PERSONAL DATA PROTECTION POLICY NOTICE
OF MORDEE SERVICE

Updated May 2022.

Chiwiborirak Company Limited and True Digital Group Company Limited (together referred to as "We", “us”, “our”) operates its business in adherence with ethical standards and respect to the privacy of our users. Therefore, this Personal Data Protection Policy Notice (“Policy”) has been provided to inform the users regarding our practices regarding personal data and reasons for collecting, using and disclosing personal data of users and the rights of users as the owner of personal data.

  • This Personal Data Protection Policy Notice applies to personal data collected by Chiwiborirak Company Limited (“Chiiwii”) and True Digital Group Company Limited (“TDG”), the joint data controllers for the “MorDee Service” (“Service”). The users of MorDee Service (“You”) agree and accept that Chiiwii is solely responsible for all health consultation operations under this MorDee service. You are advised to contact:
  • Chiwiborirak Company Limited
    Contact Location: Chiwiborirak Company Limited No. 101, True Digital Park, Pegasus Bld., 5fl. Room 503, Sukhumvit Rd., Bang Chak, Phra Khanong, Bangkok 10260 Thailand
    Contact: Mobile Phone 064-585-0232
  • True Digital Group Co., Ltd.
    Contact Location: No. 101, True Digital Park Building, 9fl.-12fl., Sukhumvit Rd., Bang Chak, Phra Khanong, Bangkok 10260 Thailand
    Contact: mordee@truedigital.com
  • For more information on this Privacy Policy, you are advised to contact the Data Privacy Officer at email address: dataprivacycenter@truedigital.com.
  • The Personal Data Protection Act B.E. 2562 including applicable laws and related regulations (“PDPA”) states that we are permitted to use personal data only if we have a valid reason to do so. This includes sharing within the group of companies under True Corporation Public Company Limited in the Charoen Pokphand Group and/or companies that are not us in our affiliates. The law requires us to have at least one of these reasons:
    • 1. To abide by the contract, we have with you; or
    • 2. Is a legal obligation that we must comply with; or
    • 3. Is necessary for the legitimate interest; or
    • 4. Is necessary for performing duties in implementing a mission in the public interest; or
    • 5. To prevent or suppress a danger to the life, body or health of a person; or
    • 6. When you have given your consent
  • Once we collect, use, disclose (together referred to "Process") your personal data for any of the above reasons, we will inform you of the details and purpose of doing so.
  • In the event that we process your personal data for legitimate interests in accordance with Article 3, we will inform you of the details of how to do so. Such processing of your personal data will not be unduly contrary to your fundamental rights in personal data.
  • We store your personal data for processing for the following purposes:
    • • To provide the service you have applied for and/or to abide by the contract you have with us.
    • • To protect your vital interests.
    • • To verify your eligibility for medical treatment and to take action related to the compensation per the conditions stated in your insurance policy.
    • • Once we have determined that it is necessary for our legitimate interest or third parties who may need to be the recipients of the disclosure.
    • • To allow us to keep you up-to-date on our products and business partners, software update, and upcoming events.
    • • To verify and identify the users, and identify appropriate service.
    • • To notify the users regarding important matters, such as communications to inform the users regarding the purchased product or service, including the notification of changes of the terms and conditions of the service, or changes of our terms, conditions and policies.
    • • To implement the internal purposes, such as internal auditing, data analysis and research to improve our products, service and communications with our customers.
    • • If you participate in prize draws, contests or similar promotions, we may use the information you provide to implement such programs.
    • • To prevent or suppress a danger to the life, body or health of a person.
    • • To carry out our duties in the public interest or perform duties in exercising the powers of the state that have been given to us.
    • • To comply with the law.
    • • To perform an analysis, comparison, risk assessment or interpretation to display your personal data in this application.
    • • To present our products, service and benefits to you.
    • • To prevent any loss and anti-fraud purposes.
    • • To safeguard account and network security, including to protect our service for the benefit of our users.
    • • To combat fraud from online transactions with us. We limit the use of information for anti-fraud purposes only where necessary and within the scope of our assessed legitimate interests to protect our customers and service. As for some online transactions, we may verify the accuracy of the information you provide with commonly accessible sources.
    • • To implement other purposes as permitted by law in collecting, using or disclosing personal data without the consent of the owner of the personal data.
  • Once you register with our application, buy products, download software updates, connect with our service, contact us, including via social media or take part in marketing activities and/or survey, we will collect personal data in connection with our current use of the service and that additional personal data may be required in the future as follows:
    • • Personal Data such as title, first name, middle name, surname, alias (if any), date of birth, gender, age, race, religion country of residence, Data on the document issued by government agencies (such as copy of national ID card, copy of passport, or documents used for identifying and confirming identity of the same characteristic), other KYC, etc.
    • • Contact information such as address per important document, home address, workplace, geolocations, email addresses, phone numbers, Name or user name for contact via electronic communication or online social media (such as LINE ID).
    • • Health data such as weight, height, blood pressure, heart rate, blood sugar level, menstrual history, personal disease history, patient documents, including medical history and treatment information, previous medical diagnoses and medical examinations, current or previous use of certain medications, family health information history, health behaviour may be collected through surveys within the application or other health surveys where you may be asked to fill out or perform such actions through sensor technology, which collects heart rhythm and rhythm-to-beat calculations, etc.
    • • Chat information while using the service and/or chat with our staff through our applications, websites and social media channels such as text data and still images.
    • • Technical data, devices or equipment such as Data of application usage, IP address or MAC address, Cookies ID, Web beacon, Pixel Tag or Software Development Kit (SDK) Device ID, Series and type of devices, network, connection data, Data on access, data on single sign - on (SSO) Log Data on login, access period, usage and usage period of application and website, search history, browsing data Time zone and location data Type and version of plug-in browser, operating system and platform including other technologies on your device used for accessing platform Other technical data from usage on platform and operating system, etc.
    • • Other information such as Record of communication or correspondence between you and us, details on complaints or comments, request for exercising rights, survey results, audio record, photos, video, audio clips, communication record via log / chat bot, photos or video from CCTV, data on registration for joining our activities, and any other data deemed personal data under the PDPA.
  • If you provide Personal Data of any other third party who is family members and / or a Personnel of Juristic Person and / or who has involvement with you to us such as shareholders, directors, authorized persons, reference persons, trade partners, etc., please inform those persons of the details under this Policy and request their consent, if necessary, or apply other lawful bases to ensure that we can collect, use and / or disclose Personal Data of the aforementioned third party.
  • We will collect personal data directly from you and collect it automatically when you access our application or interact with us. We will also collect it from partners and other sources. We rely on and follow processes required by law and only where permitted by law. The details are as follows:
  • Sources of personal data that you create and provide to us.
  • This information is provided by you personally to us and information provided by people related to you or your business, including those authorized by you or acting on your behalf.
    • • When you have registered for our service.
    • • When you communicate with us through the application, email, phone calls and social media.
    • • When you take our surveys or participate in our marketing campaigns.
    • • When you implement any activities on our application, including personal health information, the health information of another person that you record, personal data update, and various settings in the application.
    • • Once you pay for our service, we will collect payment-related information.
  • Sources of Personal Data We Automatically Collect
  • Once you access our application, we will collect your information as follows:
    • • Information of your use of the service.
    • • Information regarding communication with us.
    • • Information related to your device in connection with your communications with us.
  • Sources of personal data that are not collected from you
  • We may receive your personal data from another person if that person has used our products to send gift cards and products or invite you to join our service or forum.
  • We may also verify the accuracy of information obtained from you when registering our applications with third parties for security and fraud prevention purposes.
  • Cookies and Other Technologies
  • We may collect and use cookies and / or any other technologies of similar nature when you use our website and / or application including conducting transactions, using our products and / or services via digital channels and internet network. The collection of cookies and / or use of any other technologies of similar nature will help us to recollect your use and preferences, including analysis of your interest for improvement and development of efficiency of our website and / or application in order to respond to your demand and use so that you can have positive experiences in using our website and / or application. You can learn more details from our “Cookies Policy”. Moreover, we may disclose the data that cannot identify you to data analysis service providers such as Google, both in Thailand and other countries. Google will use technologies and tools for data analysis such as cookies and / or the Software Development Kit (SDK) to monitor and conduct reports of data analysis related to your use of our website and / or application. You can learn details of Google’s data analysis under the heading “How Google uses data when you use your partner’s sites or apps” at www.google.com/policies/privacy/partners or other URL as determined by Google.
  • You may decline of the collection of information via cookies through your browser settings. However, such settings may reduce the optimal use of the website and application.
  • We may from time to time share your personal data with organisations and/or third parties which can be classified as follows:
    • 1. Medical personnel or a health consultant service provider provided within this service
    • 2. Companies under the True Corporation Public Company Limited, companies under the Ascend group, companies under Charoen Pokphand Group
    • 3. Government agency by law
    • 4. Service partners in connection with our application or service such as KYC providers, non-life insurance providers, life insurance providers, Information Technology Service Providers Advertising Marketing and Social Media service providers, Payment and transaction service providers, business consultants, transportation service providers, and pharmaceutical service providers, etc.
  • Therefore, we abide by the contract we have with you and as you request. We will supervise third parties to process personal data in compliance with applicable laws.
  • Disclosure of Personal Data to Service Partners in connection with our Application or Service
  • We may disclose personal data to our various service providers, including but not limited to our non-life insurance, life insurance for the purposes, such as data processing, executing customer orders, delivering the product to you, managing and updating customer information and customer service, evaluating your interest in our products and service and conducting customer research studies or satisfaction surveys. These are our obligations to protect your information and may be located wherever we operate.
  • Miscellaneous
  • We may be required by law to disclose your personal data, legal process, prosecution and/or requests from private and government agencies within or outside your country of residence. Furthermore, we may also disclose information about you if we determine that disclosure is necessary or appropriate for national security, law enforcement, or any other matter of public importance. In addition, we may also disclose the information about you only if it is consistent with applicable law where we consider that the disclosure of the information is necessary for the regulations to our terms and conditions or to protect the performance of duties or our users which include the disclosure the information to the public or state agencies. Moreover, in the case there be a reorganization, business acquisition, or expansion, we may transfer any personal data or entire information to where our business exists.
  • Sharing Data with other Applications
  • You may choose to have your health information shared with other applications that you trust. Once sharing the information, you can choose what information you share with other applications by making it automatic sharing or sharing it manually, which our application will ask you to set up how you would like to share your data.
  • Other applications that can access the information from our application including medical records must provide the personal data protection and data security policy, and you must understand them prior to allowing such applications to access your health data from our application.
  • When you have chosen to share your health data with other applications, the information shared will pass from our application, which is not directly sent to us, to other applications of your choice.
  • Protection of Personal Data
  • We take the security of your personal data very seriously, for example, the application will protect your personal data during transmission using encryption such as Transport Layer Security (TLS). Once we collect your personal data, we will use the limited access computer systems available in the establishment that use physical security measures.
  • When you use some of our products, services or application; or post a message in our forums, chat rooms or social networking services, other users will be able to see the personal data and content that you share and can read, collect or use that information. You are responsible for any personal data you choose to share or submit in these cases, for example, if you provide your name and email address in a message you post to a forum, such information is publicly available, so please be careful when using these features.
  • Period of Retention of Personal Data
  • We will collect your personal data during the period you are our customer or have a relationship with us, or throughout the period required in order to achieve the related objectives of this Policy. Once your relationship with us ends, we will further keep your Personal Data for a period as necessary according to the statute of limitations or for a period as required or permitted by law. We may keep your personal data for five (5) years after the end of the relationship.
  • We will undertake operations through appropriate steps to delete or destroy the Personal Data or make it anonymous when it is no longer necessary or said period ends.
  • You can request User Account closure or deletion of your personal data, by selecting “Contact Personal Data Protection Department” under the menu Profile > Settings > Privacy Settings in the application. You must provide only information as necessary for us to process your request. We will consider the request shortly.
  • We may request any additional personal data as necessary to verify your identity and account ownership to process your request and in accordance with the law.
  • We are obliged to collect personal data by law or to enter into a contract between you and us. If you choose not to provide personal data to us, we may not be able to provide service to you apart from where we use personal data for the conformity to the service contracts and legal compliance. In the event that you do not consent to the collection, use or disclosure of personal data, you can still use our service. You may be less comfortable using the service because we do not have consent to use your personal data to provide the best service.
  • We use your personal data to send you marketing messages where we have your consent, or where it is in “legitimate interests”.
  • Your rights under this item are legal rights that you should be aware of. When the provisions of the Data Subject's Rights Section under the PDPA come into force, you can exercise your rights as stipulated by law in each country and this Policy currently available or to be amended in the future, including criteria determined by us. If you are less than 20 years old, or have limited capacity to perform juristic acts under the law, you may request your father and / or mother, appointed guardian or authorized person to express the intention to exercise these rights on your behalf according to the following details:
  • Right to withdraw consent
  • You are entitled to withdraw the consent that you have previously given to us for a specific purpose at any time during which your Personal Data is held by us, unless there is right restriction by law or there is a contract which is beneficial to you which remains valid.
  • However, the withdrawal of your consent related to and required for the service request may prevent us from complying with the contract or providing services to you, or may cause the transaction or any other related activities to be suspended or temporarily discontinued, or may affect your knowledge of products and / or services, for instance, you may not receive the offer of products and / or services, benefits, promotions or other new offers, or may not receive alternative products or services which are more in line with your needs, or may not receive news and recommendations that are beneficial to you, etc. For your own benefit, you should determine and inquire about the potential impacts before deciding to withdraw your consent.
  • Right to access
  • You are entitled to have access to your Personal Data under our responsibility and to request us to provide you duplication of your Personal Data.
  • Right to data portability
  • You are entitled to request us to send or transfer your Personal Data in our specific electronics format to other data controllers if it can be processed via automated method, and to request Personal Data of said format which is directly sent or transferred by us to other data controllers, unless it cannot be processed due to technical difficulties.
  • Your aforementioned Personal Data must be Personal Data that you have granted consent to us to collect, use and / or disclose or must be Personal Data that we needs to collect, use and / or disclose for your use of our products and / or services in accordance with your intention wherein you are a contract party with us or for undertaking operations per your request before using our products and / or services or must be other Personal Data as determined by competent authorities.
  • Right to object
  • You are entitled to lodge an objection to the collection, use or disclosure of your Personal Data at any time. If the collection, use or disclosure of your Personal Data, to which you lodge an objection, is undertaken under legitimate interest of us or any person or any juristic person, or for public benefit, We shall continue to collect, use and / or disclose your Personal Data only if we can provide legal reasons that the collection, use and / or disclosure of your Personal Data is sufficiently important, or is undertaken for the establishment, defense, use of, or compliance with, the rights to claim in accordance with applicable law, as the case may be. In addition, you are entitled to lodge an objection to the collection, use and / or disclosure of your Personal Data which is undertaken for objectives related to direct marketing or for the purpose of scientific, historical or statistical studies and research.
  • Right to be forgotten
  • You are entitled to request us to delete or destroy your Personal Data or make it anonymous if you believe that your Personal Data has been collected, used and / or disclosed illegitimately, which is not in compliance with applicable laws or if you deem that it is no longer necessary for us to keep your Personal Data under the objectives of this Policy or when you exercise your right to withdraw consent or your right to object as mentioned earlier.
  • Right to restrict of processing
  • You are entitled to request us to restrict the use of Personal Data if we are conducting an investigation per your request to exercise your right to rectification or right to object, or for any other case wherein it is no longer necessary for us to keep your Personal Data and we must delete or destroy your Personal Data in accordance with applicable laws, but you have sought to request us to restrict the use of your Personal Data instead.
  • Right to rectification
  • You are entitled to rectify your Personal Data to keep it accurate, up-to-date, complete and not misleading.
  • You are advised to contact our staff to submit a request for action under the aforementioned rights via email address mordee@truedigital.com. We reserve the right to reject any unreasonable requests. does not comply with the PDPA and/or requests that are not practical. In addition, we reserve the right to reject your request to the extent required by relevant laws. You can lodge a complaint with the Data Protection Agency. personal and/or other entities with oversight of personal data according to the announced channels
  • We do not intend to collect personal data from a child under the legal age limit ("Age Restriction "). If you are under the age limit, please don't use this application and don't give us any personal data.
  • If you are the parent, legal guardian of a child under the age restriction and know that your child has provided us with personal data, please contact us and you can exercise your rights to the extent required by the Personal Data Protection Act and other relevant laws.
  • If you are a child under the age limit and it is necessary to receive the service through our application, we require your father, mother or legal guardian to provide us with your consent to allow us to gain access to your personal data by contacting us at the details set out above in Section 1.
  • We will update this Privacy Policy from time to time to comply with the law changes in regulations or operational requirements. We will clearly announce it through the application, our website and/or notify you via email address. If you do not wish to respond to or accept any updates to this Privacy Policy, you can opt out of the service through our application.