PRIVACY POLICY

1. Introduction
1.1 We are committed to safeguarding the privacy of users received from Mom Tri’s Villa Royale co. Ltd., website. This policy applies to where we are acting as a data controller with respect to the personal data and determine the purposes and means of the processing of that personal data.
1.2 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of Hotel’s operation for your satisfaction, we will ask you to consent to our use of cookies when you first visit our website.
1.3 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can disband the use of our website’s cookies. You can also simply disregard inputting any details required in our website. Contacting us as you see fit.
1.4 In this policy, “we”, “us” and “our” refer to Mom Tri’s Villa Royale co. Ltd.,

2. Personal data
2.1 “Personal data” shall mean any information relating to an identified or identifiable natural person (‘Data Subject’); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity.
2.2 Data collected can include any information that can be used to identify an individual.
2.3 This may include data collected from you as given or as your computer setting allows.

3. How we use your personal data
3.1 In this this section we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
3.2 We may process your personal data as usage data. The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent OR our legitimate interests, monitoring and improving our website and services.
3.3 We may process your account data. The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely [the proper administration of our website and business OR the performance of a contract between you and us.
3.4 We may process your information included in your personal profile on our website (“profile data”). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business
3.5 We may process your personal data that are provided in the course of the use of our services (“service data”). The service data may include your email through to your enquiries sent through. The source of the service data is you. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business.
3.6 We may process information that you post for publication on our website or through our services (“publication data”). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent OR our legitimate interests, namely [the proper administration of our website and business.
3.7 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, promotion, special deals, rates, marketing and selling relevant goods and/or services to you.
3.8 We may process information relating to our customer relationships, including customer contact information (“customer relationship data”). The customer relationship data may include your name, your job title, your contact details, and information contained in communications between us and you. The source of the customer relationship data is you. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is [consent] OR [our legitimate interests, namely the proper management of our customer relationships.
3.9 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters.
3.10 We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
3.11 We may process identify general category of data. This data may include list specific items of data. The source of this data is our forms. This data may be processed for better communications between you and us.
3.12 We may process any of your personal data identified in this policy where necessary for the establishment.
3.13 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely [the proper protection of our business against risks.
3.14 In addition to the specific purposes for which we may process your personal data set out in this Section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3.15 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

4 Providing your personal data to others
4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
4.2 In addition to the specific disclosure of personal data set out in this section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5. Retaining and deleting personal data
5.1 This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 We will retain your personal data as follows:
(a) your personal data category or categories that has been collected will be retained for a minimum period of 60 days
5.3 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a) the period of retention of each type of personal data category which will be determined based on a specified criteria.
5.4 Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6 Amendments
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

7 The GDPR provides the following rights for individuals:
7.1 The right of access
7.2 The right to rectification
7.3 The right to erasure
7.4 The right to restrict processing
7.5 The right to data portability
7.6 The right to object
7.7 The right to be informed

8 Rights in relation to automated decision making and profiling.
About cookies
8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
8.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Cookies that we use
8.4 We use cookies for the following purposes:
(a) authentication – we use cookies to identify you when you visit our website and as you navigate our website cookies used for this purpose are: identify cookies
(b) status – we use cookies to help us to determine if you are logged into our website cookies used for this purpose are: identify cookies
(c) personalisation – we use cookies to store information about your preferences and to personalise the website for you. Cookies used for this purpose are: identify cookies
(d) security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally.
(e) analysis – we use cookies to help us to analyse the use and performance of our website and services.
(f) cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.
Cookies used by our service providers
8.5 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
8.6 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://policies.google.com/privacy.
8.7 If you block cookies, you will not be able to use all the features on our website.

9. Our details
9.1 This website is owned and operated by Mom Tri’s Villa Royale co. Ltd.,
9.2 This website is created by Web connection
9.3 Our principal place of business is at 12 Kata Noi road, Kata Noi beach, Phuket 83100 Thailand
9.4 You can contact us:
(a) by post, to the business address given above
(b) using our website contact form
(c) by telephone, on the contact number published on our website or
(d) by email, using the email address published on our website