Updated 21/06/2024
The combo power international co., ltd. (the ” Company,” “we” “us,” or “our”) recognizes the importance of the protection of personal data for you of our products and services. We know you care how information about you is collected, used, disclosed, and transferred outside. The information you share with us allows us to provide the products and services you need and want appropriately tailored for you, not only from us, but also those within our data ecosystem. “Company” appreciates your trust that “Company” will carefully and sensibly handle your personal data while giving you the very best personalized experience and customer services.
This privacy policy (this “Privacy Policy”) applies to physical stores, websites, mobile applications, call centers, social networking sites, online communication channels, and other locations where we collect your personal data. However, please read this Privacy Policy in conjunction with the terms and conditions of the particular service that you use. (This may be provided separately according to the type of Personal Data that we collect from you)
“Company” reserves the right to modify this Privacy Policy from time to time, so please review it frequently to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on our website or application. We will provide additional notice of significant updates. In case any modification deprives your rights of sensitive data in relation to this Privacy Policy, the Company will first obtain your consent, except as otherwise permitted by law.
1. What Personal Data we collect.
We may collect or obtain the following types of information which may include your Personal Data directly or indirectly from you or other sources or through our affiliates, subsidiaries, business partners or other companies. The specific type of Personal Data collected will depend on the context of your interactions with us, and the services or products you need or want from us and companies in our data ecosystem.
You have the right to choose whether or not to provide the information we request. However, in most cases, if you do not provide your personal information, we may not be able to offer you a product or service or answer your questions. The personal information we collect includes:
1.1. Personal details, such as title, full name, gender, age, occupation, qualifications, job title, position, business type, company name, nationality, country of residence, date of birth, information on government-issued cards, passport, or other identification documents issued by the Royal Government or of equivalent value, etc.
1.2. Contact details, Address for delivery, proof of address, place of work and current address, telephone number, email, ID, Telegram, Facebook account, and other required means of communication.
1.3. Membership details, such as account details, member card number, reward points, member type, customer type, member join/registration date and month, membership period, bank account and payment details, service and product applications.
1.4. Financial details, such as credit card information, bank account details, credit card number, expiration date, payment history, and personal information related to the risk assessment of a business partner, including payment confidence rating and other finance-related details..
1.5. Transaction details, such as details about payment to and from you, payment date and/or time, payment amount, details about refund, refund amount, points, date and location of purchase, purchase/order number, appointment date for service etc.;
1.6. Technical details, such as Internet Protocol (IP) address, cookies, Media Access Control (MAC) address, web beacons, logs, device ID (e.g., International Mobile Equipment Identifier (IMEI), Electronic Serial Number (ESN), Mobile Equipment Identifier (MEID), and Serial Number (SN)), device model and type, software and hardware formats, network and connection details, access details, Single Sign-On (SSO), login log, access time and location, time spent on pages, login data, latitude and longitude, applications downloaded on communication devices, search history, browsing details, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on devices used to access the platform, including any other technical information arising from the use of our platform and systems.
1.7. Behavior details, such as information about your purchasing behavior and data supplied through the use of our products and services.
1.8. Profile details, such as your username, image, order information, order history, previous orders, ordered products, order quantity, product placement, payment location, and user PIN on our system.;
1.9. Usage details, such as Information related to your searches or application usage, use of The Real Reward products and services, products in the basket, products of interest, special program announcements, partner follow-ups (Shop Follow), timestamp of the last click, and any questions in the program or with partners, including affiliates in our database.
1.10. Marketing and communication details, such as your preference in receiving marketing from us, our affiliates, subsidiaries, business partners or other companies, and your communication preferences; and/or
1.11. Sensitive data, such as race, religion, political opinions, fingerprints, facial recognition, person identity information (biometrics), face information from the iris recognition, physical or mental health or condition, genetic data, medical history, disability, and criminal records.
If you provide Personal Data of any third party to us, e.g., their name, family name, address details, and telephone number for emergency contact, family member income, or if you use the service on any of our platforms with your consent, we can access and collect third party personal information relating to you, such as information on name, picture and/or phone number, as well as personal and contact information of family, friends, emergency contact persons, recommended persons or referrals accessible from your mobile number, etc..; please provide this Privacy Policy for their acknowledgement and/or obtaining consents if necessary.
We will collect, use, or disclose your information with your informed consent or as permitted by law. The Real Reward will only collect data of minors or incapacitated persons when authorized by a person with legal authority or custody. The Real Reward will not knowingly collect personal information from customers under the age of eighteen (18) without the consent of their guardians or authorized persons. If The Real Reward receives or discovers a complaint involving such information, we will delete the data, including other relevant information from the application, in accordance with our rules.
2. Why we collect, use, or disclose your Personal Data
1. The purpose for which your consent would be required
Marketing and Communications: We collect, use, and disclose your Personal Data to provide privileges and promotions, discounts, special offers, advertisements, notices, news, information and any marketing and communications about the products and services from us, our subsidiaries, and business partners which we cannot rely on other legal bases.
2. Other Purpose
2.1 To prevent any potential endangerment of life, body, property, or health of any person, including for the public good and to resolve disputes, we are required to collect and disclose your personal information for the following purposes:
1) To provide products and services to you: to enter into and manage our contractual relationship with you; to support and perform activities related to such services or products; to complete and carry out financial transactions and services related to payments, including transaction checks, verification, and cancellation; to process your orders and exchanges of products or services; to provide updates on the delivery of products; to perform internal warehouse activities, including picking, packing, and labeling of packages; to verify warranty periods; and to provide after-sales services, including maintenance and facility reservations.
2) Marketing and Communications: To provide privileges, updates, sales, special offers, promotions, advertisements, notices, information and any marketing and communications about the products and services from us, subsidiaries, and business partners.
3) Registration and Authentication: To register, verify, validate, confirm, identify, and/or authenticate you or your identity.
4) To care for and provide customer service: To communicate with you regarding your use of The Real River services and to handle other requests such as disputes, instructions, or claims, as well as to provide technical support and develop The Real Reward software for improved performance.
3. To whom we may disclose or transfer your personal data
We may disclose or transfer your personal data to the following third parties, who collect, use, and disclose personal data in accordance with the purposes outlined in this Privacy Policy. These third parties may be located in Thailand or areas outside Thailand. You can visit their privacy policies to learn more details on how they collect, use, and disclose your personal data, as you may also be subject to their privacy policies.
3.1. The Real Reward within Combo Power Data Ecosystem
As the Real Reward application is part of the Combo Power data ecosystem, which collaborates and partially shares customer services, products, and systems including website-related platforms and systems, we may need to disclose or transfer your personal data to, or allow access to such personal data by, other companies within the Combo Power data ecosystem for the purposes set out in this Privacy Policy.
3.2. Our Service Providers
We may use other companies, agents, or contractors to perform services on our behalf or to assist with the provision of products and services to you. We may share your personal data with our service providers or third-party suppliers, including but not limited to: (1) Infrastructure, internet, technical, software, website, and IT service providers, (2) Payment service providers, (3) Research agencies, (4) Analytics service providers, (5) Survey agencies, (6) Auditors, (7) Marketing, advertising media, and communications agencies, (8) Call centers, (9) Campaign and event organizers, (10) Sales representative agencies, (11) Telecommunications and communication service providers, (12) Payment, payment system, authentication, and dip chip service providers and agents, (13) Outsourced administrative service providers, (14) Data storage and cloud service providers, (15) Verifying and data checking service providers, (16) Dispatchers, (17)Printing service providers
While providing such services, these service providers may have access to your personal data. However, we will only provide them with the personal data necessary to perform their services, and we request they do not use your information for any other purposes.
3.3. Our Business Partners
We may transfer your personal data to our business partners in the fields of banking, finance, credit, loans, asset management, investment, insurance, credit cards, telecommunications, marketing, retail, e-commerce, warehouse, wellness, lifestyle products and services, spa and fitness, reward and loyalty programs, and data analytics. This includes platform sellers or providers with whom we may jointly offer products or services or whose products or services may be offered to you. Data shared in this way will be governed by the third party’s privacy policy and not this Privacy Policy.
3.4. Social Networking Sites
We allow you to log in on our sites and platforms using social network login systems. By doing so, you explicitly authorize us to access and store public data from your social network accounts (e.g., Facebook, Google, Instagram) as well as other data mentioned during the use of such login systems. Additionally, we may communicate your email address to social networks to identify whether you are already a user of the concerned social network and to post personalized, relevant adverts on your social network account if appropriate.
We also partner with certain third parties that allow you to enroll in their services or participate in their promotions. For example, some companies allow you to use your loyalty program number or online services login to receive or register for their services. Additionally, your social network account provider may allow you to connect your social network account to your online services account. When you enroll in these services, we will share your personal data with third parties. If you do not want to share your personal data in this way, do not provide your loyalty or reward program number to third parties, do not use your online services account to register for third-party promotions, and do not connect your online services account with accounts on third-party services. Data shared in this way will be governed by the third party’s privacy policy and not this Privacy Policy.
3.5. Third Parties Required by Law
In certain circumstances, we may be required to disclose or share your personal data to comply with a legal or regulatory obligation. This includes any law enforcement agency, court, regulator, government authority, or other third party where we believe it is necessary to comply with a legal or regulatory obligation or to protect our rights, the rights of any third party, or individuals’ personal safety, or to detect, prevent, or otherwise address fraud, security, or safety issues.
3.6. Professional Advisors
This includes lawyers, technicians, and auditors who assist in running our business and defending or bringing any legal claims.
3.7. Assignees of Rights and/or Obligations
Third parties as our assignees, in the event of any reorganization, merger, business transfer (whether in whole or in part), sale, purchase, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock, will comply with this Privacy Policy to respect your personal data.
4.International Transfers of Your Personal Data
We may disclose or transfer your personal data to third parties or servers located overseas. The destination countries may or may not have the same level of personal data protection standards. We take steps to ensure that your personal data is securely transferred and that the receiving parties have appropriate protection standards or other legal derogations in place. We will request your consent for cross-border transfers where required by law.
5. How Long We Keep Your Personal Data
We retain your personal data for as long as is reasonably necessary to fulfill the purpose for which it was obtained and to comply with our legal and regulatory obligations. However, we may need to retain your personal data for a longer duration as required by applicable law.
6. Security of Your Personal Data
The Company recognizes the importance of maintaining the security of your personal data. Therefore, we endeavor to protect your information by establishing appropriate security measures in accordance with confidentiality safeguards to prevent loss, unauthorized or unlawful access, destruction, use, alteration, rectification, or disclosure. The Company ensures that the methods of collecting, storing, and processing your personal data, including physical safety measures, follow our information technology security policies and guidelines.
7. Your Rights as a Data Subject
Subject to applicable laws and exceptions, you may have the following rights:
7.1 Access: You have the right to access or request a copy of the personal data we are collecting, using, or disclosing about you. For your privacy and security, we may require you to verify your identity before providing the requested information.
7.2 Rectification: You have the right to have incomplete, inaccurate, misleading, or outdated personal data that we collect, use, or disclose about you corrected.
7.3 Data Portability: You have the right to obtain personal data we hold about you in a structured, electronic format and to transfer such data to another data controller. This applies to personal data that (a) you have provided to us, and (b) we are collecting, using, or disclosing based on your consent or to perform a contract with you.
7.4 Setting: The Real Reward recognizes that privacy concerns vary from person to person. Therefore, The Real Reward provides examples of ways for you to set strict conditions for the collection, use, display, or processing of your personal information, and to manage your privacy settings.
If you have previously agreed to The Real Reward using your personal information for any of the above purposes, you may change your mind at any time by writing or sending an email to The Real Reward.
7.5 Objection: You have the right to object to certain uses or disclosures of your personal data, such as objecting to direct marketing.
7.6 Restriction: You have the right to restrict the use of your personal data in certain circumstances.
7.7 Deletion: You have the right to request that we delete or de-identify personal data that we collect, use, or disclose about you. However, we are not obligated to do so if we need to retain such data to comply with a legal obligation or to establish, exercise, or defend legal claims.
7.7 Lodge a Complaint: You have the right to lodge a complaint with the competent authority if you believe our collection, use, or disclosure of your personal data is unlawful or non-compliant with applicable data protection law.
8.You will be notified when The Real Reward uses your personal information without your consent in the following circumstances
● Personal information important for national security and defense.
● Personal information not identified in statistical or research results that serve the public interest.
● Personal information important for public safety, public health, and significant public interest.
● Personal information related to a criminal investigation, trial, or execution of a judgment.
● Personal information made public at the owner’s discretion.
● Personal information crucial to the security and stability of the products and/or services provided, such as for detection and troubleshooting.
9.Cancellation of The Real Reward Service or Account
Please note that deleting your The Real Reward account will not prevent you from using all products and services. To protect your legal rights and those of others, The Real Reward will decide whether to support your cancellation request based on the services and products you use. For example, if funds from your account are still pending, we may not be able to support your request immediately.
If you wish to delete your The Real Reward account, you can follow the steps in the settings for the account deletion request. The process may take up to one week after requesting the account deletion, especially if your account has remaining points or benefits.
10. Our Contact Details
The Real Reward welcomes all your questions, comments, suggestions, and concerns regarding this privacy issue. If you have any questions about this Privacy Policy, the use of The Real Reward services, or if you wish to withdraw from contact with The Real Reward, or if you would like to make a request regarding the storage of your personal information by The Real Reward, please contact us.
HQ Address :
Call Center :855 (0) 69 623 547
Email : cs@combopowerint.com.kh
