Effective Date: 1 June 2022

Doctor Property Group Company Limited (“Doctor Property”, “we”, “our” or “us”) respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, disclose, store and protect personal data when you use our website, contact us, enquire about a property, list a property with us, engage our services, communicate with our team or otherwise interact with our business.

We process personal data in accordance with applicable Thai law, including the Personal Data Protection Act B.E. 2562 (2019) (“PDPA”).

1. Personal Data We Collect

Depending on how you interact with us, we may collect the following categories of personal data:

Contact and Identification Information

This may include:

• name;
• email address;
• telephone number;
• country of residence;
• postal address;
• preferred language;
• nationality, where relevant to a transaction or enquiry; and
• other information you choose to provide when contacting us.

Property Enquiry and Preference Information

Where you enquire about purchasing, renting or investing in property, we may collect information such as:

• properties you have enquired about;
• preferred locations;
• property type;
• budget;
• ownership or investment preferences;
• intended use of a property;
• viewing requests;
• communication history; and
• other property requirements you provide to us.

Seller, Landlord and Property Information

Where you ask us to market, sell, rent or manage a property, we may collect:

• your contact and identification information;
• your relationship to the property;
• property ownership and title information;
• property address and location;
• property photographs, plans and specifications;
• pricing and commercial information;
• tenancy or occupancy information;
• information required to prepare listings or facilitate transactions; and
• correspondence and records relating to our services.

Transaction and Administrative Information

Where necessary in connection with a property transaction or other service, we may collect or process:

• reservation or booking information;
• contracts and transaction documents;
• copies or details of identification documents where reasonably required;
• payment or deposit information;
• billing information;
• records of payments made or received;
• information required by lawyers, accountants, financial institutions, developers, property owners or other parties involved in a transaction; and
• correspondence relating to negotiations, due diligence, contracts and completion.

We will only collect sensitive or higher-risk personal information where reasonably necessary and where permitted by law.

Communications

We may keep records of communications with you, including communications by:

• email;
• telephone;
• WhatsApp or other messaging services;
• website enquiry forms;
• social media; and
• in-person communications where relevant to our business relationship.

Website and Technical Information

When you use our website, certain information may be collected automatically, including:

• IP address;
• browser type;
• device type;
• operating system;
• referring website;
• pages viewed;
• date and time of visits;
• approximate location derived from technical information;
• cookie identifiers; and
• website interaction and analytics data.

2. How We Collect Personal Data

We may collect personal data:

• directly from you;
• through our website and enquiry forms;
• through email, telephone, WhatsApp, social media or other communications;
• during property viewings, meetings or transactions;
• from property owners, developers, landlords, tenants, buyers, sellers or their representatives;
• from lawyers, accountants and other professional advisers;
• from publicly available sources;
• through advertising, analytics and website technologies; and
• from third parties where the disclosure is lawful and relevant to the services we provide.

3. How We Use Personal Data

We may use personal data for the following purposes:

Property Enquiries and Services

To:

• respond to enquiries;
• recommend suitable properties;
• arrange property viewings;
• communicate with buyers, tenants, sellers, landlords and developers;
• market properties;
• provide property sales, rental, management or related services;
• facilitate negotiations;
• coordinate transactions; and
• provide customer support.

Contracts and Transactions

To:

• take steps requested before entering into a contract;
• prepare or administer agreements;
• facilitate reservations, deposits and transactions;
• communicate with parties involved in a transaction;
• assist with due diligence;
• maintain transaction records; and
• perform our contractual obligations.

Business Administration

To:

• maintain our customer and property records;
• manage our business relationships;
• administer our website and systems;
• manage accounting and financial records;
• manage enquiries and sales activity;
• prevent fraud or misuse of our services;
• resolve disputes; and
• establish, exercise or defend legal claims.

Marketing and Communications

Where permitted by law, we may use your contact information to:

• send information about properties;
• provide market or company updates;
• send newsletters;
• notify you of new listings or opportunities that may be relevant to your enquiry; and
• communicate about services provided by Doctor Property.

You may opt out of direct marketing communications at any time.

Website Improvement, Analytics and Advertising

We may use website and technical information to:

• operate and secure our website;
• understand how visitors use the website;
• analyse traffic and website performance;
• improve website functionality and user experience;
• measure advertising effectiveness; and
• improve our marketing activities.

4. Legal Basis for Processing

Depending on the circumstances, we may process your personal data on one or more of the following legal bases:

Contractual Necessity

Processing may be necessary to take steps at your request before entering into a contract or to perform a contract with you.

Legitimate Interests

We may process information where reasonably necessary for our legitimate business interests, including:

• responding to property enquiries;
• operating a real-estate agency;
• communicating with clients and prospective clients;
• maintaining business records;
• improving our services;
• protecting our business and website; and
• conducting appropriate marketing activities.

Where we rely on legitimate interests, we consider those interests against your privacy rights and interests.

Legal Obligations

We may process or retain information where required to comply with Thai law, regulatory obligations, court orders, accounting requirements or other applicable legal obligations.

Consent

Where consent is required by law, we will request your consent before carrying out the relevant processing.

Where processing is based on consent, you may withdraw that consent at any time. Withdrawal of consent does not affect processing lawfully carried out before the consent was withdrawn.

5. Sharing Personal Data

We may disclose personal data where reasonably necessary for our business or for a property transaction.

Recipients may include:

• property owners and landlords;
• prospective buyers or tenants;
• property developers;
• authorised representatives of buyers, sellers, landlords or tenants;
• lawyers and legal advisers;
• accountants and auditors;
• financial institutions and payment providers;
• property management and maintenance providers;
• contractors and professional consultants;
• website hosting and IT providers;
• customer relationship management and communications providers;
• analytics and advertising providers;
• government authorities, regulators, courts or law-enforcement authorities where required by law; and
• other parties where reasonably necessary to facilitate a transaction or provide a service requested by you.

We do not sell personal data to third parties.

Where we use external service providers to process personal data on our behalf, we take reasonable steps to ensure that appropriate privacy and security arrangements are in place.

6. International Transfer of Personal Data

Some of the systems and service providers we use may process or store information outside Thailand.

Where personal data is transferred internationally, we will take reasonable measures to ensure that the transfer is made in accordance with applicable data-protection law and that appropriate safeguards are used where required.

This may include transfers to service providers operating cloud hosting, communications, analytics, customer-management or other business systems.

7. Cookies and Similar Technologies

Our website may use cookies and similar technologies.

Cookies may be used for purposes including:

• essential website functionality;
• remembering preferences;
• website security;
• traffic measurement;
• analytics;
• improving website performance; and
• advertising or measuring advertising effectiveness.

Some cookies are necessary for the website to function. Other cookies, including certain analytics or advertising cookies, may be subject to your consent where required by law.

You may manage cookies through your browser settings and, where available, through the cookie controls provided on our website.

Disabling some cookies may affect the functionality of the website.

8. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including to:

• provide our services;
• maintain appropriate business and transaction records;
• comply with legal, tax and accounting obligations;
• resolve disputes; and
• establish, exercise or defend legal claims.

Different categories of information may be retained for different periods.

Where there is no continuing business or legal need to retain personal data, we will take reasonable steps to delete, destroy or anonymise it.

9. Security of Personal Data

We take reasonable administrative, technical and organisational measures designed to protect personal data against:

• unauthorised access;
• unlawful disclosure;
• accidental loss;
• alteration;
• misuse; and
• destruction.

Access to personal data is limited to persons who reasonably require access for business purposes.

No method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

10. Your Rights

Subject to the conditions and exceptions provided under applicable law, you may have the right to:

• request access to personal data we hold about you;
• request a copy of your personal data;
• request correction of inaccurate or incomplete information;
• request deletion, destruction or anonymisation of personal data;
• request restriction or suspension of processing;
• object to certain processing;
• withdraw consent where processing is based on consent;
• request data portability where applicable;
• object to direct marketing; and
• lodge a complaint with the competent Thai data-protection authority.

To exercise your rights, please contact us using the details below.

We may need to verify your identity before acting on a request.

Certain rights are subject to legal exceptions. For example, we may be required to retain information where necessary to comply with legal obligations or establish, exercise or defend legal claims.

11. Marketing Communications

You may ask us to stop sending direct marketing communications at any time.

You can do this by:

• using an unsubscribe option contained in a marketing email, where available; or
• contacting us directly.

Opting out of marketing does not prevent us from contacting you where necessary in connection with an existing enquiry, transaction, contract or service.

12. Third-Party Websites and Services

Our website may contain links to websites, platforms or services operated by third parties.

We are not responsible for the privacy practices, content or security of third-party websites or services.

We recommend reviewing the privacy policy of any third-party service before providing personal information.

13. Children’s Personal Data

Our services are not specifically directed at children.

We do not knowingly seek to collect personal data from children except where reasonably necessary in connection with a legitimate property, family or legal transaction and where the processing is permitted by law.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

• changes in our business;
• changes in our website or technology;
• changes in the services we use; or
• changes in applicable law or regulatory guidance.

The current version will be published on this page together with its effective date.

15. Contact Us

If you have questions about this Privacy Policy, wish to exercise your privacy rights or have concerns about how we process your personal data, please contact:

Doctor Property Group Company Limited

• Email: info@doctor-property.co.th
• Phone: +66 6 1210 0497
• Address: 107/24 Moo 2, Na Mueang, Koh Samui, Thailand 84140

16. Governing Law

This Privacy Policy and our processing of personal data are subject to the applicable laws of Thailand.

Nothing in this Privacy Policy limits any rights available to you under mandatory data-protection legislation.

17. Language

This Privacy Policy is provided in English.

Where a translation is provided for convenience and there is an inconsistency between the English version and a translated version, the English version will prevail to the extent permitted by applicable law.