This privacy notice describes how we at CURADEN Thailand gather, save, and use information relating to individual users of this website. When you visit this website, you acknowledge and agree that information will be gathered and used as described in this privacy statement.
Table of Contents
- General Information and Contact
- Persons Protection of personal data
- Type of personal data collected
- Purpose of data processing by CURADEN
- Transfer of personal data to third parties
- Use of personal data for direct marketing
- Online Marketing and Web Analytics Services
- Use of social media: Social Media plugins
- Children as website users
- Storage period
- Place of storage and international transfers of your personal data
- Right to inspection, modification and deletion of your personal data
Version of: May 29, 2018
1) General Information and Contact Persons
It is very important to us to protect your privacy, so that CURADEN handles your personal data in a careful, trustworthy and respectful manner. We collect personal data in order to offer our esteemed customers better service and to constantly improve their experience on CURADEN’s websites, Online Shops and Apps. CURADEN always handles your personal data in compliance with the applicable data protection laws. This Privacy Notice will give you a clear overview of when and why CURADEN collects data about you when you use CURADEN’s websites, stores or Apps, and how CURADEN uses the data that you provide. We shall also describe the recipients to whom we transmit your data and what options and statutory rights you have for the processing of your personal data.
The data controller for this website is CURADEN (Thailand) Co.,Ltd. 48 4th flr, Narathiwasrachanakarin Rd., Silom, Bangrak, Bangkok 10500. Thailand. email: [email protected]
If you have any questions about the processing of your data, you can contact our data protection officer directly, who is also available for requests for information, requests or complaints:
CURADEN (Thailand) Co.,Ltd. 48 4th flr, Narathiwasrachanakarin Rd., Silom, Bangrak, Bangkok 10500. Thailand. email: [email protected]
In the event of any contradictions between this Privacy Notice and other applicable terms of business or contract clauses of CURADEN, the provisions of this Privacy Notice shall take priority.
By visiting the CURADEN website, you express your consent to information being collected and used in the manner described in this Privacy Notice.
2) Protection of personal data
CURADEN uses data networks protected by the standard firewalls and password systems, among other things, to ensure the security and confidentiality of any personal data recorded. When handling your personal data, we take appropriate technical and organizational measures to protect your data from loss, misuse, unauthorized access, disclosure, alteration or destruction.
For our CURADEN websites, we use encryption techniques (SSL or TLS encryption) for security reasons to protect your personal data and other confidential content. The lock icon and “https://” in the browser address box show you that the website is encrypted.
3) Type of personal data collected
The term “personal data” for the purposes of this Privacy Notice means information that can be used to identify you personally.
“Personal data processing” means any form of handling of your personal data, such as recording, using, storing, disclosing, transmitting or deleting such data.
CURADEN automatically records personal data, when you use and interact with our websites, Online Shops or Apps. Moreover, the personal data that you supply is recorded automatically or manually (e.g., during sign-up and creation of your user profile or customer account). The data entry forms show you what data items are collected.
3.1 Data that is recorded automatically
When you use our websites, Online Shops or Apps, CURADEN records certain personal data even if you do not sign in or actively provide information.
When you open a CURADEN website, your browser communicates data to us. The data is also stored in the log files of our system. Those data are not stored together with other personal data. The following data are recorded:
- which CURADEN websites are visited;
- the number of visits, as well as the date, time and duration of the visit;
- the source or reference of the site from which the user reached the website;
- Hardware and browser information (operating system, browser type and version, etc.);
- IP-address used;
The data are stored in log files for functional purposes of the website. In addition, we use the data to optimize the website and protect the security of our IT systems. No data are analyzed for marketing purposes in this context.
Such data are deleted as soon as they are no longer needed for the purpose for which they were collected. Data recorded for presentation of the website are deleted at the end of each session. Data stored in log files are generally deleted within one month, at the latest. Storage for a longer period is possible only if the users’ IP addresses are deleted or coded so that the requesting client can no longer be identified.
Recording the data for broadcasting of the website and storage of the data in log files are absolutely necessary in order to operate the website. The user therefore has no right to object.
Most browsers accept such cookies automatically. You can also configure your browser to block cookies. For further details, see the user instructions or help system of your browser.
- Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
- Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
- Chrome: https://support.google.com/chrome/answer/95647?hl=en&hlrm=en
- Safari: https://support.apple.com/kb/PH21411?locale=de_DE&viewlocale=en_US
If you disable cookies, you may not be able to make full use of all the features of this website.
In certain features of CURADEN websites, Online Shops or Apps, you can use location-specific services (e.g., tooth-brushing app/ preventionOne). In such cases, you will be informed in advance that your actual location will be tracked and processed. You can disable location determination in the hardware settings.
3.2 Data during interaction with CURADEN, when opening a customer account and for contract processing
CURADEN processes the personal data that you give us when you sign up with CURADEN, for example by registering or actively providing information. Registration is required in order to store certain content and services on our website and for the performance of a contract with you or for the performance of precontractual measures.
Most of the information that CURADEN records about you is personal data that you shared with us voluntarily, for example on our websites, in our Online Shops, on mobile Apps, at local businesses, etc. Other sources from which we obtain your personal data include:
- our POS systems (i.e., certain information about you may be recorded when you shop at our POS);
- other companies of the CURADEN Group; and
- third parties (e.g., credit agencies, law enforcement/supervisory authorities and companies providing commercially available databases etc.).
For example, you give us personal data when you contact us by means of the CURADEN contact form or by e-mail. The data entry forms show you what data items are collected. Your personal data are processed by CURADEN for the sole purpose of answering your query or for any other purpose for which you sent the form and then stored for technical administration. After completion of the processing, your query or other contract form will be deleted, unless we are required by law to retain the data.
You have the option of setting up a customer account (e.g., for the Online Shop or preventionOne). For your convenience, CURADEN lets you use a “single sign-on” method for our websites (see item 4.1 below). If you have registered for a CURADEN account, you sign into all our platforms with the same sign-on data (Single-Sign-on).
The data entry forms show you what data items are collected. CURADEN’s forms ask for basic personal data, indicating which input fields are required and which are optional. The data that you enter when creating a customer account will be stored and used for the sole purpose of contract processing unless you expressly consent to more extensive use.
For example, the following information may be requested and processed:
- First and last names
- Date of birth and age;
- Home address;
- Shopping habits;
- Information about purchasing power;
- Customer and shopping preferences;
- Delivery address;
- Billing address;
- Credit card and account information;
- Language preferences;
- Telephone number(s);
- E-mail address(es);
- Customer or member numbers;
- Information on subscription newsletters or other advertising;
- Consent to receive advertising;
- Online customer account information (e.g., account-opening date, user name or profile picture).
Data on customer’s activities
- Contract data (including the date of signature, type, contents; parties, effective period and value of the contract, and any claims asserted thereunder);
- Purchasing information (including the date, place and time of purchase; the nature, quantity and value of the purchased goods and services; shopping cart; discontinued purchase in shopping cart; payment method used; paying agent; shopping history);
- Customer service information (including product returns, complaints, warranty claims, delivery information);
- Session data concerning visits of our websites, mobile apps or offers on our Internet platforms, multimedia portals or social networks (including the duration and frequency of the visits, language and country settings, information and browsers and the computer operating system, Internet Protocol addresses, search words, and search results, evaluations given);
- Location-specific data when using mobile devices.
You can delete your customer account at any time using the delete feature or button in the customer account or by sending a message to the data controller (see item 1 above). Upon complete performance of the agreement or upon deletion of your customer account, the data are blocked and stored for the retention period required under commercial and tax law and then deleted at the end of the retention period, unless you have expressly authorized further use of your data or we reserved a legally permitted use of the data after informing you of such use.
Participation in raffles, prize drawings, or surveys, etc.:
If you would like to participate in raffles, prize drawings, or surveys, etc., CURADEN may ask you in some cases for further personal data, such as your postal address, in order to be able to send you the prize. The data entry forms show you what data items are collected and to what purpose. Personal data collected for raffles, prize drawings, or surveys are generally deleted as soon as the purpose of the action has been fulfilled.
4) Purpose of data processing by CURADEN
“CURADEN”, herein, refer to CURADEN (Thailand) Co.,Ltd, the subsidiary company of CURADEN AG in Thailand. Your personal data are used by CURADEN for the purposes described below.
4.1 CURADEN “single sign-On”
The personal data that you give CURADEN when you first register are used for identification and authentication purposes for all our services. You can therefore use the same sign-on data no matter where you are or which device you are using. Thanks to the overall single sign-on, our systems are able to identify you regardless of your location. This means that you do not have to re-register when you want to use a new CURADEN web service or are travelling in another country.
4.2 CURADEN’s provision of goods and services
CURADEN uses your personal data to perform orders and contracts, including to send confirmations of orders and forwarding, delivery confirmations, and to make deliveries and invoicing.
In addition, your information is used to check your age to confirm that you have the minimum legal age, to ensure compliance with the minimum legal age requirements for online purchasing or other purposes related to the applicable data protection and/or distribution laws.
Moreover, your personal data may be used for organizing and carrying out customer service tasks, e.g., after you use the contact form to get in touch with CURADEN.
4.3 Improving CURADEN products and services
CURADEN uses your personal data to create a profile that helps us understand how CURADEN products and services are used so that we can develop more interesting and relevant products and services and tailor them to your needs.
4.4 Communication services and other requested products or services
CURADEN uses your personal data to prepare, manage and carry out customer communications by post or by electronic communications media.
Moreover, we use your information to prepare the requested products or services (e.g., e-mail newsletter, advertising campaigns, raffles, contests, participation in events (e.g., iTOP Events), etc.
4.5 Comment feature
If you use the comment feature that may be available on certain CURADEN websites, your selected user name and the date and time of posting will be stored and displayed next to your comment on the website. We also log and store your IP address. The IP address is saved for tracking purposes in the event that third-party rights are infringed by a comment made or illegal content is posted. If a third party complains of content you have published and our examination confirms that it is unlawful, you will be contacted at the e-mail address you have specified. CURADEN deletes comments that are complained of as unlawful by third parties.
You can opt into following the replies to your comment or follow-up comments. To opt in, you will receive a confirmation e-mail to validate your e-mail address (Double Opt-In process). Your option to participate in ongoing comments can be revoked at any time with effect for the future. Further information about how to opt out will be provide in the confirmation e-mail or CURADEN website.
4.6 CURADEN Apps
CURADEN provides several apps that let you upload and/or save certain information. Depending on the app, you may be asked for various personal details (e.g., your name, age, dental care information (frequency, duration, Bleeding Index data, etc.), location, etc.); the entry form will indicate which information is required to provide the service and which information is optional.
4.7 Marketing activities and events
In addition, in line with applicable law and where appropriate, CURADEN may process your personal data and personal data of third parties for the following purposes, which are in our (or, as the case may be, any third parties’) legitimate interest, such as:
- sending of advertising, newsletters or advertising mailings as well as organizing and holding contests and prize drawings, including for the notification and publication of the winners on CURADEN websites, multimedia portals or social networks;
- Organizing and holding special occasions such as events and advertising events;
- To prevent unnecessary advertising thanks to the findings from the analysis of customer behaviour, for customized and individualized direct marketing;
- individualized and personal and/or anonymous and group-related identification, classification and analysis of current and potential customer needs and interests;
- individualized and personal and/or anonymous and group-related classification and analysis of customer behaviour and potential;
- statistical analysis of customer behaviour based on anonymized customer data.
5) Transfer of personal data to third parties
For data processing and storage, CURADEN works together with other companies and individuals or enters into subcontracting agreements with companies or individuals. When companies perform services for CURADEN, we enter into written agreements with those companies to ensure that they cannot use your personal information for any purposes other than those that have been clearly specified or are required by law. CURADEN will transfer your data to third parties in the cases defined below.
CURADEN will transfer your data to third parties:
- to ensure the protection and security of all CURADEN customers and of third parties (e.g., technical support service related to the CURADEN website);
- to protect the rights and property of CURADEN’s and of CURADEN’s customers and of third parties;
- to comply with legal obligations of disclosure imposed on CURADEN by law or in legal proceedings (orders issued by a court or by a law enforcement authority, etc.).
5.2 Order processing and credit checks
Your data may be transferred by CURADEN:
- when companies perform services for CURADEN, e.g., parcel delivery, payment processing or customer service jobs, to the extent that the data transfer is necessary for the delivery of goods or services.
- Parcel shipment and delivery may be handled by forwarding agents namely, Thai post office, Flash or Kerry.
- If you give your express consent in the ordering process, your e-mail address may be communicated [to the forwarding agent] prior to product delivery so that you can agree on a delivery date or receive an announcement of delivery. Otherwise, the recipient’s name and delivery address will be given to the forwarding agent for delivery purposes but only to the extent necessary for product delivery. In that case, you will not be able to agree on the delivery date in advance with the forwarding agent or request delivery status information. You may revoke your authorization with effect for the future by addressing the data controller (see item 1 above).
- To the extent necessary for payment processing, your payment data may be forwarded to the credit institution engaged for payment processing. Such data shall be forwarded only to the extent necessary for payment processing.
- In the case of credit card payments, your payment data may be forwarded to the following payment solutions in the course of payment processing:
- In order to protect our legitimate interest in determining the solvency of our clients, and to prevent fraud and other abusive payment practices. In such cases, CURADEN and the credit institutions involved reserve the right to perform verifications or check credit ratings before payment transactions, particularly if CURADEN tenders performance in advance of payment (e.g., delivery with an invoice). To that purpose, internal and external sources of information may be used or forwarded to credit reporting agencies.
You may object to the processing of your data at any time by sending a message to the data controller or the credit institution, but CURADEN or the credit institution, where applicable, shall retain the right to process your personal data, to the extent necessary to process your payment according to the contract.
5.3 Analysis and Marketing Activities
CURADEN will transfer your data to third parties:
- in order to be able to send direct marketing with your consent or in our legitimate interests (see item 6 below);
- if you ask CURADEN to forward your personal data to third-party websites or platforms, such as social networking websites. Please note that after the transmission of your personal data for marketing purposes to another company, the data received by the other company is subject to the data protection practices of that other company (see item 8 below).
6) Use of personal data for direct marketing
6.1 Signing up for the e-Mail Newsletter
When entering your e-mail-address, you have the option of signing up for various e-mail newsletters (e.g., about products, product news, job vacancies, etc.) of CURADEN, in order to receive regular information about our offers or job vacancies. Providing further information, e.g., your first and last names, is optional and will be used so that we can address you personally.
The newsletters will not be sent to you until you have entered your e-mail address and clicked on the link in the confirmation e-mail that will be sent to you (Double Opt-in process). By clicking on the confirmation link, you inform CURADEN of your authorization to use your personal data. To keep a record of your consent, CURADEN stores your IP address and the date time of your consent.
Each e-mail Newsletter contains a link that lets you unsubscribe from the mailing list. Alternatively, you may contact the data protection officer (see item 1). Your personal data will then be deleted, unless further use of the data is permitted by law.
6.2 Mailing of the e-mail newsletter to existing customers
CURADEN processes personal data of you and other persons, which may also come from publicly accessible sources, to the extent permitted and deemed appropriate to us, also for advertising and marketing purposes or for the purpose of customer acquisition in which we (and sometimes also third parties) have a justified interest corresponding to the purpose.
Hence, CURADEN is permitted by law to send you by post or e-mail regular offers for products or services from our range similar to the items you purchased, even without your explicit consent, if you provided your e-mail address to CURADEN when purchasing goods or services.
You are entitled, at any time with effect for the future, to prohibit your postal or e-mail address being used for the above-described marketing purpose by clicking on the link in the e-mail to remove yourself from the mailing list, or by sending a message to the data protection officer. Upon receipt of your objection, the use of your e-mail address for marketing purposes will be discontinued without delay.
7) Online Marketing and Web Analytics Services
The anonymized data recorded in cookies when you open our website may be used for analytical purposes and to optimize our website in relation to third-party services. Such third parties themselves maybe thereby collect personal data about CURADEN users to a limited extent insofar as they can recognize them based on their own cookies or logins, for example.
CURADEN uses the following third-party services for Online Marketing and web analytics services:
- DoubleClick by Google;
- Google Analytics: https://support.google.com/analytics/answer/6004245?hl=en
- Facebook Custom Audience (“Facebook-Pixel”): https://www.facebook.com/about/privacy/
Web Analytics tools provide statistics and graphics that give insights into use of our websites and our users’ browsing behaviour. In the process, the data about the use of a website is transmitted to the server used to that purpose. Such servers may be located abroad, depending on the provider of the online-marketing or web analytics Tools.
7.1 Google tools
In the case of the tool Google Analytics used for web analytics, the recorded data are transferred, including truncated IP addresses, which prevents the identification of individual devices.
Because of the Google tools used, your browser automatically sets up a direct connection with the Google server. CURADEN has no control over the scope and further use of the data collected by Google using that tool.
Google complies with Swiss and EU data protection provisions and has registered with the US Department of Commerce for the “Swiss-U.S. Privacy Shield” and “EU-U.S. Privacy Shield” (for information about Privacy Shield, see https://www.privacyshield.gov). Any transfer of such data by Google to third parties will be made only to the extent permitted by statutory provisions or for the purposes of order processing.
If you wish to be excluded from the tracking actions of analytical services, you must adjust your browser settings to block the relevant cookies (see item 3.1: Adjusting the cookie settings on your browser). You can permanently disable advertising cookies by selecting the appropriate setting in your browser software or by downloading and installing the Browser-Plug-in available at the following link: http://www.google.com/settings/ads/plugin?hl=en
7.2 Facebook tools (Facebook Audience, Facebook Pixel)
Facebook Pixel is an analytics tool that measures the effectiveness of advertising on Facebook. It helps advertisers understand who is performing which actions on the website. If users grant their express consent, the tool can be used to track the user’s behaviour after viewing or clicking on a Facebook advertisement. This process is used to analyse the effectiveness of Facebook advertisements for statistical and market research purposes and thus help optimize future advertising campaigns.
The data collected are anonymous for CURADEN and therefore cannot be used to identify the user. The data are stored and processed by Facebook, however, so that the data may be linked with the relevant user profile and be used by Facebook for its own advertising purposes in accordance with Facebook’s data policy (https://www.facebook.com/about/privacy/). You can allow Facebook and its partners to insert advertisement on and outside of Facebook. A cookie may also be stored on your computer to that purpose. Such processing is not performed unless you grant your express consent.
Facebook Inc., which is based in the USA, is certified under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, which ensures compliance with the data protection standards applicable in Switzerland and in the EU.
8) Use of social media: Social Media plugins
8.1 “Single sign-on” process by means of a social media account
CURADEN lets you use your sign-in data of your user account on a social network (e.g., Facebook or Google+) to sign in and/or create a customer account. When social media plugins are used, the user’s personal data are shared with social network providers.
When you open a CURADEN website that contains such a plugin, your browser sets up a direct connection with the relevant social network’s servers. The content of the plugin will then be transmitted directly from the social network to your browser and integrated into the page you are viewing. Through integration of plugins, the social network will be informed that your browser has opened the corresponding page of our website, even if you do not have a profile with the social network in question or are not currently logged into it. Such information (including your IP address) is transmitted directly from your browser to one of the social network’s servers, where it is stored.
8.1.1 Facebook Connect
If you want to use your Facebook profile to log into the CURADEN website, the social plugin “Facebook Connect” lets you use the single sign-on process. The social plugin “Facebook Connect” is operated by the social network Facebook, of the company Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA (“Facebook”). You can recognize “Facebook Connect” social plugins by the blue button with the Facebook logo and the label “Log in with Facebook” or “Connect with Facebook” or “Sign in with Facebook”.
You can also click the “Facebook Connect” button on our website to log in or register with our website using your Facebook Connect user data.
When you click the “Facebook Connect” button on our website, in order for us to receive the general information in your Facebook profile and the data that you have made generally available by selecting “Public” in your Facebook privacy settings, you must first expressly consent to data sharing with Facebook by selecting the appropriate option before the log-in process. Such information includes your User ID, name, profile picture, age and gender.
You may revoke your consent at any time by sending a message to our data protection officer (see item 1).
Facebook Inc., which is based in the USA, is certified under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, which ensures compliance with the data protection standards applicable in Switzerland and in the EU.
For more information about the purpose and scope of the data collected and the further processing and use of the data by Facebook, as well as your related rights and optional privacy settings, please see Facebook’s data policy at: http://www.facebook.com/policy.php
If you do not want Facebook to assign the data collected on our website directly to your Facebook profile, you need to log out from Facebook before visiting our website. You can also completely block the downloading of Facebook plugins with add-ons for your browser, e.g., by using “Adblock Plus” (https://adblockplus.org/de/).
8.2 Using social media by means of “social media plugins”
CURADEN may use social media plugins on the website, e.g., from social networks such as Facebook, Google+, Twitter or Instagram. Those platforms have their own privacy policies, which are beyond CURADEN’s control.
To increase the protection of your data when you visit the CURADEN website, we have integrated two different mechanisms:
- DoubleClick solution (Facebook, Google+, Twitter)
The social network plugins are initially disabled and can be integrated into the site by means of a “2-Klick” solution. Disabled plugins, which are greyed out, are not able to set up a connection with the social network’s servers until you express your consent to data sharing by double-clicking them. At that point your browser will connect directly to the social platform’s servers. The content of the relevant plugin will then be transmitted directly from the social network to your browser and integrated into the site. The plugin will then share data (including your IP address) with the social network. CURADEN has no control over the scope of the data collected by the social network by means of the plugin. Through integration of plugins, the social network will be informed that your browser has opened the corresponding page of our website, even if you do not have a profile with the social network in question or are not currently logged into it. The collected information (including your IP address) is transmitted directly from your browser to one of the social network’s servers, where it is stored. When you interact with the plugins, the corresponding information will also be transmitted directly to one of the social network’s servers and stored there. That information will also be published on your social network profile and your contacts will be displayed there.
- Shariff solution (LinkedIn, Instagram)
The buttons of the social networks LinkedIn and Instagram are integrated into the site using an HTML link. Such integration ensures that, when you open a page of our website that contains such buttons, no connection will be set up with the social network’s servers yet. When you click the button, a new browser window will be displayed and the page of the social network will be called where you can interact with its plugins (you may have to enter into your login data first).
You can revoke your consent at any time by clicking the enabled plugin again to disable it, or by logging out of the social network and closing the website. Such revocation will not affect the data already transmitted to the social network, however.
The social networks listed below have signed the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, certifying compliance with the data protection standards applicable in Switzerland and in the EU.
- Facebook, Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA: http://www.facebook.com/policy.php
- Google+, Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA: https://www.google.com/intl/de/policies/privacy/
- Twitter, Twitter Inc., 1355 Market St, Suite 900, San Francisco, CA 94103, USA: https://twitter.com/privacy
- Instagram, Instagram LLC., 1601 Willow Rd, Menlo Park, CA 94025, USA: https://help.instagram.com/155833707900388/
- LinkedIn, LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA: https://www.linkedin.com/legal/privacy-policy
8.3 Using YouTube Videos
CURADEN uses the YouTube embed function for display and playback of the videos from “YouTube”, which is owned by Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”).
Regardless of playback of the embedded videos, every time you open the website a connection is established with the Google network “DoubleClick”, which may trigger further data processing that is beyond our control.
Google LLC, which is based in the USA, is certified under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, which ensures compliance with the data protection standards applicable in Switzerland and in the EU.
9) Children as website users
In general, we do not intentionally collect any personal data of children and teens under 16 years of age. If we learn that we unintentionally recorded private data of children and teens under the age of 16, we take steps to delete such information as soon as possible, unless we are required by the applicable laws to retain that information.
If we know that a child is over 16 years of age but is considered underage according to the applicable laws, then we seek to obtain the consent of the child’s parent or guardian before using the child’s personal data.
10) Storage period
CURADEN retains personal data only so long as necessary in order to comply with the applicable laws and to safeguard our rights (statutory retention period, e.g., retention periods under commercial or tax law) or so long as necessary for the purposes for which the data were collected.
In particular, CURADEN retains the personal data collected from customers in compliance with the periods indicated below and deletes such data thereafter, unless there are statutory retention duties or reasons not to delete the data related to operational record-keeping, or we have informed you in advance of different storage periods.
- Data collected at the time of purchase in the online shop will generally be stored for a 10-year period after the last process operation for bookkeeping reasons;
- Data for marketing measures and advertising purposes are to be derived from the principle of whether the storage is necessary for the advertising address. Normally, data is deleted at the latest two years after no longer being used for advertising purposes.
- Data from correspondence, for example using the contact form, will be retained for six weeks after the last processing operation and then deleted;
- Data from applicants will be deleted after six months in case of a rejection. If the applicant consents to further storage of his or her personal data, the data will be stored on our systems and deleted within two years at the latest. If the applicant is hired, the data are transferred to an employee information system.
- Personal data collected by CURADEN for web analytics are deleted as soon as they are no longer needed or in any case by the end of the statutory maximal retention period, at the latest. In general, such data are deleted one month after entry.
- Data recorded for preparation of the website are deleted at the end of the relevant session. Data stored in log files are deleted within one month, at the latest.
11) Place of storage and international transfers of your personal data
CURADEN stores and processes your personal data in Switzerland or Singapore.
There may also be cases, however, in which CURADEN must transfer your personal data within the European Union (EU), where there is an appropriate standard of data protection, or outside the European Economic Area (“EEA”) to a country that does not ensure the same standard of data protection as the country in which our products and/or services are generally used. If the personal data that you provide during registration of a CURADEN account or when interacting with the CURADEN website is processed outside the European Union or EEA, we shall take reasonable steps to ensure adequate protection for your personal data.
If the standard of data protection in a country is not guaranteed by an adequacy resolution, we shall enter into a contract ensuring that the protection of your personal data will be equivalent to that in Switzerland at all times. To do so, we shall take one or more of the following measures:
- by entering into EU Model Clauses with the service providers engaged, cf. https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en
- by ensuring that the service providers engaged are certified under the Swiss-US or EU-US Privacy Shield Frameworks (if the data recipient is based in the USA or stores the data there), cf. https://www.privacyshield.gov/
- by ensuring that the service providers engaged have Binding Corporate Rules (BCR) acknowledged by European data protection authorities, cf. https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/binding-corporate-rules_en.
12) Right to inspection, modification and deletion of your personal data
CURADEN has implemented mechanisms to ensure that you can exercise your legal rights concerning your personal data.
Once the data controller (see item 1 above) has received your request and sufficient information to confirm your identity, we shall provide you with a copy of your personal data available to us for which you have a legal right of access. Moreover, we shall inform you of the purposes for which your personal data are used, of the recipient of your personal data and the source of the information.
You may contact CURADEN in writing at any time to request changes in certain personal data that you consider erroneous or insignificant, or ask us to block, delete or otherwise remove your personal data to the extent permitted by the applicable law. We shall update, block, delete or remove your personal data as required by law.
Moreover, you have the option of revoking your consent that you previously granted to CURADEN for marketing activities and marketing communications. Marketing communications contain a simple mechanism of unsubscribing from future communications, such as a hyperlink that you can click to unsubscribe. You can unsubscribe by following the instructions in the relevant communication that you have received on a certain channel or by using the settings of your CURADEN customer account. Alternatively, you can contact us directly using the contact information stated below.
Please note, that even after receiving your request to block or delete your personal data, we may be required to retain some of your personal data for the purposes of our statutory or contractual recordkeeping obligations (e.g., for invoicing purposes) in which case we shall only block your personal data to the extent necessary to that purpose. Moreover, deletion of your personal data may have the effect that you can no longer receive or use the services for which you have signed up. Under certain conditions, you may be entitled to require us to transfer your personal data in a commonly used format to you or to a designated third party.
If you have questions about this policy, please send a letter to CURADEN (Thailand) Co,Ltd, 48 Narathiwasrajanakarin Rd. Silom Bangrak Bangkok 10500 Thailand or an e-mail to [email protected]