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Loxley Business Innovation Privacy Policy Purpose and Scope This Privacy Policy (the “Policy”) sets forth the principles and standards used by Loxley Business Innovation Company Limited (“the Company” or “our”) for the collection, use, disclosure, protection, and management of personal data, in compliance with applicable personal data protection laws, including but not limited to the Personal Data Protection Act B.E. 2562 (PDPA) of Thailand and other relevant international data protection regulations such as the General Data Protection Regulation (GDPR). This Policy applies to all service users (“you” or “Data Subject”) who access our website at https://www.loxley-bi.co.th (“Website”) and all related platforms, applications, and services (collectively, the “Services”). By accessing or using the Website and Services, you acknowledge that you have read, understood, and agreed to be bound by the terms of this Policy. Types of Personal Data We Collect The Company may collect and process personal data across various categories, including but not limited to: Identity Data: Full name, prefix, email address, telephone number, company affiliation, and account credentials. Technical Data: Internet Protocol (IP) address, browser type, device information, access times, and browsing activity. Usage Data: Information related to your interactions with our Website and Services. Communication Data: The content of inquiries, questions, or feedback submitted to us. You are under no obligation to provide personal data; however, the omission of certain data may limit access to some features or services. Children’s Privacy Our Services are not intended for individuals under the age of eighteen (18). We do not knowingly collect or process the personal data of minors. If we discover that such data has been unintentionally collected, we will immediately take steps to delete that information in accordance with applicable law. Legal Basis and Purposes for Processing The Company processes personal data strictly according to the principles of lawfulness, fairness, and transparency. Processing will be conducted under one or more of the following legal bases: Consent: Where you have voluntarily given permission for specific processing purposes. Contract Performance: To fulfill obligations under a contract or to take steps prior to entering into a contract. Legal Obligation: To comply with legal or regulatory requirements. Legitimate Interest: To pursue the Company’s legitimate business purposes, provided such interests are not overridden by your fundamental rights and freedoms. Personal data may be processed for the following purposes: To provide, manage, and maintain the Website and Services. To improve functionality, usability, and user experience. To communicate with users and respond to inquiries or requests. To comply with applicable legal and regulatory requirements. To prevent, detect, and mitigate fraudulent or malicious activities. Data Disclosure and Third-Party Processing The Company does not sell, rent, or trade personal data. Personal data may only be disclosed under limited circumstances, such as: To authorized service providers or data processors acting on the Company’s behalf, subject to binding confidentiality and data protection obligations. To regulatory bodies or law enforcement agencies, where required by applicable law or court order. To protect the rights, property, or safety of the Company, its employees, or Service Users. All third parties engaged by the Company are required to process data solely based on our written instructions and in accordance with relevant personal data protection laws. Data Retention and Storage Personal data will be retained for as long as necessary to fulfill the purposes for which it was collected or as required by law. At the end of the retention period, such data will be deleted, anonymized, or securely rendered inaccessible. The Company maintains appropriate storage and disposal procedures to ensure secure and lawful data handling throughout its lifecycle. Data Subject Request and Right to Erasure Data Subjects may exercise their right to request the erasure or destruction of their personal data by submitting a written request to lbi.support@loxley.co.th. Upon identity verification and approval, the Company will action such requests in compliance with relevant legal requirements and within a reasonable timeframe. Data Subject Rights In accordance with the PDPA and other relevant data protection laws, you may exercise the following rights: Right to Access: To obtain confirmation and copies of the personal data the Company holds about you. Right to Rectification: To request the correction of inaccurate or incomplete data. Right to Erasure (“Right to be Forgotten”): To request the deletion of your data under certain conditions. Right to Restriction of Processing: To limit the processing of data under specific circumstances. Right to Object: To object to data processing conducted under the legal basis of legitimate interest. Right to Data Portability: To receive and transfer your personal data to another data controller where technically feasible. Requests can be submitted to lbi.app@loxley.co.th and will be responded to within the timeframe specified by the relevant data protection laws. Data Security and Protection The Company implements appropriate administrative, technical, and organizational measures designed to protect personal data from unauthorized access, alteration, disclosure, or destruction. Such measures include but are not limited to encryption, access controls, secure servers, and continuous monitoring of information systems. While the Company strives to ensure the integrity and security of all data transmission, complete security cannot be absolutely guaranteed due to the inherent risks associated with internet communication. Data Breach Notification In the event of a data breach or unauthorized personal data disclosure, the Company will promptly investigate the incident, take appropriate remedial action, and notify the affected individuals and relevant regulatory authorities as required by law. Do Not Track (DNT) Setting Our Website does not currently recognize or respond to “Do Not Track” (DNT) signals initiated by browsers. However, we do not engage in behavioral profiling or cross-site tracking activities. External Websites and Third-Party Links The Website may contain hyperlinks to external websites, applications, or services that are not operated or controlled by the Company. We are not responsible for the content, privacy practices, or data protection policies of such third parties. We encourage users to review the relevant privacy policies of those entities before submitting any personal data. Policy Amendments and Updates The Company reserves the right to amend or update this Policy periodically to reflect changes in our business operations, legal obligations, or technological developments. Any amendments will be effective upon their publication on our Website, indicated by the “Last Updated” date above. Your continued use of our Services after such updates constitutes acknowledgement and acceptance of the revised Policy. Contact Us For any questions, concerns, or complaints regarding this Policy or the handling of your personal data, please contact: Loxley Business Innovation Company Limited 📧 Email: lbi.app@loxley.co.th 🌐 Website: https://www.loxley-bi.co.th We are committed to responding to inquiries and resolving complaints fairly, transparently, and in a timely manner, in accordance with applicable data protection laws. Loxley Business Innovation Company Limited is dedicated to managing your personal data responsibly, transparently, and in compliance with relevant privacy regulations. This document was last updated in October 2568 (2025).