Privacy Policy

RED ORANGE CO.,LTD(IGLU)

Privacy Policy and Cookie Policy

[3.10.2019]

Background:

RED ORANGE CO.,LTD (IGLU) understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and our obligations under the law.

This Policy applies to Our use of any and all data collected by us in relation to your use of Our Site . Please read this Privacy Policy carefully and ensure that you understand it.

 

Definitions and Interpretation:

In this Policy the following terms shall have the following meanings:

a) Personal Data

 

Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

 

b) Data Subject

 

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

 

c) Processing

 

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

 

d) Restriction of Processing

 

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

 

e) Profiling

 

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

 

f) Pseudonymization

 

Pseudonymization is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

 

g) Controller or Controller Responsible for the Processing

 

Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

 

h) Processor

 

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

 

i) Recipient

 

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

 

j) Third Party

 

Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

 

k) Consent

 

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

 

l) Cookie

Cookie means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. 

m) Our Site

means this website, https://iglu.net

n) We/Us/Our

means RED ORANGE CO.,LTD, a limited company registered in Thailand, whose registered address is 91/11 Moo 5, T.Suthep A.Muang, Chiang Mai 502000 Thailand.

 

 

Information About Us:

1). Name and Address of the Controller

Our Site,https://iglu.net, is owned and operated by RED ORANGE CO.,LTD.

    RED ORANGE CO.,LTD.

    91/11 Moo 5, T.Suthep , A.Muang

Chiang Mai 502000 ,Thailand

Email : [email protected]

Website: www.iglu.net

2). Name and Address of the Data Protection Officer

    Pisit Rattananurak

    91/11 Moo 5, T.Suthep , A.Muang

Chiang Mai 502000 ,Thailand

Email : [email protected]

Website: www.iglu.net

3). Designated EU representative

    eucoop OÜ  

 

 

 

Scope – What Does This Policy Cover? 

This Privacy Policy applies only to your use of Our Site. It does not extend to any websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

 

What Data Do We Collect?

Some data will be collected automatically by Our Site (for further details, please see the section below on Our use of Cookies) , other data will only be collected if you voluntarily submit it via forms and consent to Us using it for the purposes set out below, for example, when contacting us via contact form. Iglu may collect this information in a variety of ways. For example, you may be required to provide the information when submitting requests or application through our website. Also, the information might be contained in your CVs or resumes, obtained from your passport or other identity documents, or collected through interviews, other forms of assessment.

 

We may collect some or all of the following data and divided into 4 main sections:

1 ). Data collection during visiting website

  1. IP address ,which will be anonymised (automatically collected)
  2. web browser type and version (automatically collected)
  3. operating system (automatically collected)

2). Data collection on Job Application 

  1. Full Name
  2. Email
  3. Company name
  4. Phone number
  5. CV/resume

 

3). Data collection in the event of submitting a contact form

  1. Full Name
  2. Email
  3. Company name 
  4. Phone number

4). Data collection in the event of subscribing to our newsletter

  1. Full Name
  2. Email

5). Data collection in the event of submitting a suggestion form 

  1. Full Name (optional)
  2. Email (optional)

 

How Do We Use Your Data?

1). All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.

2). We use your data to provide the best possible services to you. This includes:

  1. Contact you to provide answer to your enquiries.
  2. Supplying Our services to you
  3. Processing job application
  4. Supplying you with email Insert Type of Email e.g. newsletters, alerts etc. that you have subscribed to (you may unsubscribe or opt-out at any time by Insert Description of Unsubscription Method) 
  5. Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;

3). In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the services We can provide you without your consent for Us to be able to use such data.

4).  With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email with information, news and offers on our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.

5). Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:

  • you have given consent to the processing of your personal data for one or more specific purposes;
  • processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
  • processing is necessary for compliance with a legal obligation to which we are subject;
  • processing is necessary to protect the vital interests of you or of another natural person;
  • processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
  • processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

How and Where Do We Store Your Data?

1). We only keep your data for as long as We need to in order to use it as described above in section  “How Do We Use Your Data?“ , and/or for as long as We have your permission to keep it. The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

2). Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to us. If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contract terms between Us and any third parties We engage and the use of the EU-approved Model Contractual Arrangements. Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.

3).  Steps We take to secure and protect your data include:

  • All our data transfer is using SSL/TLS and HTTPS certificates.

4).  Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.

 

Do We Share Your Data?

1).  We may contract with third parties to supply services to you on Our behalf. These may include, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law. We currently contract with:

Third Party 

Data Shared 

Purpose

Third Party’s Privacy policy

Pipedrive EU

postal address: 

Paldiski mnt 80

Tallinn 10617

Estonia

Email – [email protected]

All Data collected in the job application form and contact form 

Customer relationship management platform 

https://www.pipedrive.com/en/privacy

The Rocket Science Group as Mailchimp

postal address: The Rocket Science Group, LLC 675 Ponce de Leon Ave NE Suite 5000 Atlanta, GA 30308 USA

All Data collected in the subscription form  

Construct mailing list to announce our service updates

https://mailchimp.com/legal/privacy/

Atlassian

postal address:Level 6 341 George Street Sydney, NSW 2000 Australia

All Data collected in the suggestion form

Customer relationship management  platform for 

https://www.atlassian.com/legal/privacy-policy

 

2).  We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We will not share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be used within the bounds of the law.

3).  In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.

 

What Happens If Our Business Changes Hands?

1). We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by Us.

2). In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.

How Can You Control Your Data?

1). When you submit information via Our Site, you won’t be given options to restrict Our use of your data, however , if you wish to restrict the usage of the data , please contact at the appointed data protection officer ( DPO )  . We aim to give you strong controls on Our use of your data

Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it

1). You may access certain areas of Our Site without providing any data at all. However, to use all the features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

2).  You may withdraw your consent for Us to use your personal data at any time by contacting Us, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible services to you and some of the data will not be able to be deleted if there is any contradiction with the requirements of legislation, a court order, or a governmental authority.

 

How Can You Access Your Data?

You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at dpo(at)iglu(dot)net , or using the contact details above.

What Cookies Do We Use and What For?

 

LIST OF COOKIES FROM OUR WEBSITE 

 

Cookie Name

First or Third Party ?  

Purpose 

__cfduid

First Party 

used to speed up page load times. According to CloudFlare it is used to override any security restrictions based on the IP address the visitor is coming from. It does not contain any user identification information.

_pk_id.oz1nv4jv5y.b680

First Party 

Analytic using Matomo 

_pk_ses.oz1nv4jv5y.b680

First Party 

Analytic using Matomo 

_pk_testcookie.

First Party 

Analytic using Matomo 

_pk_testcookie.oz1nv4jv5y.b680

First Party 

Analytic using Matomo 

 

Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our services. By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. We do not use third party Cookies on Our Site for analytic of number of visitors to our website, we use first party cookies instead. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site.

Before Cookies are placed on your computer or device , you will be shown a prompt pop-up message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.

1). You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

2). You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies – Microsoft Edge

https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences – Mozilla Firefox 

https://support.google.com/chrome/answer/95647 – Google Chrome

 

3). It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

 

Summary of Your Rights under GDPR

Under the GDPR, you have:

  1. the right to request access to, “deletion of” or “correction of”, your personal data held by Us;
  2. the right to complain to a supervisory authority;
  3. be informed of what data processing is taking place;
  4. the right to restrict processing;
  5. the right to data portability;
  6. object to the processing of your personal data;
  7. rights with respect to automated decision-making and profiling .

To enforce any of the foregoing rights or if you have any other questions about Our Site or this Privacy Policy, please contact Us using the details set out above.