailand (“Bluebik Group”) hereby inform you details of the processing, whether collection, usage, and disclosure (“Processing”), of personal data which enables the identification of such person, whether directly or indirectly (“Personal Data”) through various channels, both online and offline. This includes, for example, information of contractors, information collected through websites, information collected through points of sale and events, information collected from social networks such as Facebook and search engines such as Google. Your Personal Data will be processed in accordance withapplicable legislations e.g., Thailand’s Personal Data Protection Act B.E. 2562, the EU General Data Protection Regulation and other applicable laws and regulations. This Privacy Notice provides important information in the following areas:

1. Objectives for Personal Data Collection

The Processing of your Personal Data is for management and administrative purposes in order to ensure that Bluebik Group is able to run the business with you appropriately, effectively and lawfully in order to fulfil any and all obligations under contracts, to perform transactions, to provide suitable products and services, to respond to orders and requests, to improve the quality of products and services, and/or to pursue any other legitimate interest of Bluebik Group.

If you have provided Personal Data of any third party to us, please ensure that such third party has acknowledged this Privacy Policy or granted consent for Processing their Personal Data where applicable.

You are free to decide whether you will allow Bluebik Group to collect your Personal Data. However, please kindly note that if you decide not to provide your Personal Data, you may not be able to earn some certain benefits i.e., Bluebik Group may have insufficient information to enter into a contract with you or perform our obligations or commitments in some circumstances.

The objectives for Bluebik Group’s Processing of your Personal Data are as follows:

No.	Objective relating to customers	Legal Basis
1.	to create customer’s account and/or membership account, to manage purchase order, to manufacture products and/or to provide services, to deliver products and/or services, to manage accounting and financial activities, after-sale services, product return services and any activity in connection with the sale of products, provision of services and customers’ request.	• contractual basis
2.	to contact customers, to conduct marketing communications, to advertise and promote products and services, to coordinate and contact for business, marketing and data analysis including offering appropriate products and/or services through various channels e.g., email, SMS, applications, social media, phone and direct mail. In addition, to perform marketing research such as survey, interview and satisfaction inquiry regarding products and services.	• legitimate interest basis
3.	to implement and maintain security measures, e.g., logging into websites.	• legitimate interest basis
4.	to establish, exercise or defend legal rights or claims of Bluebik Group, and to comply with applicable laws	• legitimate interest basis

No.	Objective relating to suppliers and business partners	Legal Basis
1.	to conduct transactions regarding pre-execution of contracts such as vendor/supplier registration, account opening, qualification evaluation, vendor selection and procurement process.	• contractual basis
2.	to prepare and execute contracts as well as to manage contracts e.g., identity authentication, verification of authority, delegation of authority including supporting evidence for consideration, preparation and execution of the contracts.	• contractual basis
3.	to contact and coordinate with you in relation to the business operations between you and Bluebik Group.	• legitimate interest basis
4.	to comply with all applicable laws related to transactions e.g., the Civil and Commercial Code, the Securities Exchange Act and etc.	• legal obligation

No.	Objective relating to visitors and persons accessing to buildings, offices, factories and/or properties of Bluebik Group	Legal Basis
1.	to implement and maintain security and control of buildings, offices, factories and/or properties of Bluebik Group, to conduct security risk assessment, to manage on-site verification (e.g., exchange of identification card for visitor/entry card) in order for working or accessing in buildings, offices, factories and/or properties of Bluebik Group, to monitor regarding surveillance and security (e.g., CCTV recording), and to record Personal Data for security management (both electronic and non-electronic means).	• legitimate interest basis
2.	to manage security control process of Bluebik Group, for example, to conduct safety training before entering into buildings, offices, factories and/or properties of Bluebik Group.	• legitimate interest basis
3.	to perform health and safety management	• vital interest basis
4.	to comply with all applicable laws related to public health interest e.g., health protection from the dangerous diseases, contagious diseases or epidemics which enter into the Kingdom of Thailand	• legal obligation

No.	Objective relating to shareholders, bondholders, directors and executives	Legal Basis
1.	to manage Bluebik Group’s corporate matters, shareholders’ meeting, selection of directors and/or executives, meetings of the board of directors and/or executives, rights and obligations of shareholders and bondholders, dividend payment, bond interest payment, document verification and accounting and reporting activities, and to deliver relevant documents.	• Legal obligation
2.	to manage transactions regarding the executive position and directorship of Bluebik Group, to be supporting documents of the relevant transactions, to record, collect, use and disclose Personal Data of shareholders, bondholders, directors and executives, and to prepare and manage directors’ conflict of interest report.	• contractual basis • legitimate interest basis • Legal obligation
3.	to comply with applicable laws for a private limited company, a public limited company and/or a listed company in the Stock Exchange of Thailand (as applicable), and to process any appointment, removal, registration and/or any procedure under the applicable laws.	• legal obligation

2. Collected Data

For objectives as specified above, Bluebik Group may collect, use and disclose your Personal Data. The types of your Personal Data collected will depend on the interaction between you and Bluebik Group, including but not limited to the following information:

• personal details such as name, surname, photo, gender, birthday, weight, height, ID number, passport number and resident country;
• sensitive Personal Data such as health data, food allergy data and biometric data;
• contact information such as address, contact number, fax, email, Line ID;
• financial information such as bank account number, credit/debit card data;
• purchase and service history,
• satisfaction information as provided by you;
• technical information such as IP address, cookies, accessed devices, location while using the website;
• voice recording of conversations, and photo and video recording by means of CCTV;
• any information that you sent to us for the website connecting such as comment and your location;
• public social media information;
• securities holding information of directors, executives and persons related to directors and executives; and
• any other information you are willing to provide.

Bluebik Group’s websites may link to third party websites to provide relevant references. Bluebik Group is not responsible for such external contentmanaged by third party websites, which may contain separate privacy policies and data processing disclosures. The link to the website is not an authorization or representation of our affiliation with that third party. Bluebik Group is not in a position to endorse or control privacy policy, security policy, cookies policy and data collection policy of the third parties.

3. Retention

Your Personal Data will be collected for as long as necessary to satisfy the objectives for which your Personal Data has been collected. For example, if you ordered our products through our online channel, Bluebik Group will collect data related to your transaction and will keep such information as long as necessary to achieve the objective of that particular transaction, or if you subscribed to Bluebik Group’s newsletter, your information will be collected and used until you unsubscribe or notify us that you no longer want to receive the newsletter.

4. Consent

Bluebik Group may acquire your consent to collect, use and disclose your Personal Data for the following purposes, which include but are not limited to:

• collection and use your sensitive Personal Data as necessary;
• analysis of your preferences and consumption behavior in order to forecast your preferences based on your profile analysis in order to offer you with targeted content and advertisements;
• if you are a minor, incompetent or quasi-incompetent person whose consent must be given by their parent, guardian or curator (as the case may be); and/or
• sending or transfer of your Personal Data to another country, which may have inadequate personal data protection standards.

If it is necessary for compliance with the applicable laws, Bluebik Group may process your Personal Data without your consent. In this regard, Bluebik Group will strictly comply with the relevant laws regarding your Personal Data.

5. Disclosure of personal data

Bluebik Group may be required to disclose your Personal Data internally(refer to the appendix for the subsidiaries list) and may need to disclose Personal Data to a third party, both within Thailand and in other countries, who have appropriate personal data protection standards. In this regard, Bluebik Group will provide appropriate contract to protect your Personal Data:

Types of third parties that may receive your information e.g.;

• contractual parties who provide Bluebik Group’s services such as:
  • Data analysis service providers
  • Marketing agencies
  • Other agencies who operate or have an agreement with Bluebik Group
• trade partners
• certified authorities which Bluebik Group has requested to be certified for its own benefit including other auditing agencies
• any third party who has legitimate rights to access your Personal Data.

6. Accessing Website

Bluebik Group is obliged under Thai law to retain your computer traffic data, for at least 90 days from the date you entered Bluebik Group’s website. However, Bluebik Group will not use such data to analyze consumption behavior or conduct market research without your explicit consent.

7. Your rights

As a Data Subject, you have the following rights:

• to withdraw consent for the collection, use or disclose Personal Data;
• to request access to and obtain a copy of your Personal Data or to request the disclosure of the acquisition of your Personal Data obtained without consent;
• to request to obtain Personal Data and request the transfer of Personal Data to a third party if it can be done automatically;
• to object to the collection, use or disclosure of the Personal Data;
• to request to erase or destroy Personal Data, or anonymize the Personal Data to become anonymous;
• to request to restrict the use of Personal Data; and
• to request to update, complete and not misleading of Personal Data collected.

You can exercise your rights by sending Bluebik Group an email or sending a written notice to Bluebik Group, attaching a copy of your ID or equivalent details as requested. Bluebik Group will process such information received in accordance with, and to the extent permitted, by applicable laws.

Please note that Bluebik Group shall retain our rights under the laws to reject your request in certain circumstances. If Bluebik Group decides to reject your request, you will be notified of the reason for such rejection. Bluebik Group will try our best, also with considering technical capabilities, to answer your request on how we process your Personal Data. However, if you have unresolved concerns, you can complain to Bluebik Group or proceed further to the Data Protection Authorities.

8. Protection of Personal Data

Bluebik Group is committed to protecting your Personal Data under our security standards and will provide appropriate safeguards to protect your Personal Data in order to ensure that Personal Data will be legally and appropriately collected, used or disclosed.

9. Changes to Privacy Notice

Bluebik Group is committed to protecting your Personal Data under our security standards anBluebik Group reserves the right to make changes to this Privacy Notice to be appropriate and in accordance with any laws. Please frequently check to see any updates or changes to Bluebik Group’s Privacy Notice.

10. Contact

If you have any enquiries or would like to exercise your rights or need any help regarding your Personal Data, please send an email to the below address and provide us with your personal information together with evidence to verify your identity such as ID card. However, Bluebik Group may ask for additional relevant documents or may reject your request if Bluebik Group has received insufficient information.

Bluebik Group Public Company Limited

51 Naradhiwas Rajanagarindra Rd, Silom, Bang Rak, Bangkok 10500 

Tel +6626367011

Data Protection Officer: DPO

51 Naradhiwas Rajanagarindra Rd, Silom, Bang Rak, Bangkok 10500 

Email: [email protected]

Appendix

List of affiliates

(As at 1 November 2023)

1. GMVPI CO., LTD.
2. Bluebik Titans Co., Ltd.
3. Blue Parking Co., Ltd.
4. Orbit Digital Company Limited
5. Bluebik Group Public Company Limited
6. Bluebik Global Company Limited
7. Bluebik Vulcan Company Limited
8. Sauce Skills Company Limited

This policy was last updated on November 1, 2023.

I have completely read this notice and understood its contents.