Playboy Condoms Privacy Policy

1. Introduction

Playboy Condoms (“Playboy Condoms”, “we”, “us”, or “our”) respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how Thai Nippon Rubber Industry Public Company Limited (“TNR PLC”) collects, uses, discloses, transfers, stores, and protects personal data when you access or use our websites, online platforms, mobile applications, social media pages, customer support channels, and other services (collectively, the “Services”).

This Privacy Policy is intended to comply with the Thai Personal Data Protection Act B.E. 2562 (2019) (“PDPA”) and to reflect key data protection principles under the EU General Data Protection Regulation (“GDPR”), where applicable, including lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity, confidentiality, and accountability.

As our business may operate internationally, other data protection laws may apply depending on the location of relevant individuals, business partners, service providers, processing activities, or data transfers. Where such laws apply, we will process personal data in accordance with the applicable legal requirements to the extent required by law.

This Privacy Policy is not intended to replace any additional notices, consents, contractual terms, or other requirements that may be required under local data protection laws in specific jurisdictions. Where necessary, we may provide additional jurisdiction-specific notices or terms.

By using our Services, you acknowledge that you have read and understood this Privacy Policy.

2. Data Controller

For purposes of applicable data protection laws, Thai Nippon Rubber Industry Public Company Limited (“TNR PLC”) is the controller of personal information collected through the Services unless otherwise specified.

3. Personal Data We Collect

We may collect different types of personal data depending on how you interact with us and our Services.

Information You Provide to Us

We may collect personal data that you voluntarily provide to us when you contact us, submit an inquiry, interact with us through our social media pages or e-commerce platforms, participate in a campaign or promotion, respond to a survey, submit content, or interact with us as a business customer, distributor, dealer, supplier, or other business partner. Such personal data may include:

• Name;
• Email address;
• Phone number;
• Job title;
• Company name and size;
• Country;
• Customer service communications;
• Product reviews and survey responses;
• Marketing preferences;
• Social media or platform account information;
• Messages, comments, inquiries, and customer support communications;
• Order, purchase, delivery, payment status, and transaction-related information, where applicable.

Although some of this information may relate to a company or business relationship, it may still constitute personal data if it identifies or can reasonably identify an individual.

Information Collected Automatically

When you use our Services, we may automatically collect certain information, including:

• IP address;
• device identifiers;
• browser type;
• operating system;
• referring URLs;
• website activity and usage data;
• cookies, pixels, tags, and similar tracking technologies;
• approximate location derived from IP address or device settings, where applicable.

Product and Promotional Information

We may collect information relating to your interaction with our products, content, or promotional activities, including:

• products viewed;
• product name, product model, lot number, purchase channel, and purchase date;
• details of technical or product usage issues;
• content interactions;
• promotional redemptions;
• campaign participation;
• survey responses;
• engagement with our Services, marketing materials, or social media pages.

Sensitive Personal Data

We do not intend to collect sensitive personal data through our website or general communication channels. Please do not provide sensitive personal data unless it is specifically requested by us and is necessary for the relevant purpose.

Where possible, we will collect general product-related information, such as product name, product model, lot number, purchase channel, purchase date, or details of technical or product usage issues, for purposes such as responding to inquiries, handling product complaints, improving our products and services, and providing relevant product information.

If sensitive personal data is strictly necessary for a specific inquiry, complaint, support request, or other purpose, we will provide a separate notice and request your explicit consent before collecting or using such information, unless otherwise permitted by applicable law.

If you voluntarily provide sensitive personal data that is not necessary for the relevant purpose, we may delete, destroy, anonymize, or disregard such information in accordance with applicable law and our internal policies.

4. How We Collect Personal Data

We may collect personal data directly or indirectly from the following sources:

• when you visit or use our website or Services;
• when you contact us through website forms, email, telephone, social media, or other channels;
• when you submit business inquiries or request information about our products;
• when you interact with us as a distributor, dealer, supplier, customer, or business partner;
• when you participate in surveys, promotions, campaigns, events, or marketing activities;
• when you submit reviews, testimonials, photographs, videos, or other content;
• when you interact with cookies, pixels, analytics tools, social media plug-ins, or similar technologies;
• from our affiliates, business partners, distributors, service providers, or publicly available sources, where permitted by applicable law;
• when you interact with us through third-party social media pages, e-commerce platforms, or online marketplaces, including by sending messages, submitting inquiries, placing orders, or requesting customer support.

5. Purposes and Legal Bases for Processing

We process personal data only where we have an appropriate legal basis under applicable data protection laws. The table below explains the main purposes for which we process personal data and the legal bases that may apply to each purpose.

Where we rely on consent, you may withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of any processing carried out before your withdrawal. However, withdrawal of consent may affect our ability to provide certain services, respond to certain inquiries, or administer certain programs where the relevant processing is necessary for such purposes.

6. Marketing Communications

We may use your personal data to send you marketing communications, product updates, promotional information, campaign invitations, event information, or other business-related communications, where permitted by applicable law.

Where consent is required by applicable law, we will obtain your consent before sending marketing communications. We will not treat your acceptance of our Terms of Use or your use of the Website as consent to receive marketing communications.

You may withdraw your consent or opt out of marketing communications at any time by:

• clicking the “unsubscribe” link in our emails;
• following opt-out instructions in SMS, messaging, or other communications;
• contacting us using the contact details provided in this Privacy Policy.

If you withdraw your consent or opt out of marketing communications, we will stop sending you marketing communications. However, we may still contact you where necessary for non-marketing purposes, such as service-related, transactional, legal, security, or administrative communications, where we have another lawful basis to do so under applicable law.

We will not use sensitive personal data for marketing, targeted advertising, or profiling unless we have obtained your separate explicit consent or are otherwise permitted to do so by applicable law.

7. Cookies and Similar Technologies

We may use cookies, pixels, tags, analytics tools, advertising technologies, and similar technologies to operate, secure, measure, improve, and personalize our Services.

These technologies may be used for the following purposes:

• Operate, maintain, and secure our Services;
• Remember your preferences and personalized settings;
• Measure and optimize website performance;
• Analyze traffic patterns and user behavior;
• Deliver relevant, targeted advertising tailored to your interests.

Depending on the technology and applicable law, we may request your consent before placing non-essential cookies or similar technologies on your device. You may manage your cookie preferences through your browser settings or through our cookie management tools, where available.

Disabling certain cookies may affect the functionality, performance, or availability of some parts of our Services.

Where we use third-party analytics or advertising technologies, such third parties may collect information about your device, browser, interactions with our website, or online activity in accordance with their own terms and privacy policies. Where required by applicable law, such technologies will be used subject to your cookie preferences or consent.

Additional details regarding the cookies and similar technologies we use may be provided in our Cookie Policy or cookie preference tool.

8. How We Share Personal Data

We may disclose or transfer personal data to the following categories of recipients, where necessary and permitted by applicable law.

Service Providers

We may share personal data with trusted third-party service providers that assist us in operating, maintaining, securing, and improving our Services, including providers of:

• Website hosting and cloud infrastructure;
• Analytics and performance monitoring;
• Marketing, advertising, and distribution services;
• Customer support and relationship management;
• Security, IT, and fraud prevention services;
• Survey and promotional campaign administration;
• Social media, e-commerce, and online marketplace platform providers.

Where such service providers process personal data on our behalf, they are required to process personal data only in accordance with our instructions and to implement appropriate confidentiality, security, and data protection measures.

Affiliates and Related Companies

We may share personal data with our affiliates, subsidiaries, parent companies, related companies, or other entities under common ownership or control for purposes consistent with this Privacy Policy, including:

• Daily business operations;
• Corporate administration;
• Data analytics and research;
• Internal marketing activities;
• Regulatory compliance activities.

Business Partners and Distributors

Where relevant to our business relationship or international operations, we may share business contact information with distributors, dealers, commercial partners, suppliers, logistics providers, or other business partners for purposes such as responding to inquiries, managing commercial relationships, coordinating distribution, providing product information, administering business communications, or supporting sales and marketing activities.

Legal and Regulatory Requirements

We may disclose personal data where required by law or where we reasonably believe disclosure is necessary to:

• comply with legal obligations, court orders, regulatory requests, or government inquiries;
• protect our legal rights, property, safety, or business interests;
• detect, investigate, prevent, or respond to fraud, security incidents, or unlawful activities;
• protect the rights, safety, or security of users, business partners, or the public;
• establish, exercise, or defend legal claims.

Business Transactions

Personal data may be disclosed, shared, or transferred in connection with, or during negotiations of, any merger, acquisition, financing, restructuring, reorganization, sale of assets, business transfer, bankruptcy, dissolution, or similar corporate transaction involving our business.

Aggregated, Anonymized, or De-Identified Information

We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you as an individual. This non-personal data may be used for:

• Academic or market research
• Business development and strategic planning
• Product and service improvement
• General marketing purposes

Other Disclosures

We do not sell, rent, or disclose your personal data to unaffiliated third parties for their own independent marketing purposes without your explicit consent, except as otherwise described in this Privacy Policy or as permitted or required by applicable law.

9. International Transfers

Due to the international nature of our business, your personal data may be collected, accessed, processed, stored, disclosed, or transferred in Thailand and other countries where we, our affiliates, business partners, distributors, service providers, technology providers, professional advisors, or other relevant recipients operate.

Before transferring personal data internationally, we will assess whether the destination country, territory, international organization, or recipient provides an adequate or appropriate level of personal data protection as required under applicable data protection laws. Where such adequate or appropriate level of protection is available, the transfer may be made in accordance with applicable law.

Where the destination does not provide an adequate or appropriate level of protection, we will implement appropriate safeguards or legally recognized transfer mechanisms where required by applicable law, such as contractual commitments, data processing agreements, standard contractual clauses, binding corporate rules, certification mechanisms, transfer risk assessments, or other measures recognized under applicable law.

Where no adequacy mechanism or appropriate safeguard is available, we may transfer personal data only where a permitted derogation or exception applies under applicable law, such as where you have explicitly consented to the transfer after being informed of the relevant risks, where the transfer is necessary for contractual purposes, legal obligations, important public interest, protection of life or body, legal claims, or other grounds permitted by applicable law.

We will take reasonable steps to ensure that personal data transferred internationally receives an appropriate level of protection in accordance with applicable data protection laws.

10. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by applicable law.

The retention period may vary depending on the type of personal data, the purpose of processing, the nature of our relationship with you, legal or regulatory requirements, limitation periods, dispute resolution needs, and our legitimate business interests.

When personal data is no longer required, we will take appropriate steps to delete, destroy, anonymize, de-identify, or otherwise securely dispose of it in accordance with our internal policies and applicable law.

11. Data Security

We maintain appropriate administrative, technical, organizational, and physical safeguards designed to protect personal data against unauthorized access, accidental loss, misuse, disclosure, alteration, or destruction.

These safeguards may include access controls, confidentiality obligations, secure storage, encryption or other technical measures where appropriate, internal policies, employee training, and vendor management procedures.

The level of protection may vary depending on the nature, scope, context, purpose, and sensitivity of the personal data processed.

However, no method of transmission over the internet or method of electronic storage can be guaranteed to be completely secure. While we take reasonable steps to protect personal data, we cannot guarantee absolute security.

12. Your Privacy Rights

Depending on your location and subject to applicable data protection laws, you may have the following rights in relation to your personal data:

• the right to be informed about how we collect, use, disclose, and otherwise process your personal data;
• the right to access your personal data and receive a copy of it;
• the right to request correction of inaccurate, incomplete, or misleading personal data;
• the right to request deletion, destruction, or anonymization of your personal data;
• the right to request restriction of the use or processing of your personal data;
• the right to object to the collection, use, disclosure, or processing of your personal data, including for direct marketing, targeted advertising, profiling, or certain data sharing activities, where applicable;
• the right to withdraw consent at any time, where the processing is based on consent, without affecting the lawfulness of processing carried out before such withdrawal;
• the right to request data portability, where applicable;
• the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, where applicable; and
• the right to lodge a complaint with a competent data protection authority, including the Personal Data Protection Committee in Thailand or other supervisory authority where applicable.

To exercise your rights, please contact us using the contact details provided in Section 16 of this Privacy Policy.

Before responding to your request, we may need to verify your identity and may request additional information necessary to process your request. We will respond to your request within the timeframe required by applicable law.

We may refuse, restrict, or charge a reasonable fee for a request where permitted by applicable law, such as where the request is manifestly unfounded, excessive, repetitive, or where we are legally permitted or required to retain the relevant personal data.

13. Third-Party Links and Social Media Platforms

Our Services may contain links to third-party websites, applications, social media pages, e-commerce platforms, or other services, including Facebook, TikTok, Instagram, LinkedIn, YouTube, Shopify, or other platforms.

When you use these third-party platforms, certain activities may be managed by us, such as responding to messages, handling inquiries, processing orders, providing customer support, or conducting marketing activities. Our processing of personal data for these activities will be subject to this Privacy Policy.

Other activities may be carried out independently by the third-party platform, such as account management, payment processing, cookies, analytics, or platform security. Such activities will be subject to the terms, privacy policy, cookie policy, and data practices of that third party.

We encourage you to review the applicable terms and privacy policies of the relevant third-party platform before using its services.

Any use of cookies, pixels, tags, analytics tools, advertising technologies, or similar technologies on our Website is described in Section 7 of this Privacy Policy.

14. Children and Legal Eligibility

Our Website and Services are intended for adult users who have the legal capacity to access information about, purchase, or use our products under applicable law. Our Website and Services are not directed to children or minors.

We do not knowingly collect personal data from children or minors below the applicable minimum age under the laws of their jurisdiction, or from minors where parental or guardian consent is required under applicable law.

If we become aware that we have collected personal data from a child or minor below the applicable minimum age, or from a minor without the required parental or guardian consent, we will take appropriate steps to delete, destroy, or anonymize such personal data, unless we are legally permitted or required to retain it.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our business, Services, data processing activities, legal requirements, or privacy practices.

Any changes will be posted on this page with a revised “Effective Date” or “Last Updated” date.

If we make material changes to this Privacy Policy, we will provide appropriate notice, such as by displaying a notice on our Website, sending an email notification, or using other appropriate communication channels, where required by applicable law.

Your continued use of our Services after the updated Privacy Policy becomes effective means that you acknowledge the updated Privacy Policy. Where required by applicable law, we will obtain your consent before carrying out any new processing activity that requires consent.

We encourage you to review this Privacy Policy periodically to stay informed about how we process and protect your personal data.

16. Contact Us

For privacy-related questions, requests, complaints, or to exercise your rights under applicable data protection laws, please contact:

Thai Nippon Rubber Industry Public Company Limited

1 Charoenrat Road, Thung Wat Don Subdistrict Sathon District, Bangkok 10120 Thailand

Telephone: +66 2210 8888

Email: ir@tnrcondom.com

If you are contacting us on behalf of another person, we may request evidence of your authority to act on that person's behalf.

17. Additional Jurisdiction-Specific Terms

Depending on your location or the nature of our processing activities, additional rights, notices, consents, or disclosures may apply under local data protection laws.

Where required by applicable law, we may provide supplemental privacy notices or jurisdiction-specific terms. If there is any conflict between this Privacy Policy and any applicable supplemental notice, the supplemental notice will apply to the extent of the conflict and only in relation to the relevant jurisdiction or processing activity.

This Privacy Policy is intended to provide a global privacy baseline based on PDPA and GDPR-level data protection principles. It should be read together with any additional privacy policy, cookie notices, consent forms, data processing terms, or other documents that may apply to specific products, services, campaigns, jurisdictions, or processing activities.