Nuffnang (Thailand) Co. Ltd. (hereinafter referred as “We” or “Us” or “Our“), either itself or through its subsidiaries or licencees, provides online advertising sale and display services (“Services“) in electronic portals such as Nuffnang and ChurpChurp (“Portals“), for publishers (“Publisher(s)“).

We sell “Advertiser(s)” the right to place advertisements (“Ad(s)“) via the Services in various Portals (such as Blogs or Twitter) of our network of Publishers and managed by such Publishers. The Services run on software developed by Netccentric Pte Ltd, its subsidiaries and third party contractors.

The Services are available in various jurisdictions such as Australia, China, Hong Kong, Malaysia, Philippines, Singapore and Thailand. In view of the multi presence, our local subsidiaries or licencees may also be processing your personal information if the Services require. As we continue to expand our business, we will establish more local subsidiaries or appoint licencees. Please visit our website regularly to see our presence.

 

1. COLLECTION OF INFORMATION If you are an Advertiser or a Publisher, during your dealings with us, we may request personal information such as :-
   1. your name, identity card number, email addresses, mailing and billing address, IP address or information about your portals (such as Blogs, Facebook account and Twitter account), including but not limited to your portal’s page impressions, followers or members,
   2. your activities through the Service,
   3. any comments you may send to us and any information you may post to the Portals or a Publisher’s site, and
   4. information collected through the use of Cookies (as defined below).

   The personal infomation as required herein (unless stated otherwise) is obligatory on you and if you fail to provide any information as required, it may affect the Services and/or your application for an account with us.

   We also collect personal information when you:-

   1. register with us to become a Publisher or Advertiser,
   2. provide comments or submit a problem to us or Publisher,
   3. request information from us and provide your name or return contact information, or
   4. respond to special offers, contests or surveys.

   Some of the information collected by us may not be explicitly submitted by you as we also automatically receives and records information on its server logs from your browser, including your IP address, cookie information, the web pages you request, your browser type and language, access times, and the referring website address.

   If you give us information about another person, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:

   • give consent on his/her behalf to the processing of his or her personal information;
   • receive in his/her behalf any data protection notices; and
   • warrant that you have obtained his/her consent for us to store his/her personal information.
2. COOKIES “Cookies” are data files that may be downloaded to your computer when you visit the Portals or a Publisher’s site and permit the Portals to identify your browser whenever you interact with the Portals or a Publisher’s site. We use cookies to recognize repeat visits by users of the Services and to collect information about our users’ interactions with the Services. These cookies contain identification information that enables us to streamline your experiences using the Services and to report such information to Publishers and Advertisers. You may set your browser software to reject cookies, but you may not be able to optimize the features of the Services. In some cases, you may not be able to access the Services if cookies are disabled.
3. EXTERNAL LINKS As a part of the Services, we provide links to web sites operated by third parties. We are not responsible for the information collection or privacy practices or the content of those third party sites.
4. EXTERNAL SURVEYS We collect information through reader surveys published on portals under our network. We retain the right to analyze, process, use and share this information with Advertisers in order to segment the audience of each Portal in the hope of feeding relevant ads to readers.
5. USE OF PERSONALLY IDENTIFYING INFORMATION In general, we may use the information provided to us for the following purposes:-
   1. provide, maintain, protect and improve the Services, to develop new services, and to protect ourselves and our users;
   2. manage your account and provide you with customer support;
   3. develop and display content tailored to your interests on the Portals;
   4. verify your eligibility and deliver prizes in connection with any contests and giveaways that the Portals may have;
   5. enforce any Terms and Conditions between us;
   6. research purposes including historical and statistical purposes;
   7. general operation and maintenance of the Services including audit and tis related portal(s);
   8. provide you with regular communications (other than direct marketing materials) from us relating to the Services; and
   9. investigation of complaints, suspected suspicious transactions and research for service improvement.

   Some of your information such as your name, nickname, picture and site information will be made public in a form of a public profile.

6. DISCLOSURE OF PERSONALLY IDENTIFYING INFORMATION
   1. If you are a Publisher, we may share information about you including your personal details such as name, pictures, contact details and details of your portals such as, but not limited to, page impressions, site traffic, prices, information on publisher site readers, users, followers and members and readership with Advertisers, Publishers or Users. We may share your e-mail address with other Publishers and your traffic data with the Publisher who enrolled you into using the Service.
   2. If you are an Advertiser, we may disclosure your contact information and e-mail address to Publishers on whose sites you have ordered advertisements.
   3. If you are a User, we may share aggregated and non-personally identifiable information about you with Publishers or Advertisers such as the number of users who visit a Publisher’s site or the number of users who clicked on a particular advertisement. Such information does not identify you individually. Further, you are encouraged to review the privacy policies of the Publishers that you access. You should contact Publishers directly and review their privacy policies should you have questions concerning their use of your information.
   4. Other Disclosures. We may disclose your personal information if required to do so by law or if we have good faith belief that such disclosure is necessary to protect and/or defend our rights and interests. We may, as permitted by applicable law, disclose your personally identifiable information to Publishers or Advertisers, or third parties in connection with an investigation of fraud, infringement, piracy, tax avoidance and evasion or other unlawful activity and you expressly authorize us to make such disclosures.
   5. Domestic and International Use. All personally identifying information collected by us may be used in Australia, China, Hong Kong, Malaysia, Philippines, Singapore or Thailand or if the Services are undertaken by us for a foreign Publisher or Advertiser, such information may be transferred to that Publisher or Advertiser outside of Australia, China, Hong Kong, Malaysia, Philippines, Singapore and Thailand and you consent to any such transfer of information outside of your country.
   6. Merger or Acquisition. If we are merged or acquired by another entity, personally identifiable information may be transferred to such entity as a part of the merger or acquisition.
7. REVIEW AND MODIFICATIONS TO YOUR PERSONALLY IDENTIFYING INFORMATION If you are a Publisher or Advertiser, you may add, modify or update your email address, name, mailing address and other contact information by accessing the “My Account” page. It is your responsibility to ensure that the information you have on the Portals is the most up-to-date information as possible. We may retain transactional history in order to document a transaction you may have had with a Publisher or Advertiser. You should contact the Publisher or Advertiser directly in order to access, modify or update your personal information with them.However, we reserve the right to decline to process requests which jeopardize the security and privacy of the personal information of others as well as requests which are impractical or not made in good faith.Where you elect to limit our right to process the personal data, you may contact us in writing. For avoidance of doubt, the limitation does not include processing of mandatory personal data.
8. SECURITY We store all information including personally identifiable information obtained through registration securely and considers it part of the assets of its business. To prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of information, we have put in place physical, electronic, and managerial procedures to safeguard and secure the information it collects online. However, data security is a constantly evolving art and science. You should consider any communication that you transmit to us (such as data, questions or answers, comments, or suggestions) as non-confidential, and agree that we will not be liable or responsible if information that belongs to you is intercepted and used by an unintended recipient.
9. CHANGE TO THIS POLICY If this privacy policy changes in any way, it will be updated on this page. Regularly reviewing this page ensures you are updated on the information which is collected, how it is used and under what circumstances, if any, it is shared with other parties.