“PU” (“we”, “us”, “our”) is committed to protecting your privacy when you interact with us, our content, products, or services.
Purpose of this Policy
This policy explains our personal information handling practices. It describes how we may collect, use, and disclose information about you or your use of our content, products, or services. This policy is for the benefit of members of the community who use our products, services or “PU” Shop Online.
If we make changes to this policy, we will post those changes on the privacy page of the “PU” website. You can find the date of the most recent review at the end of this document.
1. Collection of Personal Information
1.1 How we collect personal information
The main circumstances in which “PU” collects personal information about you are:
(a) when you provide it to us
If you register as a user of “PU” digital services, you will provide information to us as part of your registration. You may also give us information when you buy from “PU” Shop Online, enter competitions or otherwise participate in “PU” events, functions or activities. For information about our collection and retention of payment information see below.
Your credit card details are only stored and transmitted in encrypted form. Unencrypted credit card information is not stored on our servers. Online credit card payments are currently processed using a third-party payment gateway service provider.
This provider delivers a PCI-DSS (plastic card industry data security scheme) compliant payment gateway service to “PU” Shop Online that is used to securely process customer payments.
If you use your credit card and the transaction is manual rather than electronic, the imprinted record will be stored by the “PU” Shop Online for the period that financial records are required to be retained.
(b) when someone else provides it to us on your behalf
Sometimes someone else such as a carer (including a parent) or friend might provide us with information about you so that we can provide you with products or services. Other times we may collect personal information about you from publicly available sources.
For more information about our practices in relation to children, see below.
Additional information for parents and young people
Some digital services provided by “PU” may be specifically designed for children
The online protection of children is a shared responsibility between the ABC, the parent or carer, and the child. We strongly encourage parents and carers to monitor and participate in their children’s use of “PU’s” digital services.
“PU” aims to ensure that children and young people who engage with our online spaces understand the possible risks they face and how to minimise them. “PU” digital spaces designed for children are subject to “House Rules” which guide participation and are designed to maintain safe and appropriate behaviour. House Rules include restrictions on the types of personal information “PU” allows children to communicate publicly. Content submitted to any specific “PU” children’s sites that may exist is largely pre-moderated in order to enforce the House Rules and protect children.
If your child is participating in online community activities, we recommend you read the House Rules for that space with your child and explain anything to them that they may not understand.
“PU” policy in relation to Cookies, Beacons, Local Storage and Other technologies described below apply to all ABC properties, including those specifically designed for children. Parents and carers should be aware that if their children are using social media sites that were not designed for their age group, they will be exposed to the various tracking and analytic technologies applied by third parties when they access or share “PU” content on or via those sites.
(c) when we collect it in relation to your use of digital services
We also collect information about your use of our digital services including our websites and apps. This is mainly to improve your experience and our digital services. “PU” uses technologies like cookies, web beacons and local storage as part of its digital services. When you use our websites, mobile sites, mobile applications, or applications on any other devices such as Apple TV, Chromecast or PlayStation, these technologies may be used to make our digital services easier to use and more relevant including by customising your user experience.
If you are a registered “PU” online user, we may link the information collected about you to your account.
If you are not a registered “PU” online user, then we will track this information by reference to digital information such as an IP address and will not seek to identify you.
If we do not collect information about you or your use of our digital services, we may not be able to provide you with certain digital services, or we may not be able to tailor or enhance your viewing or listening experience of our digital services.
What are these technologies?
A “cookie” is a small data file downloaded to your computer or device which lets our digital service gather and store information. Your web browser then sends these cookies back to the website or application on each subsequent visit so they can recognise you and remember things such as your personalised settings or preferences.
A “web beacon” is a small amount of code on a web page, application or in an email notification that allows the site to record simple actions of the user such as whether they have viewed a piece of content. These requests can gather information from a website such as: the IP address of your computer, the time the material was viewed, the type of browser used, and the existence of cookies previously set by that server. This is information that is available to any web server you visit and these beacons represent a convenient method of gathering simple statistics and managing cookies.
“Local storage” is a technology that allows a website or application to store information locally on your computer or device.
Why do we use these technologies?
“PU” uses these technologies in a variety of ways to deliver, measure and improve our services and products. These uses generally fall into one of the following categories:
Site and application functionality: To enable interactive features such as forums, voting, some games, and online shopping at the “PU” Shop Online website. For instance, cookies allow our servers to keep track of your customer details between visits to the “PU” Shop Online website. Credit card information is never stored in a cookie. The information stored by the cookie includes data that is provided during online registration processes. They can allow us to remember your place in a video so you can pick up where you left off or remember your preferences and settings so you get your local weather or preferred radio station.
Promotional targeting: Placing cookies on your device also means we can serve you promotional information that you might be more interested in. The promotional information can appear on third party digital services as well as “PU” digital services. It also allows us to control the number of times you see that promotional information and measure how effective the campaign has been.
Audience analytics: The aggregate information gathered from these technologies helps us to improve our products and understand how people use our services. For more information see Section 3 below.
Personalised content and services: Information about what content is viewed allows us to customize our services with more relevant content like tailored trends or recommendations. For example, by knowing what articles you have already read, cookies can help us make smarter and more relevant suggestions about what new content you might enjoy or find useful.
Audience analytics that DO NOT identify you
The analytics systems used by “PU” are cookies, web beacons, local storage, and other technologies which are used to gather information regarding visitor activity on “PU’s” digital services. This is not used to identify personal details but to evaluate and improve our services or to offer improved services based on aggregated visitor trends.
Generally, these services are provided to “PU” by third parties. For instance, “PU” uses Facebook and Google Analytics. More information about how Google uses information from sites or apps can be found here.
Controlling and deleting cookies
Popular browsers will usually give users a level of control over cookies.
You can set your browsers to accept or reject all, or certain, cookies. You can also set your browser to prompt you each time a cookie is offered.
Most cookies are easy to delete, and the ‘Help’ function within your browser should tell you how. Some digital services may not load properly or function as intended if cookies are disabled, however it is up to you to determine the balance of convenience and computer privacy that you are comfortable with.
Some browsers offer ‘Do Not Track’ (DNT) cookies, which send an additional piece of information when a cookie is downloaded that the user does not wish to be tracked. There are no legal or technical requirements regarding the use of a DNT cookie. “PU’s” digital properties do not recognise DNT cookies.
“PU” uses web beacons in combination with cookies to track activity. Turning off a browser’s cookies will prevent web beacons from tracking your specific activity. The web beacon will still record your visit anonymously, however your unique information will not be recorded. If you turn off cookies then we will not be able to personalise or customise content for you, which will affect your user experience.
Cookies used by ”PU”
“PU” uses the following types of cookies:
Session Computer Browser Cookies – Session cookies let you move from page to page without the need to repeatedly sign in. For instance, these cookies are used by the “PU” Shop Online website to keep track of things such as what you put in your shopping cart. A session browser cookie is stored in the browser and deleted when the browser shuts down.
Persistent Cookies – Persistent cookies are used to help us monitor the performance of our digital services by recording your browsing behaviour within the particular digital service. These browser cookies can only be read by the company that places the cookies on the computer. Persistent cookies are saved to the hard drive until they expire. Unlike session browser cookies, they are not deleted when the browser is shut down.
Third party cookies, beacons, and other technologies
“PU” uses a number of suppliers who also set cookies, use beacons, or other technology, on our digital services on our behalf in order to deliver the services that they are providing.
Such third parties may include social media providers, video / audio sharing services or digital advertising agencies and include Google and Facebook.
For instance, if we embed photos and video content from third parties such as Facebook and YouTube, those third parties may have set cookies relating to that content. If you then “share” that content, another third-party cookie may be set by the service you have chosen to share content through.
“PU” cannot control these cookies, and does not block cookies set by third parties in these ways.
Audience analytics that identify you
1.2 Purposes for which we collect, use, and disclose personal information
“PU” Audiences and Customers
The purposes for which we collect, use and disclose personal information include:
to provide our products and services to you (including physical delivery);
to improve our products and services, including conducting surveys;
to tailor and enhance your viewing or listening experience;
to manage our relationship with you, including:
(a) communicating with you about our products or services, including providing information about products or services which we consider may be of interest to you;
(b) billing you for any products or services that we charge for such as “PU” Shops;
(c) investigating any complaints made by or about you;
(d) managing any request by you to return or exchange a product at a later date; and
(e) to otherwise offer you assistance, including, by providing technical support;
to conduct competitions or promotions on behalf of “PU” or industry third parties we have entered into agreements with;
for statistical and research purposes;
to obtain professional services as required including legal, accounting or insurance services;
if permitted or required by law;
otherwise with your consent; or
for purposes directly related to any one or more of the above.
We will not send you unsolicited direct marketing emails, without your prior consent, unless we are permitted to do so by law. We will always give you the option to opt out of further communications. We may send you electronic communications for account administration purposes for so long as you are a registered user or customer of “PU”.
1.3 Disclosure of personal information
We may disclose your personal information that we collect to our:
technology service providers, including, internet service providers, app service providers, cloud hosting service providers, software suppliers, and maintenance and support service providers and security services on a confidential basis so that they can provide services to us;
“PU” Shop Online fulfilment partners such as delivery or Postal services, product distributors, third party suppliers, third party vendors, gift card suppliers and loyalty program suppliers;
marketing, promotions and ratings service providers;
analytics service providers including Facebook and Google Analytics (for more information, you can read the Google Analytics Terms of Service here); and
subscription service providers and their mailing houses.
These third parties may be located in Thailand or outside Thailand, including but not limited to Canada, New Zealand, Australia, Singapore, the UK, the EU, Ireland, Israel, India, and the USA.
“PU” has a statutory obligation to take contractual measures to ensure that its contracted service providers do not do an act or engage in a practice that would breach any relevant Thailand Legislated Privacy Principle if done or engaged in by “PU”.
“PU” will not sell or receive payment for licensing or disclosing your personal information.
“PU” may include links to third party content on its website and in other electronic communications. “PU” does not have any control over the privacy practices of those third parties. Please check the website of each relevant third party for details of their privacy policies. “PU” does not control who links to the “PU” site.
1.4 Options to enter into additional privacy terms
2. Seeking access to, and updating, information we hold about you
You have the right to request access to personal information that is held by “PU” about you. You also have the right to request the correction of any of your personal information that “PU” holds. “PU” will take reasonable steps to make appropriate corrections to personal information so that it is accurate, complete and up-to-date. To seek access to, or correction of, your personal information please contact “PU” by using [email protected]
Personal information that you have provided to the “PU” Shop Online (such as your name, invoice and delivery addresses, phone number, or email address) is accessible by you by registering with “PU” Shop Online. If you register with “PU” Shop Online you will need to retain a username and password. “PU” recommends that you update your personal information if your details change so that our records are accurate, complete and up-to-date.
3. Making a complaint
“PU” welcomes feedback about privacy issues and will attend to all questions and complaints promptly. Please contact our Privacy Officer using the details below if you would like to make a complaint.
4. Privacy contact officer contact details
If you wish to contact our privacy officer, please use the following contact details:
By email: [email protected]
This policy should be read in conjunction with the following related documents:
V1.0 December 2018