Privacy Policy

How We Protect You

SOTO Holdings, Ltd. and affiliated companies (“SOTO”) are committed to protecting the privacy of information and data that may be used to identify you, your personal information.  SOTO operates a classifieds website identified as BahtSold.com.  The intention of this privacy policy (the “Privacy Policy”) is to disclose our information-gathering practices and describe how we use your personal information in accordance with the Kingdom of Thailand requirements.  The effective date of this Policy is May 1, 2022.

What We Collect

We collect personal information from you if you use our website, fill out forms on our website, or use any of our web-based products or services. The types of personal information we collect include,

• ✓ Payment information processed by our payment processor (SOTO does not retain your full credit card information);
• ✓ Personalization information including, but not limited to, an uploaded profile photo;
• ✓ Identifiers: A real name, alias, postal address, email address, unique personal identifier, online identification, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, current or past job history, or other similar identifiers;
• ✓ Commercial Information: Records of personal property, products or services purchases, obtained, or considered, or other purchasing or consuming histories or tendencies;
• ✓ Geolocation data: Physical location.

How We Use Your Personal Information

The personal information that we collect is used to perform our contractual obligations and for our other legitimate interests.  In some cases, we may ask you for your consent to use your personal information, but any consent will be presented to you separately from this Privacy Policy.  We may use your personal information for purposes including, but not limited to, the following:

• ✓ To deliver services, products, or transactions that you have requested;
• ✓ To improve our website, including upgrading security measures;
• ✓ To send you promotional materials or communications regarding our content and services that we feel may be of interest to you;
• ✓ To evaluate the products and services that we offer and develop new or improved products or services and to better understand SOTO’s business environment;
• ✓ For educational purposes, such as polls conducted in webinars;
• ✓ To conduct general research on topics of interests to SOTO and its customers.

How We Share Your Personal Information

• ✓ We may share your information for any of these purposes with the following individuals and entities:
• ✓ Vendors engaged by SOTO to provide certain services to you, including, but not limited to, payment processing management and server storage. SOTO maintains contracts with our vendors requiring them to only use your personal information as necessary to provide their services and requiring them to comply with the requirements of this Privacy Policy and applicable laws;
• ✓ Services used by SOTO to aid our ability to provide the best possible experience to you;
• ✓ SOTO may need to share your information for law enforcement or other legal purposes. This type of sharing may be necessary in connection with a lawsuit, claim or investigation, governmental inquiry, court order, enforcement of legal rights (e.g., contract terms, intellectual property rights, etc.), safety issue, or other similar legal or security matter.  Sharing your information for these reasons is not a regular event, but could arise from time to time. We will strive to limit the types and amount of information we may need to share for legal purposes to that which is reasonably necessary;
• ✓ We may share (or receive) information about you, including personal contact information, in the event of an acquisition, merger, sale, corporate restructuring, bankruptcy, or other similar event that involves SOTO. If such an event occurs, SOTO will take reasonable steps to require that your information be handled in accordance with this Privacy Policy.

Data Retention

SOTO retains personal information for as long as we have a legitimate business relationship with you or with an organization with which you are affiliated (such as your employer).  We may also retain personal information about prospective customers or prospective employees until we determine that it is unlikely that we will provide you with services and/or employ you. We also may retain your personal information for as long as necessary to comply with our legal or contractual obligations.

Your Rights

If you do not want to receive promotional or marketing communications from SOTO, you may opt-out at any time by clicking the “unsubscribe” link at the end of our emails or by sending us an email to support@bahtsold.com.  If you choose to unsubscribe, we will retain your contact information to ensure that we do not contact you again.

If you are located in the Kingdom of Thailand, you may have the following legal rights under Thai law:

To withdraw consent at any time, if we are processing your personal information on the basis of consent;

• ✓ To access the personal information SOTO has about you;
• ✓ To request that SOTO rectify or erase your personal information;
• ✓ To request that SOTO restrict the way it uses your personal information;
• ✓ To object to the way SOTO uses your personal information;
• ✓ To lodge a complaint with the data protection agency in the Kingdom of Thailand.

Thai residents that would like to request that their data be securely removed from our systems please follow the steps in the dashboard of your account.  If you are unable to remove the data please send a request to support@bahtsold.com and SOTO staff will remove all relevant data, so long as that removal is technically feasible, does not impact the accounting or business practices of our customers, and does not violate other regulatory or legal standards with which SOTO must comply.

Data Protection Officer

SOTO maintains a Data Protection Officer on staff.  For more information, please email support@bahtsold.com.

Security

SOTO uses a number of security technologies and procedures to ensure your personal information is protected from unauthorized access, use, or disclosure. However, we cannot guarantee that third parties will not overcome these measures and gain access to your information. To the fullest extent permitted by law, SOTO disclaims any warranty or guarantee that your information will be protected from misuse, appropriation, alteration, or loss.

Links to External Websites

This website contains links to websites that are not controlled by SOTO.  Please be aware that we are not responsible for the content, security, and privacy practices of external sites. We encourage you to familiarize yourself with the privacy policy of all websites where you submit personal information.

Cookies We Use

We and our authorized partners may use cookies and other information gathering technologies for a variety of purposes.  These technologies may provide us with personal information, information about devices and networks you utilize to access our Websites, and other information regarding your interactions with our Websites. For detailed information about the use of cookies on the Websites, please read and review our Terms and Conditions and this Privacy Policy.

From time to time, SOTO may change or update this Privacy Policy.  We recommend you regularly review this page.  When we update this Privacy Policy, we will also revise the “last updated” date at the bottom of this page.  SOTO will use reasonable commercial efforts to notify you of changes to this Privacy Policy that materially change the disclosures made here.

Contact Information

If you have questions about how we handle your personal data, please contact us by phone or email.

Email:	support@bahtsold.com
Address:	SOTO Holdings, Ltd. Attn: Privacy Team 47 Srisothorn Place Building Sukhumvit Soi 23 Klongtoey nuea, Wattana, Bangkok 10110 Thailand
Last Updated:	May 1, 2022